Regulatory intelligence for US exporters

TAC May Ask BIS to Allow Quarterly AES Filings for Certain Exports

A technical advisory committee may ask the Bureau of Industry and Security to allow quarterly filings in the Automated Export System for certain exports to China, Russia and Venezuela. The change could make certain AES filings more efficient, members of the Transportation and Related Equipment Technical Advisory committee said during a Sept. 21 meeting.

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The required filings stem from a 2020 BIS rule that expanded Electronic Export Information filing requirements in AES for exports to the three countries regardless of the value of those shipments (see 2004270027). Since the rule took effect, exporters have been required to file EEI for certain commercial shipments to China, Russia and Venezuela, even those worth less than $2,500, the previous value threshold.

But some TransTAC members said giving filers the option to submit quarterly filings for those shipments could reduce administrative burdens on industry. “It's triggering a manual action for every one of those under-$2,500 items that we didn't have to do before,” said Rob Lawson, international trade compliance manager at General Electric Aviation. “It's just labor. And as much as that's labor, doing a quarterly report would be just dumping a data file.”

Ari Novis, TransTAC chair and chief global trade officer at Pratt & Whitney, said “you'd be essentially replacing one manual process with a different one, but it may be more efficient.” Lawson added that it would be “a lot easier to send an extract from the system once a quarter than it would be to type them in every day.”

Along with easing the burden on filers, the change may also benefit BIS, Lawson said. “It might actually be more convenient for BIS to receive it as a summary report, where they could get the metrics right from one place,” he said. A BIS spokesperson didn't comment.