Most exports from the United States require that the Electronic Export Information (EEI) be filed through AESDirect on the Automated Commercial Environment (ACE) portal. Depending on the circumstances of the export—Is this a routed export transaction?—a filing must be done by the exporter (also known as the U.S. Principal Party in Interest or USPPI), the freight forwarder, or some other agent.
Even if your company isn’t doing its own EEI filing, it behooves you to set up an ACE account so you can obtain and examine the ACE reports for all your exports. I have seen the look of shock and surprise on the faces of trade compliance professionals when they review their reports and see what information has been filed using their companies’ tax ID numbers.
ACE Reports for Exporters
There are three useful ACE reports: the 201 Filer Report, the 202 USPPI Report, and the 203 Routed Report. You can use these reports to identify whether a forwarder appropriately filed the EEI as a routed transaction or not and to examine shipping data to determine if a consolidation is better than an individual shipment to an ultimate consignee.
One exporter’s Shipper’s Letter of Instructions (SLI) were instructing their buyers’ forwarders to indicate a routed transaction on the EEI filing and stated the Incoterms rule was Ex Works (EXW). When reviewing their ACE reports, this exporter discovered the forwarders were selecting “non-routed” on all the EEIs filings with this exporter name and address as the USPPI.
Once you have the ACE reports in a spreadsheet format, it is relatively easy to validate whether the EEI filer—your forwarder or the buyer’s forwarder—have accurately submitted the data for your firm. The reports identify by Internal Transaction Number (ITN) a separate line for each Schedule B or Harmonized Tariff Schedule of the U.S. for each EEI. This allows you as the USPPI to easily count the number of filings, identify whether corrections were made by the filer for non-routed transactions, the value of filings, identify did the filing, and other details.
One USPPI discovered that someone else’s shipments were associated with their tax identification number on several shipments. Another USPPI discovered that a business unit that had been sold was still using the former owner’s tax ID number instead of the tax ID number of the new owner on the EEI.
By reviewing the reports, it is possible to validate the total value of your exports by shipment. One USSPI discovered that their SLI was lost for a few shipments; unfortunately, the forwarder didn’t file an EEI for the total value of each shipment. They only used the value from the first commercial invoice, thus they underreported the value of the shipment by several thousand dollars.
Another USPPI discovered that there were individuals in their firm who were shipping small packages to customers that required an EEI. They hadn’t contacted trade compliance to seek assistance; they decided to use a courier company’s portal to authorize the shipments. Trade compliance wasn’t notified and didn’t know there was someone else in the company who was shipping goods subject to an EEI filing.
Purchasing, engineering and sales are some of a company’s departments that might generate international shipments requiring an EEI. For the USPPI in this example, the ACE reports allowed their trade compliance department to provide the appropriate guidance to others in their firm regarding international shipments.
Auditing Your ACE Reports
It's much easier to review and audit the EEIs using ACE-generated reports if you add columns to your spreadsheet to indicate receipt of documentation from the forwarder such as the international bill of lading with either an ITN or EEI exemption statement.
Reviewing and auditing is enhanced if you add a separate tab in the spreadsheet for when VLOOKUPs are used to match HTSUS or Schedule B classifications and when ECCN, EAR99, USML or other export control designations are compared to the data in the ACE report.
These and other issues are uncovered when the ACE data has been retrieved and reviewed.