Commerce Clarifies Export Filings for In-Transit Goods
Published Date: 8/14/2025
Rule
Summary
If you ship goods through the U.S. on their way to another country, this new rule clears up who’s responsible for filing export paperwork. It affects exporters, customs brokers, and warehouse operators by setting clear rules on who files what and when. These changes start right away and help avoid fines by making export rules easier to follow.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 2 costs, 1 mixed.
Who Must File EEI for In‑Transit Shipments
If goods pass through the U.S. from one foreign country to another and are entered into the U.S. for consumption, warehousing, a Foreign Trade Zone (FTZ), or a bonded warehouse before export, the rule clarifies which party is the U.S. Principal Party in Interest (USPPI) and therefore who must file the Electronic Export Information (EEI). These clarifications take effect immediately.
Warehouses and FTZ Operators Liable for EEI
If a warehouse, storage facility, Foreign Trade Zone operator, or bonded warehouse operator is the USPPI, the rule makes that operator responsible for filing the Electronic Export Information (EEI) based on the information they have or receive from other parties to the export transaction. This change is effective immediately.
Clearer Penalties and Self‑Disclosure Rules
The rule revises definitions, mandatory filing requirements, confidentiality protocols, penalty provisions, and voluntary self‑disclosure processes to improve clarity, accuracy, and consistency across the Foreign Trade Regulations. These revisions are effective immediately and affect how penalties and self‑disclosures are handled.
Customs Brokers Must Get Client Consent
When a customs broker serves as the USPPI, the rule states the broker must obtain the client’s consent to provide customs entry information for filing the Electronic Export Information (EEI), consistent with customs regulations. This requirement is effective immediately.
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Key Dates
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