EEI Filing: What U.S. Exporters Must Know Before Shipping

You ship $5,000 worth of goods from the U.S. Your freight forwarder handles everything. Three months later, you receive a penalty notice from U.S. Customs and Border Protection (CBP). The charge: failure to file Electronic Export Information.

This guide explains what EEI filing is, when it's required, who's responsible, and how to avoid costly penalties.

What is EEI filing and why does it matter?

Electronic Export Information (EEI) is the digital record of goods leaving the United States. It replaced the paper-based Shipper's Export Declaration (SED) and must be filed through the Automated Export System (AES) before shipment departure. The U.S. Census Bureau uses this data for trade statistics, while CBP uses it to enforce export controls.

According to the Foreign Trade Regulations (15 CFR Part 30), EEI filing serves two primary purposes:

• Statistical reporting: Tracking U.S. export volumes and destinations

• Export control compliance: Ensuring restricted items don't reach prohibited parties or countries

When is EEI filing required?

EEI filing is required when the value of goods in a single commodity classification (Schedule B number) exceeds $2,500. This threshold applies per commodity, not per shipment. According to 15 CFR 30.2, the requirement triggers regardless of transportation mode—ocean, air, rail, or truck.

Here's a quick reference:

• Value over $2,500 per Schedule B: EEI required

• Value $2,500 or under: Generally exempt (exceptions below)

• Export license required: EEI required regardless of value

• ITAR-controlled items: EEI required regardless of value

• Shipments to Canada: Exempt for most commercial goods

The Canada exemption, outlined in 15 CFR 30.36, applies only to goods that don't require an export license and aren't controlled under the International Traffic in Arms Regulations (ITAR). Rough diamonds and goods transiting through Canada to third countries also require filing.

Who is responsible for filing EEI?

The U.S. Principal Party in Interest (USPPI) bears legal responsibility for EEI filing. In most export transactions, this is the U.S. seller or manufacturer. According to 15 CFR 30.3, the USPPI can authorize a freight forwarder or customs broker to file on their behalf, but liability remains with the USPPI.

This is where many exporters make a critical mistake. They assume that hiring a forwarder transfers responsibility. It doesn't.

As trade compliance firm Descartes notes: "The USPPI is ultimately responsible for the accuracy and timeliness of EEI filing, even when an agent files on their behalf."

To authorize a forwarder to file:

• Include explicit EEI filing authorization in your Shipper's Letter of Instruction (SLI)

• Provide complete and accurate export data

• Confirm the filing was completed before departure

• Obtain the Internal Transaction Number (ITN) as proof of filing

The ITN is a 15-character confirmation code issued by AES upon successful filing. No ITN means no proof of compliance.

What are the filing deadlines?

EEI must be filed before the goods leave the United States. According to 15 CFR 30.4, specific deadlines vary by transportation mode and cargo type:

• Vessel cargo: 24 hours before loading (or departure for non-FROB cargo)

• Air cargo: 2 hours before departure

• Truck/rail to Canada or Mexico: 2 hours before crossing

• ITAR-controlled items: 8 hours before export for all modes

Filing after departure is a violation, even if the goods are properly documented otherwise. Late filing penalties begin accumulating immediately.

What happens if you don't file or file late?

Penalties for EEI violations are per shipment, not per company. According to CBP enforcement guidelines and the Census Bureau's Foreign Trade Regulations, penalties include:

• Late filing: Starting at $1,100 per day (inflation-adjusted rates may be higher)

• Failure to file: Up to $10,000 per violation

• Willful violations: Up to $10,000 and/or 5 years imprisonment

• Knowingly filing false information: Up to $10,000 and/or 5 years imprisonment

The penalties are civil, but repeat violations or intentional falsification can trigger criminal prosecution. CBP can audit export records up to 5 years after the export date.

Consider this scenario: You export 10 shipments over 6 months, each valued at $5,000, without filing EEI. Each shipment is a separate violation. Potential penalty: $100,000.

How do you file EEI correctly?

EEI is filed through the Automated Export System (AES), accessed via the ACE (Automated Commercial Environment) portal. You can file directly or authorize an agent. According to Trade.gov, the filing process requires:

• USPPI information: Name, address, EIN or SSN

• Consignee information: Ultimate recipient details

• Commodity details: Schedule B number, quantity, value

• Transportation information: Carrier, port of export, destination

• License information: If applicable

Upon successful submission, AES returns an Internal Transaction Number (ITN). This number must appear on the bill of lading or air waybill. The format is X + 14 digits (e.g., X20250205123456).

Common filing errors include:

• Wrong Schedule B classification

• Incorrect commodity value

• Missing or wrong consignee details

• Filing after departure

• Not including ITN on shipping documents

The forwarder assumption trap

One of the most common compliance failures occurs when exporters assume their freight forwarder will handle EEI filing automatically. This assumption creates liability exposure in several ways:

• No explicit authorization: Without written authorization in the SLI, the forwarder may not file

• Incomplete data: Forwarders file based on information you provide—if it's incomplete, the filing may be rejected or incorrect

• Communication gaps: The forwarder may assume you're filing directly, while you assume they're handling it

• Liability misconception: Even when the forwarder files, you remain legally responsible

Best practice: Confirm EEI filing responsibilities in writing before shipment, and always obtain the ITN as verification.

What about shipments to Canada?

Canada is the largest U.S. export destination, with U.S. goods exports reaching $349.9 billion in 2024 according to the U.S. Trade Representative. Most commercial shipments to Canada are exempt from EEI filing under 15 CFR 30.36.

However, the exemption does not apply to:

• Goods requiring an export license

• ITAR-controlled defense articles

• Rough diamonds

• Goods destined for third countries via Canada

• Goods moving through Foreign Trade Zones

If any of these conditions apply, EEI filing is mandatory regardless of the Canada destination.

EEI filing checklist for exporters

Use this checklist before each shipment:

• Confirm shipment value exceeds $2,500 per Schedule B number

• Verify destination (Canada exemption applicable?)

• Check if export license or ITAR controls apply

• Include EEI filing authorization in SLI if using a forwarder

• Provide accurate Schedule B codes, values, and consignee data

• Confirm filing completion before departure deadline

• Obtain and record ITN

• Include ITN on bill of lading or air waybill

• Retain export records for 5 years

EEI filing is a compliance requirement, not an optional step. Whether you file directly or through a forwarder, the responsibility—and the liability—stays with you.