ITN vs exemption legend: an ITN proves that Electronic Export Information was filed and accepted in AES; an exemption legend such as NOEEI § 30.37(a) states on the shipping documents that no filing was required.
What is an ITN (Internal Transaction Number) in exports?
An Internal Transaction Number (ITN) is the number the Automated Export System (AES) generates to confirm that an Electronic Export Information (EEI) filing was accepted and is on file (15 CFR 30.1). It is the AES proof of filing citation: the evidence, on the shipping documents, that the export was reported before the goods left the United States.
What an ITN looks like
The Census Bureau describes the format: the letter X, then the year, month and day AES accepted the filing, then six digits the system assigns. A filing accepted on March 8, 2019 could carry X20190308366903, so an ITN is X followed by 14 digits. On the bill of lading it is written as "AES" followed by the ITN, for example AES X20170101987654, the model in Appendix B to 15 CFR part 30. Filers in ACE AESDirect see the ITN on screen and get it by email once the filing is accepted.
When there is an ITN
Only when EEI has been filed. The most common trigger is value: filing is required when the goods under a single Schedule B or HTS number, from one USPPI to one consignee on one conveyance, are worth more than $2,500 (15 CFR 30.37(a)). That test applies line by line, regardless of the total shipment value. The other triggers, such as export licenses, are on the Automated Export System (AES) page. Find the Schedule B number with the Schedule B finder.
Deadlines by mode
Under 15 CFR 30.4(b)(2), the exporter or its agent must file and hand the carrier the ITN or exemption legend:
- Vessel: 24 hours before the cargo is loaded on the vessel at the US port
- Air: at least 2 hours before the aircraft's scheduled departure
- Truck: at least 1 hour before the truck arrives at the US border
- Rail: at least 2 hours before the train arrives at the US border
- Used self-propelled vehicles: filed, and the citation given to CBP, at least 72 hours before export (30.4(b)(4))
Approved USPPIs may file up to five calendar days after export for most shipments (30.4(c)); their documents then carry an AESPOST citation instead of an ITN.
Where the ITN goes
15 CFR 30.7(b) makes the USPPI or its authorized agent responsible for putting the proof of filing citation or exemption legend on the first page of the bill of lading, air waybill, export shipping instructions or other commercial loading documents, and for giving it to the exporting carrier. The carrier annotates it on its outbound manifest and presents it to CBP at the port of export without material change.
Exemption legends instead of an ITN
When no EEI is required, the documents carry a legend from Appendix B to part 30 instead:
- NOEEI § 30.37(a): low-value shipments, every Schedule B line at $2,500 or less
- NOEEI § 30.36: exempt shipments to Canada
- NOEEI § 30.37 followed by the paragraph letter: the other exemptions in 30.37(b) to (y)
Common mistakes
- Using the low-value legend on a shipment where one Schedule B line is over $2,500, because the invoice total looked small
- Leaving the EEI unchanged after the booking, consignee or quantity changes. The filer must transmit corrections as soon as they are known, and failing to correct EEI is a violation (15 CFR 30.9)
- Sending the ITN after the carrier's documentation cut-off, when the bill of lading is already being drafted
AES replaced the paper Shipper’s Export Declaration; the ITN is what took the place of the stamped form. On exports from the US to India, send the ITN or the exemption legend with your shipping instructions so it can go on the bill of lading. See USA to India shipping.
Related terms
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