- Start from scope, not from value. The Foreign Trade Regulations open with a broad obligation rather than a threshold:
That clause is the reason a small direct-to-consumer seller cannot assume the export rules belong to somebody with a freight desk. The exemption analysis comes after scope, not instead of it.“…for all exports of physical goods, including shipments moving pursuant to orders received over the Internet.”
15 CFR 30.2(a)(1), General requirements for filing Electronic Export Information, eCFR, October 2026 - Classify each product line to a Schedule B number before anything else. The HS versus HTS versus Schedule B comparison explains why the export number is not simply the import code copied across, and the US HTS Code Lookup plus the HS Code Finder help establish a candidate line from material and function. Treat the result as a candidate until it is confirmed against the current official schedule, because the whole value test is applied per line.
- Apply the threshold line by line, to one USPPI, one ultimate consignee, on one exporting conveyance. The exemption text is explicit that the comparison is not made against the shipment total:
So a shipment with one line at $3,400 and three lines at $600 each produces one reportable line and three exempt ones, and the total invoice value tells you nothing useful on its own.“This exemption applies to individual Schedule B numbers or HTSUSA commodity classification codes regardless of the total shipment value.”
15 CFR 30.37(a), Miscellaneous exemptions, eCFR, October 2026 - Check the mandatory categories before relying on the exemption. 15 CFR 758.1(b) lists the situations that require a filing whatever the goods are worth, including exports that need a license application, exports to Country Group E:1 or E:2, exports under License Exception Strategic Trade Authorization, and shipments to parties on the Unverified List. The ECCN versus HS code versus EAR99 reference is the right place to establish whether a control classification exists at all, because a no-license-required position is a finding, not a default.
- Check the destination rule separately from the value rule. 15 CFR 758.1(b)(10) requires a filing for items on the Commerce Control List going to certain destinations regardless of value, which means a $90 shipment and a $9,000 shipment can carry the same obligation. A destination rule that applies regardless of value cannot be satisfied by an exemption that is built on value.
- Do not read the Canada exemption too widely. 15 CFR 30.36 exempts shipments whose country of ultimate destination is Canada, but it carves out goods sent for storage in Canada and ultimately destined for a third country, and goods moving through Canada to a third destination. A Canadian warehouse in a North American distribution chain is therefore not automatically an exempt shipment, and the USMCA origin data elements are a different question from the filing question.
- Keep the line value consistent with the commercial document. The Commercial Invoice Generator keeps description, quantity, unit value, currency, origin, and candidate code on one line, which is exactly the structure the filing record needs. Do not substitute a customs valuation position for the export value without recording the reason; the Customs Value Calculator is an estimate aid for the import side, and the two questions are related but not interchangeable.
- State the authority on the loading document when no filing is required. 15 CFR 758.1(d) requires the export authority for all items to be entered on the loading document, such as the cargo declaration, manifest, or air waybill, by the person preparing that document. This is the step most often skipped by sellers who correctly concluded that no filing was needed: the conclusion is right, and the paperwork is still incomplete.
- Confirm who files and who carries the proof. The International Trade Administration states that the USPPI, or the authorised U.S. agent, prepares the filing and provides the proof of filing, exclusion, or exemption citation to the carrier, which then cites it on the commercial loading document before loading. Put that handoff on the shipment calendar, because a carrier that has not received the citation cannot load the goods.
- Reconcile the whole packet before it leaves the building. The documents needed for international shipping checklist and the customs document pack keep the invoice, packing list, and declaration views on the same underlying lines. Postal routes add their own layer, which the CN22 versus CN23 comparison covers, and the commercial invoice and HS code note explains what the invoice itself must show.
- Store the record and re-check it when the inputs move. A filing position rests on a classification, a value, a destination, and a control determination, and any one of them can change between shipments. Keep the dated record with the sources used, review it when the schedule revision or the destination rule changes, and route corrections through the corrections page rather than editing history silently.
Guide
EEI Filing in AES: When a U.S. Ecommerce Export Needs It
When a US export needs an Electronic Export Information filing in AES, how the $2,500 threshold is applied per Schedule B line, and which records to prepare before the carrier loads the goods.
Answer Summary
Preparation checklist
The Electronic Export Information is filed in the Automated Export System, and it is filed for physical goods leaving the United States, including orders that arrive through a web store rather than a purchase order.
The familiar $2,500 figure is a per-line exemption, not a shipment-level free pass. Each Schedule B number is tested on its own, so a shipment worth far more than $2,500 can still contain reportable lines and exempt lines at the same time.
Mandatory filing categories override the exemption completely. A license requirement, a controlled destination, or an agency permit produces a filing obligation whatever the value is.
An exemption is a position you have to state, not silence. Where filing is not required, an exemption citation still has to reach the carrier so it can appear on the loading document.
