Most Miami export shipments valued above $2,500 per Schedule B number require Electronic Export Information (EEI) to be filed in the Automated Export System (AES) before the cargo leaves the United States. You file through ACE AESDirect, you file it by a deadline that depends on your mode of transport, and the carrier cannot legally load the goods without the resulting Internal Transaction Number (ITN) or a valid exemption citation on the bill of lading.
For an export gateway like Miami, that single requirement touches almost every ocean container leaving PortMiami and nearly every air pallet leaving MIA. Below is what South Florida exporters need to have right in 2026.
When EEI is actually required
EEI filing is triggered by the Foreign Trade Regulations (15 CFR Part 30). The core rules:
- Value threshold. Filing is required when the value of goods classified under a single Schedule B or HTS number, shipped from one exporter to one consignee on one conveyance, exceeds $2,500.
- License-controlled goods. If the shipment requires an export license or a license exception under the EAR or ITAR, EEI is required regardless of value — including $200 worth of controlled parts.
- Destination. Shipments to Canada are generally exempt below the license trigger. Shipments to Puerto Rico and the U.S. Virgin Islands are not foreign exports but still require EEI under the same value rules.
- Rough diamonds, used vehicles and certain self-propelled equipment carry their own filing requirements with no value floor.
If none of these apply, you cite an exemption on the transport document instead — commonly “NOEEI 30.37(a)” for low-value shipments.
The Puerto Rico trap
South Florida shippers routinely assume a domestic move needs no filing. It does. Cargo moving from Miami to San Juan above the value threshold requires EEI even though it never leaves U.S. customs territory. If you run that lane, read our guide to freight shipping from Miami to Puerto Rico before you book.
Filing deadlines by mode
The deadline is measured against departure, not against your booking:
- Vessel: file and receive the ITN no later than 24 hours before cargo is loaded.
- Air: no later than 2 hours before departure.
- Truck: 1 hour before arrival at the border.
- Rail: 2 hours before the train departs.
- Mail and pipeline follow separate timelines under 30.4.
Vessel cargo is the one that bites Miami exporters. A 24-hour pre-load window means your Schedule B classification, value and consignee details must be settled well before the cutoff at the terminal, not on the day of the sailing.
Who files: USPPI, agent, or routed transaction
In a standard export, the U.S. Principal Party in Interest (USPPI) — usually the seller receiving the primary benefit — either files directly or authorizes a forwarder to file with a written power of attorney. In a routed export transaction the foreign buyer selects the forwarder, and the filing obligation shifts to that agent, but the USPPI must still supply accurate data elements and is entitled to a copy of the filing.
Whichever structure applies, your freight forwarding partner should confirm in writing who is filing before the container is packed. Ambiguity here is how shipments miss the 24-hour vessel cutoff.
Data elements that cause the most rejections
Fatal errors and warnings in AES cluster around a handful of fields:
- Schedule B / HTS number. Wrong classification is the most common cause of amendments. It also flows into duty and license determinations.
- Value. Report the value at the U.S. port of export, excluding international freight and insurance — not simply your commercial invoice total if that invoice is quoted on a delivered basis. Your Incoterms choice determines what belongs in that number.
- ECCN and license type. Defaulting everything to “EAR99 / NLR” without a real classification is a compliance exposure, not a shortcut.
- Ultimate consignee type. Direct consumer, government entity, reseller and other are not interchangeable.
- Quantity and unit of measure must match the Schedule B requirement, not your packing list convention.
Penalties and correction windows
Civil penalties under the FTR can reach $1,100 per day for late filings, capped at $10,000 per violation, with substantially higher exposure for false statements or failure to file on license-controlled goods. Corrections should be made in AES as soon as the error is discovered — 15 CFR 30.9 requires amendment promptly, and voluntary self-disclosure is treated far more favorably than a discrepancy found during an audit.
Practical workflow for a Miami export
- Classify the goods and confirm licensing before quoting.
- Confirm in writing who files EEI — you or your forwarder.
- Book the vessel or flight and note the true AES deadline, not the terminal cutoff.
- File in ACE AESDirect and capture the ITN.
- Put the ITN or exemption citation on the bill of lading or air waybill.
- Retain the filing and supporting documents for five years.
If your cargo consolidates with other shippers before sailing, the timing gets tighter still — see how Caribbean export consolidation from Miami compresses the document window.
Frequently asked questions
Do I need to file EEI for a shipment worth less than $2,500?
Usually no. If the value per Schedule B number is $2,500 or less and the goods do not require an export license, you cite an exemption such as NOEEI 30.37(a) on the transport document instead of filing. Licensed or controlled goods must be filed at any value.
How long before my vessel sails do I have to file?
For vessel cargo you must file and receive the ITN at least 24 hours before the cargo is loaded aboard the ship. Air is 2 hours before departure, truck is 1 hour before arrival at the border, and rail is 2 hours before the train departs.
What happens if I file EEI late?
Late filing can draw civil penalties of up to $1,100 per day, capped at $10,000 per violation, and the carrier may refuse to load without an ITN. Correct or amend the filing in AES as soon as you discover the error, because voluntary correction is treated more favorably than an error found in an audit.
Need an export partner in Miami?
Go Freight is an asset-based 3PL at 3300 NW 110 St, Miami, FL 33167, handling export drayage, CFS consolidation and forwarding for South Florida shippers. Request a freight quote or call (786) 445-0150.