EEI Filing in AES: A Guide for Forwarders and Foreign Buyers Shipping From the US

Electronic Export Information (EEI) must be filed in the US Automated Export System (AES) when a commodity line is worth over $2,500 per Schedule B or HTSUSA code, and whatever its value when a mandatory requirement applies, for example a shipment needing a BIS licence. Only parties in the United States may file: the US seller (USPPI), its US agent, or a US agent authorised by the foreign buyer. A UK forwarder or buyer that controls the shipment therefore works through a US authorised agent in what the rules call a routed export transaction. Sources: Census Quick Guide to 15 CFR Part 30 (April 2026) and 15 CFR 758.1.

Why a UK-based team cannot simply file itself

Under § 30.3(a), AES filers are the US Principal Party in Interest (USPPI), the USPPI's US authorised agent, or the US authorised agent of the Foreign Principal Party in Interest (FPPI). An authorised agent must be physically located in, or otherwise under the jurisdiction of, the United States and hold a power of attorney (POA) or written authorisation (WA).

15 CFR 758.1(e) sets the export control conditions: the filer must be in the United States when filing and must be a certified AES participant. The person who transmits the EEI is responsible for its truth, accuracy and completeness, except where they can show they reasonably relied on information supplied by others. For a UK forwarder, this usually means appointing, or working with, a US partner office that holds the authorisation and transmits the filing.

Standard or routed? Incoterms don't decide

A common assumption on the UK side is that buying on EXW or FCA terms makes the export the buyer's problem. The Census Quick Guide and Trade.gov both state that Incoterms and terms of sale do not determine the type of export transaction, as they have no regulatory basis. What matters is who controls the movement of the goods:

• Standard transaction: the USPPI controls the movement and files the EEI or authorises an agent. If an agent files, the USPPI provides the POA/WA and makes the licence determination where a licence is required.
• Routed transaction: the FPPI (for example a UK importer) controls the movement and authorises a US agent to facilitate the export and file the EEI. The FPPI may instead authorise the USPPI to file. The parties stay the same; their responsibilities change.

Applying the $2,500 test

A shipment is everything sent from one USPPI to one ultimate consignee in one destination country, on a single conveyance, departing the same day. The low-value exemption (§ 30.37(a)) applies per Schedule B/HTSUSA code, not to the total: in a mixed shipment, only lines valued over $2,500 must be filed. Goods of domestic and foreign origin under the same code are reported separately, and filing is needed when either exceeds $2,500.

Example (assuming no mandatory filing applies): a UK distributor buys a consignment with one line at $4,100 and another at $1,900, total $6,000. Only the $4,100 line is reported in AES, because $4,100 > $2,500 and $1,900 ≤ $2,500. Value for this purpose is the selling price in US dollars plus inland freight, insurance and other charges to the US port of export.

The ultimate consignee is the party abroad that ultimately receives the goods, not a forwarding agent. The Census guide's example: a Mexican company orders $6,000 of tyres from a US company and has them shipped directly to an Australian buyer; the Australian company is the ultimate consignee. The same logic applies when a UK trader has goods drop-shipped to a customer in another country.

When value doesn't matter

Mandatory filing (§ 30.2(a)(1)(iv)) applies regardless of value and overrides the exemptions. It covers shipments requiring a BIS, State Department (ITAR), DEA, NRC or other federal licence; ITAR items that are licence-exempt (except as noted in the ITAR); rough diamonds; and used self-propelled vehicles. Section 758.1(b) adds the EAR cases, several of which matter for UK-bound or UK-routed goods:

• 9x515 and “600 series” items, regardless of value or destination, including exports to Australia, Canada and the United Kingdom;
• items transshipped through Australia, Canada or the United Kingdom to a third destination, where a direct shipment would require EEI or a licence;
• exports under License Exception STA or the VEU authorisation;
• exports where a party is on the BIS Unverified List;
• exports of CCL items to China (including Hong Kong), Russia or Venezuela, subject to one exemption in § 758.1(c)(4);
• all exports to Country Group E:1 or E:2.

The Canada exemption, briefly

US-origin shipments with Canada as the ultimate destination are exempt from EEI (§ 30.36), except under the mandatory rules. The exemption does not apply to goods stored in Canada but bound for third countries, or to goods moving through Canada to a third destination, which matters if your supply chain consolidates UK-bound cargo in Canada. Exempt shipments still carry a legend such as NOEEI 30.36, and under 15 CFR 758.1(d) the licence authority must appear on the loading document.

Timing and proof of filing

An accepted filing generates an ITN (Internal Transaction Number) to be passed to the carrier, which must not load without it or an exemption legend. A fatal error blocks export until fixed. Postdeparture filing (up to five calendar days after export) is reserved for approved USPPIs, so a UK buyer's agent should not plan on it.

Checklist for UK forwarders and buyers

1. Decide who controls the movement: if you do, it is a routed transaction.
2. Appoint a US authorised agent with a POA/WA that expressly covers EEI filing.
3. Ask the US seller for the Appendix C data, especially ECCN or EAR99, licence code and value.
4. Check each line against $2,500, separating domestic and foreign origin.
5. Screen for mandatory filing triggers, including 600 series items and transshipment via the UK.
6. Diarise the filing deadline for the transport mode.
7. Keep the file for five years from the date of export (§ 30.10).

The US export basics knowledge base answers questions like “Above what shipment value must I file EEI?” or “Who is responsible for EEI in a routed transaction?”, with references to the Census guide and the eCFR.

This guide summarises US rules and is not legal advice; UK customs and export formalities are outside the scope of this knowledge base. Read the Census Quick Guide to 15 CFR Part 30 for the full text.