CBP Orders Rail Exporters to Digitize Cargo Manifests by 2027
Published Date: 8/26/2026
Rule
Summary
Starting October 26, 2026, all rail cargo leaving the U.S. must have its export info sent electronically through the Automated Commercial Environment (ACE). This new rule helps Customs keep cargo safe and makes trade smoother for rail exporters. Rail companies and exporters should get ready because enforcement begins a year later, on October 26, 2027.
Analyzed Economic Effects
6 provisions identified: 1 benefits, 4 costs, 1 mixed.
Mandatory electronic rail export filing
If you export cargo by rail, CBP now requires an electronic export manifest (EEM) submitted in ACE. An initial filing must be sent as early as practicable but no later than 24 hours prior to the train's departure from the U.S. port of export, and the remaining data must be transmitted at least 2 hours prior to that departure. The rule takes effect October 26, 2026, and CBP will begin enforcing it on October 26, 2027.
Bond requirement and penalty authority
Anyone transmitting EEM data must have an appropriate CBP bond on file that includes the condition to transmit advance export information; CBP will obligate the transmitter's bond in this order: an active international carrier bond, then an active basic custodial bond, then an active basic importation and entry bond. CBP amended bond regulations to permit assessment of liquidated damages for failures to provide required EEM data. Parties have the period between the rule effect date and enforcement date to obtain or replace bonds.
Holds and Do-Not-Load (DNL) blocks departures
CBP may issue Hold or Do-Not-Load (DNL) instructions after risk assessment; cargo subject to Hold or DNL cannot depart until the required information is transmitted or a physical inspection or other specified action occurs. DNL and Hold instructions are issued to the outbound rail carrier and any transmitter, and all recipients must contact CBP at the port of export.
Estimated industry costs and net savings
CBP estimates present-value total costs to CBP and trade members of about $10.3 million using a 3% discount rate (and about $7.0 million using a 7% rate) over its analysis period, with annualized costs of about $859,845 (3%) to $764,026 (7%). Present-value total cost savings are estimated at ~$47.7 million (3%) to ~$29.6 million (7%), yielding present-value net cost savings of ~$37.5 million (3%) to ~$22.7 million (7%); annualized net savings are about $3.1 million (3%) to $2.5 million (7%). Using a perpetual horizon at 7%, CBP reports present-value net savings of $128.6 million and annualized net savings of $9.01 million.
Who must send what information
The outbound rail carrier must transmit transportation and empty-container data; other eligible parties (e.g., USPPI, FPPI, authorized agents, customs brokers, ABI filers, NVOCCs, freight forwarders, or any party with direct knowledge) may transmit initial filing or cargo data. If no eligible party transmits advance export information, the party that arranges for or delivers the cargo to the outbound carrier must fully disclose the required initial data elements to the carrier.
Seven initial data elements required
CBP requires seven mandatory data elements in the initial filing submitted no later than 24 hours before departure: Bill of Lading Number, Total Quantity, Total Weight, Cargo Description, Shipper name and address, Consignee name and address, and Employer Identification Number (EIN) or Importer Record Number (IRN) or CBP-assigned number. An AES Internal Transaction Number (ITN) or FTR exemption/exclusion code is a conditional element that must be provided as soon as it is available.
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Key Dates
Department and Agencies
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