• Export from US: Export code C66 when exporting under SCAL

    Question: Any knowledge on C66 would be appreciated. Does it matter what the value is, meaning if EEI filing is under $2500, can we not exclude anymore because of these new requirements? Answer 1: Unless YOUR SPECIFIC LETTER RECEIVED says something to the contrary, normal AES filing rules apply. So the $2,500 AES filing exemption […]

  • routed transaction

    Question: Who dictates if a shipment is routed or non-routed? Is it USPPI or the FPPI? Answer 1: The FPPI nor the USPPI actually dictate if a shipment is routed or non-routed. The shipment is routed if provisions of the regulations are followed. The structure of your transaction will guide you to look for certain […]

  • Multiple Legal Entities Centralized Customer Service team

    Question: Hoping to gain insight.   We have a centralized customer service function who supports multiple legal entities. Example:  Primary Company #1: ABC, Inc.; Legal Entity #2: DEF, Inc.; Legal Entity #3: GHI, Inc. Invoices from this centralized function all list our primary company’s logo and company name with a central accounting function for payment, with […]

  • Company located outside of the U.S. Files EEI

    Question: We have a contract with ocean carrier to arrange transportation from US origin to foreign destination and issued POA for their EEI team to file EEI on behalf of our company (USPPI).  I have been advised the EEI team is physically located outside of the U.S.  Are the persons, physically in a different country, […]

  • AES/EEI filings to China/Hong Kong

    Question: Are EEI filings required for EAR99 shipments to China valued under $2500 ? I thought the rule only pertained to ECCNS  in Supplement 2 , but my colleague said the rule had changed and included EAR99 items as well now. Answer 1: No.  As you state, filing is required for anything other than EAR99. […]

  • How to show a surcharge on the SLI/EEI filing

    Question: I have a question for the membership surrounding surcharges to customers listed as a separate line item on the export commercial invoice.  For international customers this charge shows up separately on the SLI form without HTS or product weight that is associated with the items listed on the commercial invoice. If we just list […]

  • EEI filing – Re-export of an imported item for repair

    Question: We are exporting a product that our company imported for repair but was not repairable and is not covered under warranty, so the technical team is sending it back as is but they charged the customer a nominal diagnostic evaluation fee. The subject product is licensable, FTR Section 30.29 states that EEI filing for […]

  • Exports to a Maquiladora – SLI Filing Responsibility

    Question: I am a new employee at a company who ships to their sister company in Mexico 3 times a week.  I have been receiving copies of the EEI filings.  I received a copy of one that was filed for less than $2500.  This error raised my curiosity as to how this company operates. I […]

  • Record of EEI Filing

    Question: My new company (the USPPI) has not been diligently obtaining copies of the EEI filings from freight forwarders. To avoid extra work pulling these records retroactively, some of them (including a major express courier) are attempting to substitute actual EEI printouts with reports in excel that do contain all the required data elements. Census […]

  • Regular exports vs EEI filings

    QUESTION: I think we are all familiar with the FTR 15 CFR Part 30 requirement related to the $2,500 value threshold and EEI filing requirements.  Only a US entity can be the USPPI in a EEI filing or if it is exporting an article that requires an export license.  If not a US entity, a broker or […]

  • Should EEI be filed per city or per country?

    QUESTION: My company ships product via vessel. We have a customer that always issues 2 BLs, one per consignee, they are the consignee on both but 2 different addresses in different cities, same port, same country. Freight forwarder has always filed 2 EEI’s, 1 per address. When trained years ago this is what was taught. […]


    QUESTION: For the following scenarios, would like to ask the membership to identify the ultimate consignee type for the EEI filing. Our EU business receives orders from customers. They then order from us.   We receive the order in the U.S., know the names of final customers, screen the customers.  We file the EEI and […]