The requirements for filing Electronic Export Information (EEI) in the Automated Export System (AES) are the same for both standard and routed export transactions. However, in routed export transactions, it is common for the U.S. Principal Party of Interest (USPPI) to face challenges getting the authorized agent to make necessary EEI corrections.
Authorized agents—whose customer is the Foreign Principal Party of Interest (FPPI)—can have EEI elements that get lost in translation based on different regulation requirements between countries. It is essential that all parties involved take care to work together to ensure the information is accurate and provided in a timely manner.
Obtaining Accurate EEI from Authorized Agents
The Census Bureau’s Trade Regulations Branch (TRB) suggests the following steps for USPPIs to take if they are having trouble getting the authorized agent to correct the EEI.
- First, the USPPI should inform the authorized agent of their responsibility to electronically transmit accurate EEI and any corrections—as soon as they are known. Specifically, Section 30.9(a) of the FTR states, “Corrections, cancellations or amendments to that information shall be electronically identified and transmitted to the AES for all required fields as soon as possible.” Once authorized agents are alerted to corrections, they generally make the EEI updates as required.
- If the USPPI is still unable to get the authorized agent to cooperate—even after providing them with the regulatory requirements—they can contact the TRB for assistance. The TRB can assist by contacting the authorized agent directly. Sometimes, authorized agents are more willing to cooperate after the TRB reminds them they’re required to make corrections to the EEI as needed.
- If the above suggestions fail, the USPPI can refer the matter to U.S. Customs and Border Protection (CBP) to enforce Sections 30.3(c), 30.3(d), 30.3(e), and 30.9(a) of the FTR. The USPPI can submit any suspected FTR violations to CBP through its e-Allegations program.
The TRB strongly recommends the USPPI retain all documentation of export transactions and all communications with the authorized agent. Retaining your records can help mitigate penalties issued by CBP or other enforcement agencies.
Mohawk Global Trade Advisors can help you uncover violations that you may have missed, recommend improvements to your current processes, and train your staff on how to properly file your EEI. Interested in learning more? Let’s talk.