CBP 7512 In-Bond Moves: IT, T&E and IE Explained

A container lands at Los Angeles, rides a train to Chicago under bond, and is released to the importer a week later. Everyone treats the move as finished. Two months on, the bonded carrier receives a claim for liquidated damages equal to the cargo's full value, because nobody sent the arrival message within two business days and the in-bond record still shows the box somewhere on the rails.

An in-bond movement lets foreign goods travel under a carrier's bond before duty is paid or before they leave the country, but the bond holder stays answerable until the record is closed. Getting the entry type, the data, the clocks and the closing messages right keeps that exposure at zero, and the same discipline applies to Indian transhipment from a gateway port to an inland depot.

• What you will learn: how IT, T&E and IE entries differ, what replaced the paper CBP Form 7512, which data the application carries and how the 30-day and 15-day clocks run.
• Risk and liability: diversion rules, the custodial bond's liquidated damages, India's transhipment bond under the Sea Cargo Manifest and Transhipment Regulations, 2018, and a costed loss in dollars and rupees.

Why foreign cargo can travel inland before duty is settled

An in-bond movement carries imported merchandise from the port where it first lands to another US port, or out of the country, without formal entry or duty payment at the first port. The carrier's bond, not the importer's cash, secures the government's interest while the goods are moving.

Under 19 CFR 18.1(a), moving merchandise in bond requires an in-bond application made up of a transportation entry and a manifest. The movement must be covered by a CBP Form 301 custodial bond carrying the conditions in 19 CFR 113.63, and CBP must authorise the movement electronically before the goods leave the origin port. Historically, all of this was written on the paper CBP Form 7512, which is why the trade still calls an in-bond "a 7512".

Every US in-bond movement under 19 CFR Part 18 needs a transportation entry and manifest, a CBP Form 301 custodial bond with 19 CFR 113.63 conditions and electronic CBP authorisation before departure. Goods must reach the destination or export port within 30 days, or 60 days when any leg moves by barge.

Our guide to e-way bills for imported cargo touches on in-bond moves only as a US contrast to India's road document. This page is the full treatment: entry types, data, deadlines, liability and the Indian transhipment equivalent.

IT, T&E and IE: three entry types and where each one closes

The entry type tells CBP where the bonded journey ends and what happens next. Pick it from the cargo's final disposition, not from the transport route, because the wrong type closes the record at the wrong port and leaves the bond exposed.

• Immediate Transportation (IT): foreign goods move from the arrival port to another US port, where the importer makes entry, admits them to a foreign-trade zone or exports them. CBP's 7512 instructions use class code 61.
• Transportation and Exportation (T&E): goods cross US territory and leave from a different US port without entering US commerce, as with Asian cargo moving by rail to Laredo for Mexico. Class code 62.
• Immediate Exportation (IE): goods are exported from the same port where they arrived, for example a transshipment from one vessel to another at Long Beach. Class code 63.
• Warehouse withdrawals: 19 CFR 18.1(b) also lists withdrawals from a bonded warehouse for IT, IE or T&E, and IE or T&E entries for vessel and aircraft supplies.

An IT shipment therefore closes when the destination port records arrival and the goods are entered, while T&E and IE shipments close only on proof of export. Under 19 CFR 18.7(a)(2), a T&E shipment must be exported within 15 calendar days after its last portion arrives at the export port; on the sixteenth day it falls under the general order rules.

From paper Form 7512 to ACE: QP applications and WP closures

CBP Form 7512 still names the transaction, but the paper copy is no longer how most in-bonds move. CBP's final rule on changes to the in-bond process was published on 28 September 2017 and took effect on 27 November 2017, moving the process to electronic filing and closure.

CBP stopped accepting paper Form 7512 for input into ACE on 2 July 2018, and electronic reporting of all in-bond transactions became mandatory on 6 August 2018. In the ABI-hosted interface, a QP transaction carries the in-bond application and a WP transaction reports arrival and export. Ocean, rail and truck movements must use ACE or QP and WP; air carriers may use either route.

Data the in-bond application must carry, item by item

An in-bond application fails most often on description and quantity, not on carrier details. Section 18.1(d)(1) lists the electronic data, and CBP's older Form 7512 instructions explain why vague descriptions are refused.

