Effective July 2, 2008 electronic AES filing is mandatory for all modes of transport, with September 30, 2008 being the enforcement date.
According to the new regulations, Internal Transaction Number (ITN) is the only acceptable proof of filing citation that can be used
For vessel cargo, the US Principal Party in Interest (USPPI) or authorized agent shall file Electronic Export Information (EEI) as required by 15CFR30.6 and provide the filing citation or exemption legend to the exporting carrier 24 hours prior to loading cargo on the vessel at the US Port where cargo is laden; for Air Cargo no later than two (2) hours prior to scheduled departure of the aircraft.
External Transaction Number (XTN) will no longer be accepted.
If you are using CMS AES filing facility you are already in compliance as far as EEI filing is concerned. If you are not filing EEI for cargo which is included in your consolidation you need to obtain a valid ITN from your co-loader or shipper and provide it to the carrier 24 hours prior to loading.
CMS will be updating your software in the next few days to properly display "proof of filing citation" on shipping instructions to carrier as well as on the un-freighted consolidated manifest.
In addition to above a new penalty structure has been put in place; $1,000 for each day of delinquency up to $10,000 per violation. When you fail to file or file false/misleading information civil penalty shall apply which can carry $10,000 per violation or imprisonment up to five (5) years.
You can obtain a copy of Federal Register 15CFR30 on our web site under AES.
If you have any questions regarding this notice or if you wish to use CMS AES filing facility call us at 908-688-0555 ext 221
June 27, 2008