Who Files the AES on Your FOB Miami Phone Order?
Most resellers buying FOB Miami have never thought about the Automated Export System, and most of the time they don't need to. Then one order sits at the port because nobody filed, and suddenly it's the only thing anyone wants to talk about.
Here is how the filing actually works, who is responsible for what, and which question to ask when a container is not moving.
The $2,500 threshold is per Schedule B number, not per invoice
Electronic Export Information, or EEI, is filed in AES when the value of the commodity classified under an individual Schedule B number is over $2,500, or when a mandatory filing requirement applies. That per-commodity detail is what catches people. A mixed shipment can have three commodity lines and trigger the filing on one of them, or on all three, regardless of the total invoice.
Phones cross that line fast. A single pallet of 30 handsets is almost always well past $2,500 under one Schedule B code, so plan on the filing being required rather than hoping it isn't.
On a FOB Miami sale, the filer has to be a US party
The filer is the US Principal Party in Interest, defined as the person in the United States who receives the primary benefit from the export transaction, or a US authorized agent acting for one of the parties. As the overseas buyer you are the Foreign Principal Party in Interest. You cannot file the EEI yourself from Kingston, Georgetown or Santo Domingo.
That isn't a limitation so much as an assignment of duty. What matters is that somebody on the US side is named for the job before the booking, not after the cargo arrives at the terminal.
Standard transaction versus routed transaction
There are two structures. In a standard export transaction the USPPI controls the movement of the goods and files the EEI itself, or authorizes an agent with a power of attorney. In a routed export transaction you, as the FPPI, control the movement and authorize a US agent, usually your freight forwarder, to file on your behalf.
Most FOB Miami phone orders are routed. You choose the forwarder, the forwarder files, and the US seller supplies a defined list of data elements: name and address of origin, USPPI identification number, state of origin, commodity classification number, description, unit of measure, quantity and value. A power of attorney or written authorization from you to that agent is required, and a POA that only authorizes moving cargo does not authorize filing unless it says so.
The deadlines are tighter than people expect
For shipments that are not on the US Munitions List, the filing timeframes are 24 hours prior to loading for vessel, 2 hours prior to scheduled departure for air, 1 hour before a truck reaches the US border, and 2 hours before a train reaches it. Miss those and you are looking at a compliance alert on the filing, or cargo that simply does not load that day.
The ITN is the number the carrier actually needs
When AES accepts a filing it returns an Internal Transaction Number, a string that looks like X20261231000022. The USPPI or agent passes that ITN to the carrier, and the carrier is not permitted to load or move the cargo unless the loading document carries a proof-of-filing citation, a postdeparture citation, a downtime citation, or an exemption legend.
So when you ask whether your container is moving, the concrete version of that question is: does the carrier have the ITN? If nobody can produce it, the cargo is not loading, and no amount of calling the terminal changes that.
Keep the file for five years
Every party to the transaction, including the USPPI, the FPPI, authorized agents and carriers, has to retain shipment records for five years from the date of export. Keep the commercial invoice, packing list, power of attorney and ITN together per shipment, in whatever format you like. It costs nothing while things go well and saves you when a question comes back a year later.
What we handle on our side
A1A Solutions ships FOB Miami out of Doral, Florida, with a 30-unit minimum and wire transfer payment. We provide the commercial invoice and packing list with the model, quantity and value detail your forwarder needs for the filing. See our wholesale cell phones page, the wholesale iPhones page, or our FAQ for how orders and payment work.
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