• Tariff number: the six-digit HTSUS number for the merchandise, although CBP's FAQ notes that no enforcement date had been set for this element.
• Description for regulated goods: enough detail for any other agency that regulates the goods to decide whether to examine or detain them.
• Quantity: counted in the smallest external packing unit; containers and pallets are not acceptable units, so "2 containers" fails while "1,920 cartons on 40 pallets" passes.
• Container and seal: both numbers, with the seal number allowed up to two business days after filing if it is unknown when the application goes in.
• Destination: the US destination port for IT, or the export port and first foreign port for T&E and IE.
• Optional permits: visa, permit or licence numbers where they apply.

Any party listed in 18.1(c) may file: the carrier bringing the goods to the origin port, the carrier accepting them under its bond or a carnet, or a person with sufficient interest in the goods, such as the importer's broker. Filing can happen at any time before the goods leave the origin port, which lets brokers pre-file while the vessel is still at sea.

The 30-day transit clock, the 15-day window and general order

Two clocks govern every in-bond, and both start from events your team must timestamp. Miss the first and the delivery is irregular; miss the second and the goods go to a general order warehouse at the cargo owner's cost.

Under 19 CFR 18.1(i)(1), merchandise must reach CBP at the destination or export port within 30 days. The clock starts on the later of the conveyance's arrival at the origin port, where the application was approved before arrival, or the date CBP authorises the movement; it does not run from the day the carrier picks up the goods. Time spent held for examination is excluded, and a port director may extend the period on written request.

-- Open in-bonds approaching the 30-day limit, and T&E arrivals not yet exported
-- Table inbond: one row per in-bond number; timestamps stored in port local time
SELECT inbond_no,
       entry_type,                                   -- 61 IT, 62 T&E, 63 IE
       GREATEST(origin_arrival_at, cbp_authorized_at) AS clock_start,
       GREATEST(origin_arrival_at, cbp_authorized_at)
         + INTERVAL '30 days' + exam_hold_days * INTERVAL '1 day' AS deliver_by,
       dest_arrival_reported_at,
       export_reported_at
FROM   inbond
WHERE  closed_at IS NULL
  AND (
        -- transit clock: flag at day 25 so a carrier can still request an extension
        (dest_arrival_reported_at IS NULL
         AND now() >= GREATEST(origin_arrival_at, cbp_authorized_at)
                      + INTERVAL '25 days' + exam_hold_days * INTERVAL '1 day')
     OR -- T&E export window: 15 calendar days after the last portion arrives (19 CFR 18.7(a)(2))
        (entry_type = 62 AND export_reported_at IS NULL
         AND now() >= last_portion_arrived_at + INTERVAL '12 days')
      );
-- Use the earlier origin arrival only if the application was approved before arrival;
-- otherwise the authorisation date governs. Business-day rules (arrival and export
-- updates within 2 business days) need a holiday calendar, not a plain interval.

Once any part of the shipment arrives at the destination or export port, 18.1(j) requires an electronic arrival report within two business days, including the FIRMS code of the place where the goods sit. Then 18.1(k) gives 15 calendar days from arrival of the entire shipment to enter it, export it or admit it to a foreign-trade zone; on day 16 it becomes general order merchandise.

Diversion, amendments and the two-business-day update rule

A diversion changes the destination or export port, and since the 2017 rule it needs CBP's electronic permission first. It never buys extra time: the diverted shipment must still arrive within the original 30 days counted from the first authorisation.

Under 19 CFR 18.5, only the filer of the in-bond application may request a diversion, through a CBP-approved EDI system, and CBP may refuse it where another agency restricts the goods. CBP's FAQ explains that approvals are automated in ACE and carry disposition code 3W; if the request is rejected, the cargo goes to the original port. Agricultural transit permits still bind the carrier even after CBP approves a diversion.

• Record updates: 18.1(h) requires the filer, or another listed party with the bond holder's authorisation, to update or amend the record electronically within two business days of the event that changes it.
• Arrival reporting: 18.1(j) and 18.7(a)(1) make a late or missing arrival report an irregular delivery, even when the goods arrived on time.
• Export proof: 18.7(a)(3) requires the record to be updated within two business days after export, and 18.7(c) obliges the exporting carrier to keep export records for five years.
• Deletion limits: CBP's 2015 ACE guidance states that an in-bond already arrived or exported cannot be deleted until a CBP officer reverses that status.

Bond liability: merchandise value, triple value and $1,000 defaults

The party whose bond is obligated on the transportation entry carries the liability. Under 19 CFR 18.8(a) that party answers for shortages, irregular delivery, non-delivery, failure to export a T&E shipment and broken seals, and any loss found at destination is presumed to have happened in its custody unless conclusive evidence shows otherwise.

