CUSTOMS COMPLIANCE | 2026-09-23

CBP Opens an Electronic Export Manifest Test for Truck Cargo — Nine Carrier Slots, Filed 24 Hours Before Departure, Starting October 23, 2026

A voluntary two-year ACE test that moves truck export manifest data from paper at the border to electronic filing before the truck leaves, with the complete manifest due two hours before arrival at the port of export.

On September 23, 2026 U.S. Customs and Border Protection announced the ACE Electronic Export Manifest for Truck Cargo Test. Participating carriers agree to submit limited export manifest data electronically at least 24 hours before departure from the United States, completed by a full export manifest filing no later than two hours before arrival at the final port of export. The test begins October 23, 2026 and runs approximately two years. CBP is limiting participation to nine truck carriers and

On September 23, 2026 U.S. Customs and Border Protection published a notice announcing that it will conduct an Automated Commercial Environment Electronic Export Manifest for Truck Cargo Test. The test is voluntary. Participants agree to submit certain limited export manifest data electronically at least 24 hours prior to departure from the United States to a foreign destination, complemented by the complete export manifest filing no later than two hours prior to arrival at the final port of export.

The test begins October 23, 2026 and runs for approximately two years, subject to extension, modification or early termination announced in the Federal Register. Comments on any aspect of the test may be submitted at any time during the test period.

Nine slots, first come

CBP is limiting this test to nine truck carriers. There are no restrictions on organization size, location or commodity type. CBP will accept applications until it has received applications from nine parties meeting all participant requirements, and states that in selecting participants it will take into consideration the order in which applications are received.

That is an unusually small program, and the first-come element means a carrier that wants a seat should not treat the October 23 start date as the deadline. The practical deadline is whenever the ninth qualifying application arrives.

The technical requirement is the real gate

Prospective participants must have the technical capability to submit data to CBP electronically through ACE. There are two routes.

A participant may file through the ACE Export Truck Manifest Trade Portal, which is the lower-barrier option. Or it may file by electronic data interchange — but a carrier choosing EDI must be able to receive response message sets via Cargo-ANSI X12 or Unified XML, and must successfully complete certification testing with its client representative. Parties planning to use EDI must complete a test phase to confirm the data transmission is in the required readable format, and are notified once they have passed and may participate fully.

For most mid-sized carriers the portal route is the realistic one. The EDI route implies a development project with a certification gate in front of it, and that project has to be scoped now to be ready for a two-year window that has already begun accepting applications.

Where CBP's authority comes from

This is a National Customs Automation Program test. The Customs Modernization Act gives the Commissioner of CBP authority to conduct limited test programs or procedures designed to evaluate planned NCAP components. The test is authorized under 19 U.S.C. 1411-1415 and 19 CFR 101.9(b), which provides for the testing of NCAP programs and procedures and allows the Commissioner, for purposes of such a test, to impose requirements different from those specified in the CBP regulations.

That last clause is the one participants should register. Inside a test, the operative rules are the rules of the test notice, not the ordinary regulatory baseline. Obligations, timing and data elements come from the notice itself.

The test is also framed as furthering the International Trade Data System initiatives set out in section 405 of the Security and Accountability for Every Port Act of 2006 (Pub. L. 109-347, 19 U.S.C. 1411(d)), whose stated purpose includes eliminating redundant information requirements across agencies.

The benefits CBP identifies

CBP is candid that benefits will vary, and lists several advantages of joining. Reduced costs from fewer examinations required after cargo is already loaded on the truck. Reduced delays and associated costs from fewer trucks being stopped for inspection at the border, and less cargo being returned to CBP custody for inspection once it has departed the United States. More accurate real-time transportation data — such as date and port of export — which, when linked to the AES Electronic Export Information filing, can reduce the likelihood of penalties issued to exporters or carriers under 15 CFR part 30 for incorrect information.

That third benefit deserves emphasis, because it reaches beyond carriers. Penalties under 15 CFR part 30 for incorrect EEI data fall on exporters as well as carriers, and date and port of export are among the fields most often wrong — precisely because they are recorded after the fact rather than captured as the movement happens. An exporter whose carrier participates may see its own filing accuracy improve without doing anything itself.

CBP is equally clear about costs: participants are responsible for all costs incurred as a result of participation, varying with their pre-existing infrastructure.

Two conditions worth reading before applying

First, participation is not confidential. CBP states that the name of an approved participant in any ACE test will be disclosed upon a written Freedom of Information Act request, in accordance with 5 U.S.C. 552. A carrier that regards its CBP program participation as commercially sensitive should know that before applying.

Second, the misconduct provision has teeth. If a participant fails to abide by the rules, procedures or terms and conditions of the test and all other applicable Federal Register notices, fails to exercise reasonable care in executing its obligations, or otherwise fails to comply with applicable laws and regulations, it may be suspended from the test and subjected to penalties, liquidated damages, or other administrative or judicial sanction. CBP also reserves the right to suspend a participant on a determination that an unacceptable compliance risk exists.

