Customs Update: Export Manifest is Coming - Are You Prepared?

For several years now, U.S. Customs and Border Protection (CBP) has been testing and developing requirements for electronic transmission of export manifest.

The long history of pilots includes the Advance Export Information (AEI) program, the Automated Export System (AES), and finally the Automated Commercial Environment (ACE) AESDirect portal.

Just recently, CBP announced the extension of its latest electronic export manifest pilot program, known as EEM (Electronic Export Manifest). This announcement should be seen as one of the final steps before ACE EEM is fully implemented by CBP.

It is anticipated that EEM submission will follow the same guidelines as import (AMS), with submission required 24 hours prior to loading on the vessel.

How does this impact me – a carrier – and what can I do to prepare?

Today, vessel operating carriers can submit their manifest via email using the DIS (Document Imaging System). It will soon be announced that the DIS option carriers have come to rely on will be discontinued and carriers will be expected to either transmit electronically or go back to the printed paper submissions. The timing of this is expected to be before the preloading and EDI requirement is enforced.

If your NVOCC customers are not planning to file electronically, the carrier will need to obtain these details and file on behalf of the NVO customer.

Carriers will need to obtain export manifest information much earlier than they currently do. Start to educate your customers on these new requirements and time frames.

Exemption statements that are currently incorporated directly into the carrier’s bill of lading will need to be coded for transmission, for example:

• “CEN” will be used to identify AES exemption number
• “ITN” will be used to identify the ITN number

Begin to collect information on what types of exemptions are currently being associated with your documents, either as printed directly on the B/L forms, provided via clauses, stamps or other means.

How will this affect me – an NVOCC – and what can I do to prepare?

While the NVOCC community today has no requirement to file house bills, nor give the carrier their proprietary shipper/consignee information, the coming requirement is expected to state that house bill details will have to be filed, including the actual shipper and consignee parties.

CBP will not mandate this data be filed by the NVO/FF, just that it must be filed.

As the trade experienced at the initiation of import AMS, the NVO/FF will have 2 options:

1. File HBL yourself electronically. Vilden eCLEAR can file EEM, learn more here.
2. Provide the actual HBL information to the carrier to file on your behalf. 

If you are not prepared before the Federal Register Notice mandating the submission of house bill data, you run the risk of pushing against a deadline to make the necessary changes and/or having to share your information with other NVO/FF (consolidation) or carriers.

We urge the trade, both carriers, NVOCC, Freight Forwarders or anyone preparing export documentation to become educated and consider participating in this important pilot program.

Vilden’s eCLEAR service is certified for EEM EDI transmissions.

One of the advantages of early participation via the pilot is the opportunity to work with CBP to refine your business process and modify your internal workflow to comply and be completely prepared ahead of the mandatory filing requirement.

If you are interested in more details on the requirements to register as a pilot participant, or any additional questions on these changes or filing with US Customs, you can reach us anytime, stay safe!