The Census Bureau has issued a final rule clarifying who is responsible for filing Electronic Export Information (EEI) when goods pass through the US on their way to another country. These changes, effective September 15, 2025, are designed to remove confusion and make compliance more straightforward for importers, exporters, and logistics providers.
Takeaways
Clearer USPPI responsibilities—Customs brokers, warehouses, and foreign-trade zone operators may now serve as the US Principal Party in Interest (USPPI) in certain in-transit scenarios. The rule confirms that they must have the necessary authority and share accurate data when filing EEI.
Refined definitions—One definition was removed, one revised, and 19 others updated to align terminology and reduce ambiguity.
Improved guidance—The rule clarifies filing requirements for routed exports, DEA-controlled items, split shipments, exclusions, and voluntary self-disclosures.
Balanced enforcement—Census emphasized that when a USPPI reasonably relies on others for product details, this context will be considered in any penalty review.
The final rule also reflects public feedback, with many commenters asking for clearer language, training resources, and recognition of how USPPIs obtain data from other parties in the supply chain.
For companies moving goods through the US, the rule provides long-needed clarity on who must file export data and how. That means fewer gray areas, better compliance planning, and reduced risk of penalties.
If you’re dealing with in-transit shipments or trying to interpret how these export filing rules apply to your operations, reach out to our experts today.