Required fields or decision table
Fields to prepare before the document draft
| Field or decision | What to prepare |
|---|---|
| Schedule B number | The ten-digit export classification for the goods, line by line. It is the export-side counterpart of the import HTS line and it drives the value test, so an approximate or missing number makes every downstream decision unreliable. |
| USPPI and consignee | The U.S. principal party in interest, meaning the party that receives the order and benefits from the export, and the ultimate consignee abroad. For a marketplace order the USPPI is usually the seller of record, not the fulfilment centre that packed the box. |
| Line value and currency | The value of the goods under each Schedule B number, in the transaction currency, together with the rate used. The value test runs on this figure, so it must match the commercial invoice rather than a retail price or a marketplace payout. |
| Country of ultimate destination | Where the goods will finally be consumed or further processed, which is not always the country on the shipping label. Transshipment through a third country does not change the ultimate destination. |
| Country of origin | Where the goods were produced, supported by a production or supplier record. Origin and destination answer different questions, and mixing them up is the most common data defect in an export packet. |
| License authority | The export control classification when one applies, the license code or license exception used, or a no-license-required position. This field decides whether the value exemption is even available. |
| Filing method and proof | Whether the filing is transmitted through AESDirect or a direct connection to AES, and the proof of filing, exclusion, or exemption citation that will be handed to the carrier. |
| Carrier and loading reference | The carrier, the booking or air waybill reference, and the date the goods are loaded. The filing has to be in place before loading, so this is a deadline field rather than a tracking detail. |
| Retention record | The filed data, the exemption citation used, the invoice, and the classification record kept together. A filing decision that cannot be reconstructed months later is difficult to defend. |
Step-by-step preparation
How to prepare the draft
Ecommerce example
How this looks in a seller workflow
A U.S. seller ships one carton to a customer in Germany. The carton holds three product lines under three different Schedule B numbers: line A at $3,400, line B at $1,150, and line C at $620. The invoice total is $5,170, which is well over the figure most sellers remember, and the shipment is still not automatically a single filing question.
Line A exceeds the per-line exemption on its own, so it is reportable. Lines B and C sit below it and are exempt unless a mandatory category applies to either of them. That means the seller needs the line values separated before the filing decision can be made at all, which is also why an invoice that shows only a lump total is a problem for this workflow rather than a formatting preference.
Now change one fact. Suppose line B is an item that requires a license application. The value of that line no longer matters: the mandatory category governs, and the exemption never becomes available for it. The same result follows if the destination rule applies regardless of value. This is the reason the sequence is scope, then classification, then mandatory categories, then value, and never value first.
The last step is the one that gets missed. Even where lines B and C are exempt, the export authority for those items still has to be noted on the loading document, and the carrier still needs the citation before loading. The packet is complete when the invoice, the classification record, the filing or exemption position, and the carrier handoff all describe the same three lines.
- Split the shipment into Schedule B lines with individual values.
- Test each line against the per-line threshold.
- Check mandatory categories for every line, whatever its value.
- Apply the destination rule separately from the value rule.
- Note the authority on the loading document and hand the citation to the carrier.
Verification checklist
Review the export record before the carrier loads the goods
- Each product line carries its own Schedule B number, and the number is recorded as a candidate with the facts that supported it.
- The USPPI is identified as the party that received the order, and it is not assumed to be the warehouse that packed the carton.
- Line values match the commercial invoice, and no retail price or marketplace payout figure has been substituted.
- The per-line threshold has been tested per USPPI, per ultimate consignee, per exporting conveyance, and not against the shipment total.
- The mandatory filing categories have been checked for every line, including lines that fall below the threshold.
- The destination rule has been checked independently of value, with the country of ultimate destination rather than the ship-to label.
- Where the Canada exemption is relied on, the storage and transshipment carve-outs have been ruled out.
- Where no filing is required, the exemption citation and the export authority have been given to the carrier for the loading document.
- The filing or exemption position, the invoice, and the classification record are stored together with the date and the sources used.
Source-backed checks
What external guidance supports this workflow?
- 15 CFR 30.2: general filing requirementEstablishes that the filing applies to exports of physical goods including orders received over the Internet, names the parties who may file, and lists the categories that require a filing regardless of value.
- 15 CFR 30.37(a): the low-value exemptionThe operative exemption for lines at $2,500 or less, including the statement that it applies per Schedule B number regardless of total shipment value.
- 15 CFR 30.36: shipments destined to CanadaThe Canada exemption and its two carve-outs: goods stored in Canada but ultimately destined elsewhere, and goods moving through Canada to a third destination.
- 15 CFR 758.1: EEI filing to the AESThe Bureau of Industry and Security conditions that require a filing regardless of value, the per-Schedule-B threshold for commodities subject to the EAR, and the notation requirement on export documents.