CBP will notify a participant of a suspension decision, the facts or conduct warranting it, and its effective date, and the decision may be appealed in writing to the Executive Assistant Commissioner, Office of Field Operations. In cases of willful misconduct, or where public health or safety is concerned, suspension may be effective immediately.

The "reasonable care" standard is familiar from the import side, and it carries the same meaning here: a good-faith intention is not the test, a documented process is.

Why a nine-carrier test matters to everyone else

Voluntary CBP tests are how mandatory requirements are built. The notice describes the ACE development pattern directly: each release begins with a test and ends with mandatory use of the new feature, and each release builds on the previous ones.

Truck export manifest is one of the last significant paper-and-presentation processes at the land border. A two-year voluntary test of electronic filing, with a 24-hour advance data element, is the ordinary prelude to a rulemaking that makes it compulsory. Carriers and exporters who watch what the nine participants learn — and what CBP changes in response to comments during the test — will be several years ahead of those who wait for a final rule.

What California exporters and carriers should do

First, if you run trucks to Mexico or Canada and have ACE capability, evaluate applying now rather than in October. Nine slots, filled in order of receipt.

Second, if you are an exporter rather than a carrier, ask your carriers whether they are applying. Your EEI accuracy and your border dwell times are affected by their answer even though the application is not yours to file.

Third, examine whether you could actually produce manifest data 24 hours before departure. For many operations that is the genuine obstacle — not the filing mechanism but knowing the load, the destination and the port of export a full day ahead. That is a scheduling and systems question, and it is worth answering regardless of whether you join the test, because it is the direction the requirement is heading.

Fourth, reconcile your export documentation process against your import compliance process. Firms often run them separately, with the import side disciplined by CBP audit and Focused Assessment experience and the export side handled informally. The penalty exposure under 15 CFR part 30 is real, and a test that surfaces date-and-port-of-export discrepancies will surface them for the exporter too.

Fifth, take advantage of the open comment period. Comments may be submitted at any time during the test, and operational objections grounded in what carriers can actually produce, in what format, at what cost, carry more weight than general objections.

A note on direction of travel

Read alongside CBP's September 2, 2026 proposed rule on heightened import disclosures and its enforcement of importer of record data accuracy under Executive Order 14411, the pattern is consistent: CBP is moving toward earlier, electronic, verifiable data about who is moving what, in both directions across the border. Export manifest was the remaining gap.

Trembach Law Firm advises exporters, carriers and brokers on customs compliance, CBP programs and enforcement. To discuss participation in this test or your export documentation process, call (818) 514-7680, or contact a customs defense attorney or our San Diego port customs practice.

Frequently Asked Questions

What does a participating carrier have to file, and when?

Participants agree to submit certain limited export manifest data electronically at least 24 hours prior to departure from the United States to a foreign destination, complemented by the complete export manifest filing no later than two hours prior to arrival at the final port of export.

How many carriers can join, and what is the real deadline?

CBP is limiting the test to nine truck carriers, with no restrictions on organization size, location or commodity type. CBP will accept applications until it has received applications from nine parties meeting all participant requirements, and will take into account the order in which applications are received. The practical deadline is whenever the ninth qualifying application arrives, not the October 23, 2026 start date.

What are the technical options for filing?

Either the ACE Export Truck Manifest Trade Portal, which is the lower-barrier option, or electronic data interchange. A carrier choosing EDI must be able to receive response message sets via Cargo-ANSI X12 or Unified XML and must successfully complete certification testing with its client representative, including a test phase confirming the transmission is in the required readable format.

How long does the test run?

It begins October 23, 2026 and runs for approximately two years, subject to extension, modification or early termination announced in the Federal Register. Comments on any aspect of the test may be submitted at any time during the test period.

Does joining change which rules apply to me?

Yes, and it is worth registering. The test is authorized under 19 U.S.C. 1411-1415 and 19 CFR 101.9(b), which allows the Commissioner, for purposes of such a test, to impose requirements different from those specified in the CBP regulations. Inside a test, the operative rules — obligations, timing and data elements — come from the test notice rather than the ordinary regulatory baseline.

What does CBP say participants get out of it?

CBP is candid that benefits will vary. It lists reduced costs from fewer examinations required after cargo is already loaded on the truck, and reduced delays and associated costs from fewer trucks being stopped for inspection at the border and less cargo being returned to CBP custody for inspection once it has departed.

This article is provided for general informational purposes only and is not legal advice. Reading it does not create an attorney-client relationship. Program eligibility and compliance obligations depend on the specific facts and operations of each participant, and no particular outcome is guaranteed. Consult a qualified attorney about your own circumstances.

Contact Trembach Law Firm at (818) 514-7680 for a confidential consultation.

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