What is the value of your no license required shipment? Is it important?

Of course it is!! The buyer needs to know in order to plan for the duties, the insurance company needs the value in order to properly insure the shipment, and the USPPI uses the information to make sure that the goods are correctly represented in the bill of lading, invoice, etc.  Finally, the U.S. Government needs the information to report trade statistics and enforce export laws.

The question is, what does one report in the Electronic Export Information (EEI) of the Automated Export System (AES), housed within the Automated Commercial Environment (ACE), the government’s single window for reporting export and import information?

The Foreign Trade Regulations (FTR) provide in Section 30.6(a)(17) that the value 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….”

Ok, simple enough, so one then reports the value of all the goods, correct?

If this was the case, then if one was exporting a shipment (for this scenario there are no insurance or shipping costs) that contained spark plugs (valued $2000), carburetors (valued at $5000), and brake pads (valued at $3000), you would report $10,000 for the shipment. Well, not so fast, the government wants you to report only the items that are valued over $2500 [see 15 CFR Part 30.37(a)].  In the scenario above, you would only report two items, the carburetors and the brake pads in the AES.  So it is not necessary to report the spark plugs in the AES, however, it is a good practice to annotate the invoice to indicate that the spark plugs are low valued.  So in addition to annotating the invoice, or bill of lading with the internal transaction number (ITN), you should note: “Remainder of the shipment low valued – No EEI 30.37(a).”  This should alert the CBP officers to the reason that the spark plugs are not reported in the AES, but shown on the invoice.

Next time we will discuss how to report the value for shipments that have insurance and freight cost to the port of export.

By: Joe A. Cortez, Senior Trade Advisor of Braumiller Consulting Group
(Former U.S. Census Bureau Regulations Chief and Trade Ombudsman)