ACE Electronic Export Manifest Information and Requirements

Background

The Trade Act of 2002, Sec. 343 mandated U.S. Customs and Border Protection (CBP) collect pre-departure data for all exports. The Commercial Customs Operations Advisory Committee (COAC) Export Modernization Working Group (EMWG) worked together with CBP and the U.S. Census Bureau (Census) to develop this concept and the result was a streamlined export process vision that includes requirements, streamlined data elements, and a modernized process design.

The Electronic Export Manifest (EEM) pilot is currently operating in select ports with limited participation. To accurately evaluate EEM’s effectiveness, additional pilot participants are needed before the use of EEM becomes mandatory. Eventually, Export Manifest will be required to be submitted electronically to the Automated Commercial Environment for air, ocean, and rail modes of transportation. The EEM Truck Pilot is expected to be announced when ready via a Notice of Proposed Rulemaking.

Today, export manifest information is submitted to CBP via document images, email, and paper processes, resulting in inefficiencies for both the party submitting the data and CBP. The EEM allows pre-departure manifest data to be collected on all export transactions electronically and includes master and house level manifest data from the carriers and parties that control that information. As the EEM pilot unfolds and regulations are implemented, the modernized vision for exports is planned with the following additional features:

• Streamlined data elements: A major part of the EMWG’s work included a careful analysis of the overlapping elements between the EEM and the Electronic Export Information (EEI), which is submitted to ACE by the U.S. Principal Party in Interest (USPPI) or an authorized agent. While the EEI will remain a separate and distinct filing to collect data for Census and all other Participating Government Agencies (PGA), EEM will provide a basis for the long-term goal to eliminate redundancies between these two filings. In the future, this will be accomplished by aligning the EEI with the EEM, extracting the most accurate data from each submission based on the ownership of the information. For example, the manifest could be the source for the actual date of exportation and port of departure (see Export Modernization Working Group White Paper (cbp.gov), page 123 for more information).
• Standardized manifest data elements: A major part of CBP’s work with global Customs administrations is to align manifest data elements for each mode, enabling other countries to consider use of CBP’s EEM data as part of their incoming manifest requirements. This could benefit other countries Customs administrations and the trade community by reducing the submission of extra manifest information. Ultimately, the full implementation of EEM as a required filing will support CBP’s efforts to further streamline data collection for global traders.

What are the Potential Benefits?

It is important to note that there are both immediate benefits and potential future benefits of EEM and export modernization that may be realized through participation in the pilot. These benefits include:

• Cargo processing efficiency: Receiving the relevant shipment data earlier in the process will allow CBP and other PGAs to potentially target and inspect cargo further upstream in the supply chain. The pilot indicated that because the actual carriers will report the transportation data, that data is much more accurate. When CBP targets earlier with more accurate data, the trade community benefits with streamlined export operations.
• Streamlined reporting and protection of proprietary shipment data: The export manifest requires house bill of lading data. Non-Vessel Operating Common Carriers (NVOCC) and Indirect Air Carriers (IAC) will either have the option of transmitting house bill of lading/air waybill manifest data electronically utilizing EEM or providing the information to the carrier for them to transmit. Participating in EEM will streamline the reporting function for NVOCCs and IACs and will protect the shipment data.
• Adapting the design: Participating in the pilot now will allow companies to realize the extra benefit of having their business intricacies considered and adaptations made more readily during the pilot phase. Once rulemaking is complete, the resources may be limited to further enhance the program.
• Elimination of redundant data elements / increased accuracy: CBP and Census will continue work to improve the efficiency of data sharing to eliminate redundancies in submission, making the process more streamlined and reducing the possibility of inadvertent data entry errors.
• Better data access / proof of export: The future ability for EEM to be used to support proof of export for shipments will streamline procedures for drawback, in-bond movements, and temporary imports because EEM is reliable and electronically accessible via ACE.
• Beneficial resolutions: The use of more reliable and advanced data may result in faster cargo issue resolution and fewer violations that can lead to penalties.
• Potential cost savings: With implementation of new processes, export modernization will create efficiency of export operations for the trade community and CBP. With near real-time data available in EEM, advanced screening will result in more rapid notification of inspection and reduce costly repacking. In addition, with the increased reliability of EEM data, there may be opportunities to remove transportation data elements from the EEI in the future, resulting in reduced labor to amend filings and the reduced need for penalties. Finally, since EEM data will be automated, evidence for duty reduction programs is electronic, reducing the time associated with paper proof. In summary, process owners will find considerable cost savings in the efficiency of the EEM process.

