More information regarding the new requirements can be found on the Immigration and Customs Enforcement website.
For reasons unclear to us, the rule change was never enforced. Now, however, it will be. According to the NRA-ILA, “In postings on the Immigration and Customs Enforcement (ICE) website and in internal ICE documents obtained by NRA-ILA, ICE makes clear that it has begun enforcing the rule change. Form 4457 may no longer be used for firearms, and electronic declarations will be the norm.”
AES is an online reporting tool designed for business use. It is a joint venture between Customs, the Foreign Trade Division of the Census Bureau (under Commerce), the Bureau of Industry and Security (also under Commerce), the Directorate of Defense Trade Controls (under State), other federal agencies and the export trade community.
According to advice posted by Safari Club International (SCI), American hunters planning to travel abroad with their personal firearms must, at the time of departure, declare the articles to a Customs officer, present an Internal Transaction Number obtained from the submission of the Electronic Export Information in the AES and present the guns (and ammo, if any) for inspection to Customs at the port of departure. Gun owners must declare that the articles are for their exclusive use, that the guns and ammo will not be re-exported or otherwise change ownership and that it is their intent to return to the States with the articles.
Here’s the catch: Individuals are currently unable to use the AES because it requires entry of an Employer Identification Number, according to internal ICE documents. Of course private U.S. citizens have no Employer Identification numbers, which are obtained only by businesses. According to the Internal Revenue Service, they should be used only for tax purposes. Clearly, say NRA-ILA personnel, law-abiding American hunters traveling abroad with personally owned firearms are not exporters “under any reasonable understanding of what that term is intended to mean.”