Quest News™

April 29, 2014

Delayed Enforcement for ATA Carnet Shipments

The United States Council for International Business (USCIB) confirmed that beginning April 5th, 2014, the Census Bureau and CBP have declared an "Informed Compliance Period" during which no penalties will be issued for ATA Carnet Shipments who fail to comply with the March 14, 2013 Electronic Export Information (EEI) filing requirement.

The FTR Letter No. 8 Notice of 180 Day Informed Compliance Period for Regulatory Changes, states that "during this 180 day period the Census Bureau and CBP will use "informed compliance" to educate the trade on the new requirements". Furthermore, “the period of informed compliance will take place from the revised FTR effective date of April 5, 2014 through October 2, 2014”. This does not change the EEI filing obligation for ATA Carnet shipments that require an export license.

The final rule under the U.S. Foreign Trade Regulations altered previous standards where most goods traveling under a carnet were exempt from filling the EEI requirement.

Under the EEI requirement, Carnet shipments are not exempt, although there are still some exemptions that certain ATA Carnet shipments can still be eligible for:

  • “Low Value Exemption”: goods valued at or below $2500 are exempt. With multiple Schedule B/HTSUS numbers, as long as no single item on the General List is valued at more than $2,500, there is no need to file EEI.
  • “Hand Carried Tools of the Trade”: Goods that are defined as “tools of the trade” traveling under a U.S. Carnet are exempt unless they are subject to licensing or other export controls.
  • “Canada”: Shipments that travel under a U.S. Carnet where the final destination is Canada are exempt.

EEI Requirement Background:

Electronic Export Information (EEI), formerly collected as Shipper’s Export Declaration (SED), supports the Census Bureau by collecting and compiling export trade statistics under the provisions of Title 13, United States Code (U.S.C.), Chapter 9, Section 301. This is collected via the Automated Export System (AES), which is the primary system of tracking. The data collected via AES is also utilized by the Bureau of Industry and Security and other federal agencies to monitor and help prevent unauthorized exports of certain items.

As a distributor of Carnets, Avalon continues to be proactive in providing updated information regarding Carnets and exemptions associated with the EEI requirements. To learn more about Carnets, please view Avalon's Carnet Brochure or USCIB's website at Avalon provides a full range of Carnet services as well as bonds and they can easily be obtained by writing to

About Avalon

Avalon Risk Management provides insurance and surety solutions to the transportation and logistics industries. Local service is provided through ten offices in major U.S. port cities and Toronto, Canada. Products include: Bonds, Marine Cargo Insurance, Professional Liability, Property & Casualty, Executive Risk coverage and specialty auto programs including Truck, Courier and Paratransit insurance. Avalon is Ahead of the Curve when responding to the needs of our clients in an ever evolving industry.

For more information, visit our ISF archives page where we provide the most current information on ISF and copies of all prior presentation, webinar recordings, and links to CBP’s ISF web page.  Or please contact our ISF Hotline at (847) 700-TISF or email

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