The U.S. Census Bureau published the Final Rule entitled, “Foreign Trade Regulations (FTR): Clarification on Filing Requirements,” April 19.

This rule addresses new export reporting requirements related to the International Trade Data System and includes the addition of a new data element, the original Internal Transaction Number (ITN) that can be reported in the Automated Export System (AES). The original ITN field is an optional data element that can be used when a previously filed shipment is replaced, divided or cancelled.

The Census Bureau decided to add the original ITN data element to address situations when a party involved in an export transaction received penalties for shipments that were originally filed on time, but whose shipments were divided while in transit to the ultimate consignee. This data element makes it possible for U.S. Customs and Border Protection (CBP) to identify AES filings that are associated with previously filed shipments. Prior to the original ITN field, CBP was unable to determine if a shipment, identified as late, was associated with a shipment originally filed in accordance with the FTR. The inclusion of the original ITN field will enable parties in an export transaction to proactively provide CBP with additional information and will allow CBP to conduct a more thorough review of these types of shipments prior to assessing any penalties.

Let’s take a look at an example of how the original ITN field can be used. A foreign buyer in Italy purchases $20,000 worth of jewelry from a U.S. seller. The U.S. seller ships the jewelry to the buyer, but while in transit the seller is contacted by the buyer who now only wants $8,000 worth of jewelry. The seller then finds a new buyer in Sweden for the remaining $12,000 worth of jewelry. The originally filed AES record needs to be updated to reflect the value of $8,000 for the buyer in Italy. Additionally, a new AES record is created for the new buyer in Sweden. This new filing would generate a late filing compliance alert.  However, to ensure CBP is aware that the new shipment was filed prior to exportation in accordance with the FTR, the filer can include the previously filed ITN in the original ITN field.

For more information, contact the International Trade Management Division Call Center at 1-800-549-0595. Select option 3 for the Trade Regulations Branch.

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