Shipping items to China, Russia, or Venezuela? Please take note

In the past, if you have shipped one or more items of the same kind—having total value of $2,500 or more—outside the United States, then your carrier (such as FedEx or DHL) or freight forwarder will have likely asked if you wanted them to assist with the filing of Electronic Export Information, or EEI, which is entered into the Automated Export System, or AES, in order for your shipment to comply with U.S. foreign trade regulations. As of June 29, 2020, the United States Bureau of Industry and Security, or BIS, requires that EEI also be filed when a broad range of items is shipped to China, Russia, or Venezuela, regardless of their value. The kind of items that trigger this filing requirement are those that are described on the [Commerce Control List] (, or CCL, which contains the following:

  • tangible goods, source code, and technology that are "dual-use," which means that they can be used for benevolent, civilian purposes but also for military purposes; and.
  • certain defense-related or military items that are less critical to national security than those subject to controls by other agencies

Looking ahead, you can expect carriers and freight forwarders to ask you whether your shipments to China, Russia, or Venezuela will contain items that are listed on the [CCL] (, where they are listed on the CCL, and whether any type of EEI filing exemption applies to them. Please find here a description of filing exemptions that FedEx is currently sharing with its customers.

If you are unable to provide your carrier or freight forwarder with the information that they need to help you comply with the new EEI filing requirement, contact JHU's Export Control & Facility Security office, or ECO, at Note that, in some instances, ECO may not be able to provide the information that you need without investigation, which might require asking third parties for input (such as the manufacturer of your items to be shipped). Thus, when shipping to the three countries in question, it is important to factor into your shipping timeline at least five business days, which might be needed for ECO to collect the necessary information.