Join the Pilot!

CBP has been conducting an EEM pilot for several years with carriers in various transportation modes. The pilot has successfully enabled carrier participants to program the EEM data elements, validate transmission paths to ACE, and manage the hold/inspection process more efficiently. Below is a list of some of the key reasons to consider pilot participation:

• Pilot participants can eliminate manual/paper submission of manifest information.
• Pilot participants can influence the design of the future export systems and proposed regulations by working with CBP to adapt the requirements to your business model.
• The EEM pilot is being extended into additional modes of transport and more ports to create a robust environment for testing the needs of various supply chain entities.
• The requirements for participation in the pilot are aligned closely with those of the future NPRM, so pilot participants will be prepared for the new rule and will experience minimal business disruption when the EEM goes into effect.

NOW is the time for carriers, consolidators, IACs and NVOCCs to begin their engagement with the EEM pilot!

Where Do I Get More Information?

• For the Air Cargo Test: ACE Export Manifest for Air Cargo Test: Extension of Test
• For the Rail Cargo Test: ACE Export Manifest for Rail Cargo Test: Renewal of Test
• For the Vessel Cargo Test: ACE Export Manifest for Vessel Cargo Test: Renewal of Test
• For all questions, reach out to the following points of contact at CBP:
  • Your assigned CBP Client Representative;
  • David Garcia, Program Manager, Outbound Enforcement and Policy Branch, Office of Field Operations; via email at cbpexportmanifest@cbp.dhs.gov; or by phone at (202) 325-4221.

Beginning in March of 2012, CBP allowed CBP Form 1302A Cargo Declaration - Outward with Commercial Forms to be filed using the Document Image System (DIS). The use of DIS was offered as an interim step to the development of a fully electronic export ocean manifest. In 2022, CBP published an extension to the pilot in the Federal Register titled “Automated Commercial Environment (ACE) Export Manifest for Vessel Test: Renewal of Test” (Document Number 2022-08955). Since October 2015, this pilot allowed carriers to submit the export manifest data elements thru the Electronic Data Interface (EDI) to the Automated Cargo Environment (ACE).

In preparation for the upcoming publication of the Notice of Proposed Rule Making (NPRM) that will announce the proposed regulatory changes for outbound vessel manifest submission, effective October 1, 2024, CBP will disable in DIS the option to submit the CBP Form 1302A Cargo Declaration - Outward with Commercial Forms for outward vessels. Carriers currently utilizing DIS to file this form should begin to transition to either paper submissions or start participation in the ACE Export Manifest Test. As outlined in 19 CFR 4.63, carriers are required to submit the CBP Form 1302A Cargo Declaration - Outward with Commercial Forms to the port of departure. A carrier that is participating in the test and submitting 100% electronic manifest by EDI to ACE will no longer have to submit CBP Form 1302A Cargo Declaration - Outward with Commercial Forms to the port of departure. Participating carriers submitting 100% outbound electronic manifest will be identified in Appendix P of the Electronic Export Manifest Implementation Guides. Carriers submitting 100% outbound electronic manifest can continue to submit Pro forma manifest as outline in 19 CFR 4.75, if authorized by the area port director.

Questions may be directed to the Outbound Enforcement and Policy Branch, at cbpvesselexportmanifest@cbp.dhs.gov.

The Truck export manifest is still being discussed as to how it will be implemented so details will be announced as soon as a decision has been reached.

MMM Transaction Set (XML)

• Summary of Changes
• Appendix A - Mode of Transportation
• Appendix B - Party Type
• Appendix C - ISO Country Codes
• Appendix D - Amendment Codes
• Appendix E - Units of Measure
• Appendix F - Equipment Type Codes
• Appendix G - Transportation Service Codes
• Appendix H - Hazardous Materials
• Appendix I - Reference and Exemption Codes
• Appendix J - Response Codes
• Appendix K - Action Codes
• Appendix L - Schedule D Codes
• Appendix M - Container Equipment Type Codes
• Appendix N - ISO Country
• Appendix O - Schedule K
• Appendix P - Pilot Participants Carriers Submitting Electronically