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The U.S. Census Bureau offers free or low-cost instruction to everyone involved in international trade. They provide newsletters, suggestions and recommendations on AES best practices. They have worked diligently to develop regulations that we can read and readily understand.
While Census has done all they can do to prepare companies for filing their Electronic Export Information (EEI) in the Automated Export System (AES), it is the responsibility of an exporter and the respective freight forwarders to develop a response to the changes that occur in the regulations. In this case it is the Federal Trade Regulations or FTR—15 CFR 30.
Shakespeare wrote, "To thine own self be true." This oft-quoted line is applicable to the change in the regulations. Where to start? Start by filling in a basic schematic of who handles the export documentation within your organization. Identify who files the EEI for your export transactions. If it is a freight forwarder, who provides the detail and how is it provided to the freight forwarder or agent who will complete the EEI filing?
Once a schematic has been drawn, then layer on the regulatory requirements. These include, but are not limited, to:
Selecting a Harmonized Tariff Schedule of the US (HTSUS) or Schedule B Code number;
Verifying the country of origin, at minimum, identifying whether the goods are Domestic (D) or Foreign (F);
Identifying whether products being exported are subject to export control or not, such as an Export Control Classification Number (ECCN);
Screening transactions against the U.S. Government's Consolidated List, plus additional sanctions as announced by other agencies such as the Office of Foreign Assets Controls;
Verifying the destination country to eliminate the possibility of shipping to a restricted or embargoed country without the proper license or authorization; and
Establishing who will prepare the Electronic Export Information (EEI) in AES for export transactions.
What often stops companies from going forward is the great unknown of mapping this process, or one of several excuses such as: "I don’t have time to go into all that detail," or "This is a job for someone else."
To jumpstart the process, here's a template with one caveat: IT IS INCOMPLETE! It needs your input and that of others in your firm - such as purchasing, engineering, legal, sales and export compliance - to finalize the who, what and when of filing an EEI.
Step-by-Step: AES Yes or No?
First, identify the classification of each item on a data sheet alternatively on an invoice (whether a proforma, customs or commercial).
Second, identify the country of origin for each line item; at minimum, whether the goods are domestic or foreign. FTR Part 30.6 requires the division of products into a subset of Domestic (D) or Foreign (F). Segregate the products by classification to 10-digits, then into subset by D or F.
Here's an example:
Your customer orders 10 table fans under Schedule B code 8414.59.0000 that are country of origin U.S.A. or (D) and have a total value of $2,400. They also order 10 table fans that have the same Schedule B code 8414.59.0000, but the country of origin is China or (F) with a total value of $2,400.
Although the total value of the fans is $4,800 under 8414.59.0000 would trigger an EEI filing through AES, this exporter will be exempt from filing since neither the Domestic nor the Foreign goods under 8414.59.0000 exceeds $2,500. The Low Value Exemption will be reported on the international bill of lading and other commercial documents as required. The low-value exemption statement is NOEEI Sec. 30.37(a).
Caveat: The Low Value Shipment exemption cannot be applied if the allocated transportation and insurance costs to the port or airport are $100 and applied as follows:
Foreign - $2,400 plus $100 for transport and insurance = $2,500, EEI required
Domestic - $2,400 plus $100 for transport and insurance = $2,500, EEI required
| Product Model | Inside Diameter | Outside Diameter | Thickness |
| PBMF230250140M1G1 bearing | 230 | 250 | 140 |
| PBMF230250100M1G1 bearing | 230 | 250 | 100 |