Alphabet Soup (Continued)

Exporters know that EEI (Electronic Export Information) must be filed in the Automated Export System (AES), also known as the Automated Commercial Environment (ACE) , which is a US Customs and Border Protection (CBP) system. Finally, the EEI replaced the old yellow paper Shippers Export Declaration (SED) a number of years ago. Got all that?

I have found that most clients are quite proficient with the system and are able to process their filings easily. In many companies, however, EEI filings are forgotten after they go through and are not audited for accuracy. If you have a formal Export Compliance Program, which is highly recommended, EEI audits are probably included. If not you are at risk for fines and penalties.

Here is an example of a common filing error for which you may be in violation without realizing it. According to 15CFR part 30.6 the value reported in the EEI must include inland freight, insurance, and other charges to the US port of export. So simply entering the Commercial Invoice value in the EEI is a mistake unless these charges are also on the CI.

(17) Value. In general, the value to be reported in the EEI shall be the value of the goods at the U.S. port of export in U.S. dollars. The value shall be the selling price (or the cost, if the goods are not sold), plus inland or domestic freight, insurance, and other charges to the U.S. seaport, airport, or land border port of export. Cost of goods is the sum of expenses incurred in the USPPIā€™s acquisition or production of the goods. Report the value to the nearest dollar, omit cents. Fractions of a dollar less than 50 cents should be ignored, and fractions of 50 cents or more should be rounded up to the next dollar.

Ad Hoc Logistics can audit your EEI filings and help you avoid fines and penalties. Contact mitch@adhoclogistics.com for immediate assistance.