NOEEI exemption codes: the complete list for small US exporters

Some of the most common searches that land on this site are exemption codes typed in raw: "noeei 30.36", "noeei 30.37a", "eei exemption codes". That search has a story behind it. Somebody saw a legend on another company's invoice, or a forwarder asked "which exemption applies?", or a shipment got held with a note about a missing citation, and now they need the list.

Here is the list. Every AES exemption a small exporter will realistically use, what each one covers, the conditions that quietly cancel them, and exactly where the legend goes on your paperwork. The decision logic (file or not) lives in our EEI decision guide; this post is the reference card you keep open next to it.

First, what a NOEEI legend actually is

When a shipment leaves the US, one of two marks must appear on its commercial loading documents:

• An ITN (Internal Transaction Number), the proof that Electronic Export Information was filed in the Automated Export System, or
• A NOEEI legend, the citation that explains why no filing was required.

NOEEI is literally "No Electronic Export Information," followed by the section of the Foreign Trade Regulations (15 CFR Part 30) that grants the exemption. Written out, it looks exactly like this on an invoice:

NOEEI 30.37(a)

The Census Bureau's guidance on filing citations and exemption legends requires the citation to be clearly visible on the commercial loading documents. A blank where the legend should be is the failure mode: the shipment is not "exempt," it is "undeclared," and undeclared is what gets pulled at the port. CBP publishes the accepted legend formats in its ACE exemption legends appendix.

One rule outranks every code below: if the goods require an export license, are ITAR-controlled, are rough diamonds, or are headed to an embargoed destination, no exemption applies. You file, full stop. The exemptions only exist for shipments with no licensing question attached.

The two workhorses

For a small commercial exporter, two codes cover the overwhelming majority of exempt shipments.

NOEEI 30.37(a): the low-value exemption

No EEI filing is required when the goods under a single Schedule B or HTS number, shipped from one USPPI to one consignee on a single conveyance, are valued at $2,500 or less.

The mechanics that matter:

• The test is per classification code, not per shipment. One shipment can carry a $4,000 line (file it) and a $900 line (exempt, legend it). You evaluate line by line. If you are not sure which code a product falls under, that is upstream of this decision; start with what is an HS code.
• Domestic and foreign-origin goods under the same code count separately. If either side exceeds $2,500, that side gets filed.
• It vanishes for used self-propelled vehicles, which have their own mandatory filing regardless of value, and for anything licensed, ITAR-controlled, or embargo-bound as above.

NOEEI 30.36: the Canada exemption

No EEI filing is required when Canada is the country of ultimate destination, regardless of value. A $40,000 machine to Toronto ships with a legend, not a filing.

The word doing the work is ultimate. The exemption fails when:

• The goods require an export license or are ITAR-controlled.
• The goods are rough diamonds.
• Canada is a transit stop and the real destination is a third country. Routing through Vancouver to reach Asia is not a Canada shipment; the destination country decides the filing, and Canada in the middle changes nothing.

If your Canadian buyer is genuinely the final user, write NOEEI 30.36 and ship. If the goods keep moving, treat the shipment as what it is: an export to the ultimate destination.

The rest of 15 CFR 30.37: the situational exemptions

Section 30.37 runs from (a) to (y). Most letters cover situations a small commercial exporter meets rarely, but when you meet one, the right legend saves a pointless filing. The ones worth knowing, from the regulation text:

Two neighboring sections complete the map: 30.39 exempts qualifying shipments to the US Armed Services and 30.40 exempts certain shipments to US government agencies and employees. If you sell to the government, those are the legends your contracting officer expects.

We deliberately left out the letters covering diplomatic pouches, human remains, carrier stores, dunnage, and pet baggage. If your business regularly ships any of those, you are not the small commercial exporter this site is written for, and you already have a broker on retainer.

Which code do I write? A 20-second recap

The full decision tree is in the EEI decision guide, but compressed to its spine:

1. License, ITAR, embargo, rough diamonds? File EEI. No legend exists for you.
2. Ultimate destination Canada? NOEEI 30.36.
3. Line value $2,500 or less per Schedule B number? NOEEI 30.37(a) for that line.
4. A special situation from the table above? Use its letter.
5. None of these? File in AESDirect (it is free inside the ACE portal; forwarders charge $25 to $50 to do the same typing) and put the ITN where the legend would have gone.

Where the legend goes

Same two places every time, and this is the part the government PDFs assume you already know:

• On the commercial invoice, as a clearly labeled line. The invoice travels with the goods and is the first thing an officer reads. Proforma invoices never carry it; the difference is covered in commercial invoice vs proforma invoice.
• In the EEI block of the shipper's letter of instruction, in place of the ITN. The SLI has exactly one slot for this: ITN if filed, NOEEI legend if exempt, never empty.

Write it exactly as the regulation section reads: NOEEI 30.36, NOEEI 30.37(a). No paraphrasing, no "exempt - low value," no bare "NOEEI" with nothing after it. The citation is the content.

The pattern behind every held shipment

Notice what all of this is: one field, sourced from one decision, that must appear consistently on two documents and match the values on both. That is the entire game, and it is exactly the kind of consistency that breaks when an invoice is typed in Word, the packing list in Excel, and the SLI on the forwarder's web form.

ExportDocsHub closes that gap structurally. You enter the shipment once (value, consignee, Schedule B, Incoterm), the system knows whether the line clears the $2,500 test and whether the destination is Canada, and the same legend or ITN lands on the invoice and the SLI from a field that cannot be silently left blank. If you would rather make the exemption call once instead of three times per shipment, start a free trial. No credit card required.

Ship with the legend on the paper, and the question "why is there no filing for this?" never gets asked, because the answer is already written where the officer is looking.

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Further reading

• Do I need to file EEI in AES? A decision guide for small US exporters
• How to fill out a shipper's letter of instruction (SLI), step by step
• Export documents checklist: what every small exporter needs
• What is an HS code? How to find yours