SCI has received additional information about the newly implemented requirements for traveling with firearms out of the United States, including for international hunting and recreational shooting purposes. All individuals who plan to travel outside the U.S. with their firearms should carefully review the attached “Fact Sheet: International Travel with Firearms on Commercial Airlines Departing the United States” well in advance of their travel. The Fact Sheet was provided by Customs and Border Protection (CBP).
SCI, together with representatives of several other hunting and shooting organizations, met with personnel from the key agencies involved in adopting, implementing and enforcing these new export procedures. At the meeting, we solicited information about current implementation and future plans concerning firearms and ammunition export reporting requirements. Our findings are below:
Please note that the information below is not intended to serve as legal advice. For additional information, SCI members should consult these sources:
Registering with the Automated Export System (AES): The government is requiring hunters and shooters to use the AES for registering their firearms and ammunition that will be temporarily exported from the U.S. At this time, CBP personnel are not consistently implementing and enforcing these new procedures. In some locations, CBP is already enforcing the new procedures. In others, it is not. Some CBP officers remain unfamiliar with the new procedures. Despite these inconsistencies, the government expects all hunters and shooters who wish to travel with firearms and ammunition to register for and use the new AES system. The government flatly refused SCI’s request that implementation of the new procedures be delayed or suspended until CBP can achieve consistent application.
Dealing with the AES complexity: The government admits that AES registration is not user friendly. They are trying to simplify the registration process and hope these new streamlined procedures will be in place by the end of this year. In the meantime, a hotline has been set up to assist those who need to register. If you need assistance in completing an AES filing, you should call 1-800-549-0595 and press Option 1. Although the line is not open 24 hours a day, you can (and should) leave a message for a return call if you do not reach someone immediately. SCI was told that the people staffing this phone line will be well-prepared to answer questions posed by hunters seeking to travel with their firearms. Alternatively, you can submit questions about AES filing by e-mail to email@example.com.
Obtaining an Employer Identification Number (EIN): To complete an AES filing, you will need an EIN. Representatives of CBP and the Census Department informed us that they have consulted with the Internal Revenue Service (IRS) about the propriety of obtaining EINs not for business or commercial purposes, but solely for the purpose of making an AES filing to export firearms for personal reasons. SCI was also told that the IRS will be modifying their application process so that applicants can designate AES filing as their purpose for seeking an EIN.
The Importance of Advance Planning: An individual can complete his or her AES filing as early as 120 days in advance of his or her trip. By completing the AES registration, the hunter/shooter obtains the Internal Transaction Number (ITN) that he or she will need to present, along with his or her firearms and ammunition, for inspection to a CBP officer at the airport of departure. For those who are starting their travel at airports without CBP offices, the inspection will need to take place at the airport (involved in the travel) where a CBP office is located. Hunters/shooters should make every effort to arrange for adequate time (e.g. several hours) before or between flights to fulfill this inspection requirement. Ignorance of the procedures or avoidable failure to budget adequate time for the inspection will not encourage CBP personnel to assist with an expeditious inspection process.
Non-Airline Travel: The (attached) Fact Sheet and information provided at the meeting attended by representatives of SCI, addresses only travel by commercial airline. We have no concrete information about the enforcement of these new procedures on individuals traveling by other means (e.g., automobile travel to Canada).
SCI Reaction: SCI is currently working with representatives of the National Rifle Association, National Shooting Sports Foundation, and the Congressional Sportsmen’s Foundation to find solutions to the problems presented by these new procedures and to develop more suitable alternatives for the hunter/shooter who wishes to travel with his or her firearms. We are also working on ways that our members can help to communicate our concerns about the problems caused by these new requirements. We will keep you posted with new developments.