The International Trade Blog Export Compliance
What Is an EEI Filing?
On: August 1, 2022 | By: David Noah | 4 min. read
Are you adrift in the sea of export acronyms? Like many industries there are scores of acronyms that get bandied about like tennis balls at Wimbledon. Some of them you probably have heard of. Others only come up in specific circumstances.
One of the most important of these acronyms is EEI, which stands for Electronic Export Information. You’ve probably heard it used along with another set of acronyms—AES, ACE and SED. Let’s take a look at what it means and why it’s important.
What Is EEI?
The Electronic Export Information (EEI) is the export data that must be filed through the Automated Export System (AES) whenever an AES filing is required. The U.S. Foreign Trade Regulations require an AES filing for exports to anywhere other than Canada if the value of the exported goods grouped by Schedule B number is more than $2,500, or if the goods require an export license.
There are many other nuances of when an AES filing is required, so if you aren’t sure when to file, download our free white paper:
The Census Bureau uses these filings to calculate U.S. trade statistics, and Customs and Border Protection (CBP) uses the data to help ensure compliance with U.S. export regulations.
For those of us who’ve been involved in exporting for a while, we know the electronic AES filings replaced the old paper Shipper’s Export Declaration (SED) form, which officially went away in 2008. (For an export form that has been extinct for so long, I’m surprised by how often people still ask me about the SED!)
AESDirect and the Transition to ACE
When AES became mandatory in 2008, exporters (or their freight forwarders) typically used the Census Bureau’s AESDirect website to file. That old legacy system was shut down in April 2016 when AESDirect was rebuilt and added to the Automated Commercial Environment (ACE) platform operated by CBP.
The move from the AESDirect legacy system to the new AESDirect on the ACE platform is part of the effort to make ACE the primary interface in which U.S. importers and exporters file their import and export information. The government’s goal is to streamline the reporting process, eliminate paper and more easily ensure compliance with U.S. laws and regulations.
We’ve published several articles about the transition to ACE, and about some of the new features of the ACE platform. We’ve also uploaded a video showing how easy it is to use Shipping Solutions software to file through AESDirect via the ACE portal.
Who Files the EEI?
In a standard export transaction, it is the responsibility of the U.S. Principal Party in Interest (USPPI) to submit the EEI through AESDirect. However, the USPPI can give their freight forwarder (or some other third party) a power of attorney (POA) or written statement authorizing them to prepare and file the EEI on their behalf. (In most cases, the USPPI is the same as the exporter.)
In this case where an exporter is relying on a third party to submit the EEI filing, they should provide them with a Shipper's Letter of Instruction (SLI) that includes all the export data that is required. The SLI also usually includes the written authorization required for the third party to file. (You can download a sample SLI here.)
In a routed export transaction, however, the Foreign Principal Party in Interest (FPPI) must provide a POA or other written authorization to submit the EEI to either the USPPI or a U.S. Authorized Agent. (In most cases, the FPPI is your ultimate consignee or foreign customer.)
I agree with the Census Bureau's recommendation that the USPPI should request the POA to file through AES on behalf of the FPPI instead of relying on an agent. That way the USPPI will know the EEI is filed accurately and mitigate their risk for compliance errors. I write about this at length in this article: Why I Hate Routed Export Transactions.
Required EEI Data
The Foreign Trade Regulations list dozens of specific pieces of information about the export transaction that must be included in your AESDirect filings, and several more conditional fields that may be required depending on how you are shipping, what you are exporting, and who you are shipping to.
If your shipment is a routed export transaction and your foreign customer’s freight forwarder has gotten written authorization to file through AESDirect, you are still required to provide about a dozen data elements, so the forwarder can file the correct information. Again, an SLI is used to do this.
You’ll find these required data fields, as well as your other responsibilities in a routed export transaction, in this blog post: Standard vs. Routed Export Shipment: What's the Difference?
I’m not sure I’ve ever written an article that included so many different acronyms. (I think I’ll submit it to Guinness World Records to see if I can be included in their next book!) In the meantime, if you find all these acronyms to be confusing, check out this cheat sheet of common exporting acronyms.
To learn more about EEI, AES and ACE, check out our newly updated free AES white paper, Filing Your Export Shipments through the Automated Export System (AES), or watch the webinar by clicking the link below.
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This article was first published in August 2016 and has been updated to include current information, links and formatting.