In Bond Shipment Rules: IT, T&E and IE Moves Under 19 CFR Part 18

An in bond shipment is imported cargo that moves under a CBP-approved bond from the port where it arrives to another U.S. port, or out of the country, before any duty is paid or the goods are appraised, and 19 CFR Part 18 gives the carrier 30 days to deliver it. The regulations write it as in-bond. Duty, other agency admissibility and the formal entry happen at the destination port, or never happen at all if the goods are exported.

The rules were rewritten by the final rule “Changes to the In-Bond Process” (82 FR 45366, September 28, 2017), effective November 27, 2017. CBP then stopped accepting the paper CBP Form 7512 for ACE input on July 2, 2018 and made electronic reporting of arrivals, exports and diversions mandatory on August 6, 2018. This guide covers the three movement types, who may file and what bond is needed, the clocks that run once the cargo moves, and what happens when a box arrives late, short or at the wrong port. It sits inside our broader guide to the customs clearance process.

The Three In-Bond Types: IT, T&E and IE

CBP recognizes three primary in-bond movements, identified in ACE by type codes 61, 62 and 63, and the type decides where the goods must end up. The choice is made when the in-bond application is filed and can only be changed through the update and diversion procedures in 19 CFR 18.1(h) and 18.5.

Immediate transportation (IT, type 61)

An IT moves foreign cargo from the port of arrival to another U.S. port of destination, where a consumption entry, a warehouse entry or a foreign-trade zone admission must follow. This is the standard move for ocean containers discharged at a coastal port and railed or trucked to an inland port, or for air cargo arriving at a gateway and flown on to the consignee’s airport.

Transportation and exportation (T&E, type 62)

A T&E moves foreign cargo through the United States to a different U.S. port, from which it is exported without ever entering U.S. commerce. Under 19 CFR 18.20 a T&E may be made for any merchandise, subject to the special-class restrictions in 18.1(l). CBP’s in-bond process document gives the example of vehicles landed at Brunswick, Georgia, moved on a type 62 to Miami and exported to Brazil.

Immediate exportation (IE, type 63)

An IE exports the cargo from the same port where it arrived, with no movement to another port. 19 CFR 18.25 uses it for merchandise in CBP custody with no completed entry and for goods on an unliquidated consumption entry that are being sent back out. Related variants cover vessel and aircraft supplies and withdrawals from a bonded warehouse for transportation or export.

Who May Move Cargo In-Bond and the Bond It Requires

Three kinds of parties may file the transportation entry under 19 CFR 18.1(c): the carrier that brings the goods to the origination port, the bonded carrier that will accept them for the move, and any person with a sufficient interest in the merchandise shown by the bill of lading, the manifest, a carrier certificate such as a power of attorney or letter of authorization, or another document. CBP may ask for evidence of that interest. In practice the bonded carrier or the importer’s customs broker files.

The movement itself must be performed by a bonded common carrier, contract carrier, freight forwarder or private carrier under 19 CFR 18.2. 19 CFR 18.1(e) requires a custodial bond on CBP Form 301 containing the conditions of 19 CFR 113.63, and that bond must be continuous. Road carriers also need a Standard Carrier Alpha Code (SCAC) from the National Motor Freight Traffic Association to be identified as the bonded carrier; for withdrawals from a foreign-trade zone or bonded warehouse, the facility’s FIRMS code can stand in for the SCAC. An importer’s own entry bond does not cover the move. How importer bonds are sized and chosen is covered in our guide to the customs bond.

The in-bond application, which is a transportation entry plus a manifest, must be filed electronically through a CBP-approved EDI system before the merchandise leaves the origination port, and the cargo may not move until CBP transmits movement authorization (disposition code 1J on AMS bills). Under 19 CFR 18.1(d)(1) the application must carry:

• The six-digit HTSUS number of the merchandise. CBP’s in-bond FAQ states that no implementation date had been set for enforcing this element on IT movements and that a ten-digit number will also be accepted.
• A description precise enough for any other agency that regulates the goods to identify them.
• The quantity in the smallest external packing unit. Containers and pallets are not acceptable units: a container holding 10 pallets of 200 cartons is reported as 200 cartons.
• Container and seal numbers, with the seal number added within two business days after the initial carrier takes possession if it was not known at filing.
• The U.S. port of destination for an IT, or the port of exportation and first foreign port for a T&E or IE.
• Optionally, any visa, permit, license or entry number issued for the goods.