The custodial bond's liquidated damages clause in 19 CFR 113.63(j) sets the amounts. Defaults involving merchandise are claimed at the value of the merchandise involved, or three times that value where the goods are restricted or prohibited or are alcoholic beverages. Defaults that do not involve merchandise, such as a late report, are claimed at $1,000 each. Duties, taxes and fees on missing goods come on top under 18.8(c), and they are not limited to the bond amount.

Liquidated damages on a US custodial bond under 19 CFR 113.63(j) equal the merchandise value for an in-bond default, triple value for restricted goods or alcohol, and $1,000 for defaults without merchandise. Duties on missing cargo are owed separately under 19 CFR 18.8(c), uncapped by the bond amount.

Claims are not the end of the road. Section 18.8(b)(2) lets CBP cancel a claim, accept less or waive payment when a petition under 19 CFR Part 172 shows the violation happened without intent to evade the law. Petitions succeed far more easily when the carrier can show timestamped proof that the goods arrived or left, which is why the closing messages and their evidence matter more than the claim response.

India's counterpart: transhipment under Customs Act section 54

India achieves the same result through transhipment. Section 54 of the Customs Act, 1962 lets goods named in the arrival or import manifest for transhipment move without payment of duty, either out of India subject to section 11, or to another customs station such as an inland container depot, subject to prescribed conditions for their arrival there.

The conditions now sit in the Sea Cargo Manifest and Transhipment Regulations, 2018. Under regulation 7, the authorised carrier, which may be a sea carrier, a train operator or a custodian, files a departure manifest before the train or truck leaves and an arrival manifest when it arrives, in Form VIII for moves between a port or ICD and an ICD, CFS, SEZ or foreign post office, and in Form VIIIA for moves to a land customs station.

• Bond: regulation 9(1)(c) requires the authorised carrier to execute a bond in Form IX A, IX B, IX C or IX D, with or without bank guarantee or surety; direct sea-port-to-sea-port transhipment needs no bond.
• Sealing: regulation 9(1)(d) requires a customs officer to seal the container, bonded truck or wagon for a land-route transhipment, unless the Commissioner records reasons for waiving it.
• Carrier duties: regulation 10(1) requires records of goods brought for transhipment, a track-and-trace facility, and makes the carrier liable to pay duty on goods pilfered or lost in transit under its custody.
• Penalty: regulation 13 sets a penalty of up to ₹50,000 for contravening any provision.

India's regulations set no single statutory transit day count comparable to the US 30-day rule; control comes from the paired departure and arrival manifests, the seal and the bond. The table below prices one illustrative loss on each side, using assumed duty rates rather than any particular tariff line.

Indian transhipment from a gateway port to an ICD under Customs Act section 54 relies on Form VIII departure and arrival manifests, a Form IX bond and a customs seal under the Sea Cargo Manifest and Transhipment Regulations, 2018, with carriers paying duty on pilfered goods and penalties up to ₹50,000.

A T&E container that crossed the border but stayed open in ACE

Most in-bond claims involve cargo that arrived and left exactly as planned. The failure is in the record, and the trace below shows how a delivered T&E box became a liquidated damages claim.

1. 3 March, 08:12: CBP authorises in-bond 62 for container ABCU 4182270, 1,920 cartons of phone accessories, from Los Angeles to Laredo for export to Monterrey; the 30-day clock starts at this authorisation, which came after the vessel arrived the previous day.
2. 20 March, 17:40: the drayage carrier delivers the container to a bonded yard in Laredo; the driver's mobile app records the gate-in, but the carrier's ACE interface sends no WP arrival message.
3. 24 March, 10:05: the Mexican carrier takes the container across the border; the forwarder believes the export is complete and closes the job in its TMS, still without an export update.
4. 2 April, 06:00: the in-bond passes day 30 with no arrival or export on record; CBP later issues a liquidated damages claim against the bonded carrier for irregular delivery and failure to show export.
5. Controlled path: the yard's gate-in event triggers the arrival report within two business days with the FIRMS code, and the border crossing triggers the export update; the claim never arises, and the carrier's petition file holds both timestamps if one does.

Running an in-bond desk: owners, checks and go-live list

An in-bond desk works when every message has a named owner and every clock has an alert. Split filing, arrival and export reporting by party, then decide which checks the system enforces and which a person must make.

For overland transit across land borders with carnets and handovers at border yards, see our cross-border land customs and transshipment architecture, which deals with the corridor design rather than the US in-bond record itself. More import and export guides sit in the logistics and supply chain library, and if you need a system that tracks in-bond clocks and closing messages, you can share your requirements with us.