- Trade.gov: Electronic Export InformationAgency guidance on the filing, the Schedule B requirement, the ITN handoff to the carrier, postal-route obligations, and the situations where a filing is not required.
- BIS: licensing overviewThe agency entry point for determining whether a license is required, which is the question that decides whether the value exemption is available at all.
Internal workflow links
Use the same catalog data in the next review step
- Create a classification casePaid workspace: retain product facts, code candidates, evidence, and risk notes in one review record.
- Run a catalog reviewPaid workspace: review repeated SKUs and platform CSV rows with source-separated credits and history.
- Open reviewed recordsPaid workspace: keep reviewed fields and mapped exports available for later shipment work.
- Compare plansCompare one-time and monthly credits for repeated customs-data workflows.
- Official sourcesVerify current agency requirements against the primary source before filing or shipping.
- MethodologySee how TariffCatalog separates facts, candidates, estimates, and final filing decisions.
- CorrectionsReport an outdated source or unclear workflow for editorial review.
Common mistakes
What to avoid
- Applying the $2,500 figure to the shipment total and concluding that a $9,000 carton is one filing question.
- Assuming a direct-to-consumer order from a web store sits outside the export rules because no purchase order was issued.
- Treating a low line value as decisive while ignoring a license requirement that applies regardless of value.
- Using the country on the shipping label as the country of ultimate destination.
- Reading the Canada exemption as unconditional and ignoring the storage and transshipment carve-outs.
- Copying the import HTS code across as the export classification without checking the export schedule.
- Concluding correctly that no filing is needed, then failing to give the carrier the exemption citation and export authority.
- Filing or exempting a shipment from a lump-sum invoice with no per-line values to test.
Editorial
Editorial review note
Written by the TariffCatalog Editorial Team for ecommerce document preparation workflows. The page is designed as a preparation checklist, not a filing outcome.
Maintained by Ryan Cole, with review focused on ecommerce catalog, document, and source-check workflow clarity.
Document requirements may be required differently by carrier, destination, shipment value, and product facts. Use the methodology, sources, and corrections pages to understand how the page is maintained.
Official source note
References to verify
Use official sources, carrier guidance, postal operator rules, and destination requirements to verify before filing or shipping.
USITC HTS
Use this official source when checking final classification, duty treatment, or customs requirements.
CBPUse this official source when checking final classification, duty treatment, or customs requirements.
EU TARICUse this official source when checking final classification, duty treatment, or customs requirements.
UK Trade TariffUse this official source when checking final classification, duty treatment, or customs requirements.
FAQ
Common questions
What is an EEI filing in AES?
The Electronic Export Information is the export data set filed in the Automated Export System. It is used to collect trade statistics and for export control purposes, and it records the parties, the classification, the description, the quantity, the value, and any license authority for the goods leaving the United States.
Is the $2,500 threshold per shipment or per product line?
Per product line. The exemption is written around an individual Schedule B number or commodity classification code, and the regulation states that it applies regardless of the total shipment value. A shipment above the threshold can therefore contain both reportable and exempt lines, so the invoice has to be split by line before the test can be applied.
Do small ecommerce orders from a web store need an EEI filing?
Not automatically. A filing is generally required for physical goods leaving the United States, including orders received over the Internet, when a line exceeds the value threshold or a mandatory category applies. An order arriving through a web store is not a filing exemption, so the line-by-line test still has to be run.
When is a filing required regardless of value?
A filing is required regardless of value in several situations, including exports that need a license application, exports to certain controlled country groups, exports of enumerated controlled items, exports under Strategic Trade Authorization, and transactions involving parties on the Unverified List. Some destination rules also apply regardless of value. The list is in 15 CFR 758.1(b) and the categories in 15 CFR 30.2(a)(1)(iv).
Do shipments to Canada need an EEI filing?
Usually not, when the country of ultimate destination is Canada. The exemption has carve-outs: goods sent for storage in Canada but ultimately destined for a third country, and goods moving through Canada to a third destination, are not covered and must be reported like any other export. A Canadian warehouse in a wider distribution chain therefore needs the destination chain checked, not just the ship-to address.
What do I give the carrier if no filing is required?
An exemption citation and the export authority for the items, so the carrier can cite them on the loading document. The notation requirement is separate from the filing requirement, and where filing is not required the export authority still has to be entered on the loading document by the party preparing it.
Is the Schedule B number the same as the HTS code?
No. The Schedule B number is the U.S. export classification maintained for statistical reporting, while the HTS line is the import classification used for duty. They follow the same international structure at the heading level and diverge further down, so an export workflow should not reuse the import code without verifying the export classification line.
Disclaimer
TariffCatalog provides informational tools and preparation workflows only. Verify final classification, rates, document requirements, and filing treatment with official sources or licensed professionals.