By: Nidaal Jubran
How important is it to retain documentation filing in the Automated Export System (AES)? We receive many inquiries from users who are experiencing issues which stem from poor record retention on a daily basis. I make an effort to convey the importance of retaining accurate records of each transaction to the trade whenever I can.
What is record retention?
As it pertains to the Foreign Trade Regulations (FTR), record retention is the necessary act of keeping all documentation pertaining to an export transaction for a period of at least five years for an Electronic Export Information (EEI) filing, or a time frame designated by the controlling agency for licensed shipments, whichever is longer. This can be as simple as keeping hard copies of all invoices and any documents which were used to process your AES transactions. Don’t throw them away!
I’m a bit of a pack rat myself, so this issue hits home with me. There are a few reasons for maintaining accurate records. First, it is a requirement under the FTR, Section 30.10 (a). All parties to the transaction must retain documents pertaining to the export shipment for five years from the date of export. Any party listed in an AES record, whether it is the USPPI, Freight Forwarder, Authorized Agent, etc., has legal responsibility to retain documentation with that particular shipment. The involved parties should have an understanding of the information they have provided as a party to the transaction.
Second, it is important to keep accurate records in order to make necessary updates to your EEI prior to or after the shipment has been exported, should the need arise. As the filer, it is your responsibility to make sure we have accurate records of each transaction transmitted through the AES. You may correct the data at any point, regardless of the length of time between the original filing and the date in which you correct the data. If it comes to your knowledge that a particular piece of information was entered incorrectly for a shipment filed a week ago, a month ago, a year ago or longer, you will still need to retrieve the data and make the necessary changes. For shipments filed a year ago or longer, it may be difficult to ‘remember’ the information, so we encourage the practice of good record retention to make this easier to accomplish.
Lastly, record retention can help in preventing shipment duplication. The Shipment Reference Number (SRN) is the identification number assigned to each shipment by the filer. The SRN may be up to 17 characters, and may contain alpha, numeric, and special characters. As you know from my previous posts, the SRN must be unique for every shipment! No two shipments from an AES filer may share the same SRN!
In AESDirect, if an SRN has been used previously, and is mistakenly listed again in a new transaction, a few things will happen. Instead of creating a new AES record for this shipment, the system will simply erase the information in the original transaction and replace it with this new information. AESDirect will assume you are ‘amending’ the existing data instead of creating a new record. Because of this, a new Internal Transaction Number (ITN) will not be generated, the original data will be lost, and our export statistics will be deflated to some degree.
So what does this mean for you? If an ITN is not provided to Customs and Border Protection (CBP) prior to the date of export (for pre-departure filers), you will be unable to move your cargo at that time. You may also run into some difficulties, or may be subject to penalties.
This sounds like a serious issue, and it is. However, good record retention will allow you to address and resolve these errors effectively. By maintaining the original documentation, you can restore the shipment back to its original state prior to the replacement, and then transmit the new shipment with a unique SRN.
It is in the best interests of all parties involved to maintain some documentation of each transaction filed through the AES. You don’t need to be a pack rat like myself, but some responsible record keeping can go a long way!