In-Bond Time Limits and Arrival and Export Reporting

An in bond shipment must be delivered to CBP at the destination or export port within 30 days, and every event after that triggers a two-business-day or 15-day clock. The 30 days run from the conveyance’s arrival at the origination port if the application was approved before arrival, or from CBP’s movement authorization, whichever is later. Barge movements get 60 days. Transferring the cargo to another conveyance does not extend the limit (19 CFR 18.3(a)). ACE warns the carrier with disposition code 1K when a bill is five days from the end of its transit period and code 1L when the period has expired without arrival.

Arrival must be reported electronically within two business days after any portion of the shipment reaches the destination or export port, together with the FIRMS code of the location where the goods sit. Missing either is an irregular delivery under 19 CFR 18.1(j). Once the entire shipment has arrived, the goods have 15 calendar days to be entered, exported or admitted to a foreign-trade zone; on the 16th day they become subject to general order requirements under 19 CFR 4.37, 122.50 or 123.10, depending on the mode.

Diversions, Irregular Deliveries and Liquidated Damages

A diversion to a different destination or export port is legal only if the filer requests it electronically and CBP approves it before the cargo goes there, and any other deviation is a bond default. Under 19 CFR 18.5 the request goes through a CBP-approved EDI system and the permission comes back the same way; CBP’s FAQ notes that an authorized diversion posts disposition code 3W. If CBP denies the request, the goods must go to the original port. Merchandise needing another agency’s permission can be blocked from diversion on that agency’s behalf, and diverted cargo still has to meet USDA permit restrictions.

Shortages are reported with the arrival notice under 19 CFR 18.6. When goods are not delivered, are delivered to an unauthorized place or are released to the consignee without CBP permission, CBP may demand redelivery within 30 days after discovering the problem, and if the goods are not returned within 30 days of that demand, it issues a liquidated damages claim on CBP Form 5955-A.

The party whose bond is obligated on the transportation entry carries the liability under 19 CFR 18.8. The custodial bond conditions in 19 CFR 113.63(j) set liquidated damages at the value of the merchandise involved, or three times that value for restricted or prohibited merchandise or alcoholic beverages, and $1,000 per default that does not involve merchandise. On top of that, 18.8(c) makes the bonded party liable for the duties, taxes and fees on missing merchandise, and that amount is not capped at the bond amount. A petition for relief under 19 CFR Part 172 can reduce or cancel the claim if the violation occurred without intent to evade the law. The carrier holds the bond, but the commercial fallout usually lands on the cargo owner, so importers who arrange their own inland moves should know which carrier’s bond is on the line. Our customs audit support team handles liquidated damages petitions and the records behind them.

When an In-Bond Move Makes Sense

An in-bond move makes sense when the place where duty and admissibility are best handled is not the port of arrival. Typical cases are inland destinations with their own CBP port and a broker who knows that port, foreign cargo transiting the United States between foreign countries, goods landed at the wrong port that must be re-exported, and imports headed for a foreign-trade zone or bonded facility at another port. Moving duty and partner-agency review to the destination also moves any customs exam there, which can be an advantage when the destination port has shorter CES queues; see our guide to the customs exam for how those are run.

It makes less sense when the cargo needs another agency’s release that will not be granted for in-bond movement, when a 30-day transit window is unrealistic, or when no reliable bonded carrier serves the lane. Warehousing under bond is a different tool: if the goal is to store goods for months with duty deferred, see our guide to the customs bonded warehouse, and for manufacturing or long-term inventory consider a foreign-trade zone. Our licensed customs brokerage team, in business since 1989, can file in-bond applications and destination entries for importers who route cargo inland.

Frequently Asked Questions