INTERNATIONAL TRADE LAW
Export Documentation: The Exporter's Checklist
Every U.S. export shipment needs a core set of documents — a commercial invoice, a packing list, a transport document, and, for most shipments, an Electronic Export Information (EEI) filing in the Automated Export System. Get those right and the rest is detail. Get them wrong and you face holds, refused entry abroad, and penalties at home. This guide is the exporter’s checklist: what each document does, when the government filing kicks in, and what you must keep.
The Core Export Documents
These travel with — or alongside — almost every international shipment:
| Document | What it does |
|---|---|
| Commercial invoice | States the parties, the goods, the value, and the terms of sale; the basis for the buyer’s customs valuation |
| Packing list | Itemizes what is in each carton or container, with weights and dimensions |
| Bill of lading / air waybill | The carrier’s receipt and contract of carriage; the ocean bill can also be a document of title |
| Certificate of origin | Evidences where the goods were made; may unlock preferential duty for your buyer |
| Export license | Required only when the goods, destination, or parties are controlled |
The commercial invoice is the keystone — it must agree with the packing list, the transport document, and your export filing. Inconsistencies are the single most common cause of customs delay.
When You Must File an EEI
The EEI is the export data the U.S. government collects through the Automated Export System (AES), under the Foreign Trade Regulations (15 CFR Part 30), administered by the Census Bureau. You generally must file when:
- the value of the goods under a single Schedule B or HTS classification exceeds $2,500, or
- the shipment requires an export license, regardless of value.
After a successful filing, AES returns an Internal Transaction Number (ITN) that goes on your transport documents. You can authorize a freight forwarder to file the EEI for you, but as the U.S. Principal Party in Interest you remain responsible for its accuracy. Shipments to most destinations below the threshold and without a license requirement can move under an exemption — but you must cite the correct exemption, not simply skip the filing.
Incoterms Decide Who Does What
An Incoterm (e.g., EXW, FOB, CIF, DDP) is the three-letter rule in your sales contract that allocates cost, risk, and tasks between you and the buyer — including who arranges carriage, who insures, and at what point risk transfers. It does not change what documents are required; it changes who is responsible for producing them. State the agreed Incoterm and version on the commercial invoice so there is no dispute about, for example, who clears the goods for export or pays freight. Misaligned Incoterms quietly create gaps where a required document has no owner.
Records You Must Keep
Export documentation is also a recordkeeping obligation. Retain your invoices, filings, licenses, authorizations, and AES confirmations — the Foreign Trade Regulations and export-control rules generally require retention for five years from the date of export. Good records are what turn a routine government inquiry into a non-event.
A Practical Pre-Ship Checklist
- Product classified and Schedule B/HTS number confirmed
- Parties and destination screened against restricted-party lists
- Any license requirement resolved before booking
- Commercial invoice, packing list, and transport document agree
- EEI filed (or a valid exemption cited) and the ITN on the documents
- Incoterm stated; insurance arranged by whoever owns that risk
- Copies retained for five years
Frequently Asked Questions
What documents are required to export from the U.S.?
At minimum: a commercial invoice, a packing list, and a transport document (bill of lading or air waybill). Most shipments also require an Electronic Export Information filing, and some require a certificate of origin or an export license.
When is an EEI filing required?
When the value of goods under a single Schedule B or HTS classification exceeds $2,500, or whenever the shipment needs an export license regardless of value. The filing is made in the Automated Export System under 15 CFR Part 30.
What is an ITN?
The Internal Transaction Number — the confirmation the Automated Export System returns after a successful EEI filing. It must appear on your export transport documents as proof the filing was made.
How long must I keep export records?
Generally five years from the date of export, under the Foreign Trade Regulations and U.S. export-control rules. Keep invoices, filings, licenses, and AES confirmations.
Clean, consistent documents are the difference between a shipment that clears and one that sits. Reidel Law Firm helps U.S. exporters build document and filing controls that hold up to scrutiny, on flat-fee terms. Get an export compliance memo.
