19 CFR 141.89: Commercial Invoice Requirements by Category

The commercial invoice requirements in 19 CFR 141.89 add category-specific technical details to the standard invoice for dozens of merchandise types, from metals and chemicals to textiles, watches, bearings, and beads. U.S. Customs and Border Protection uses this data to classify goods under the Harmonized Tariff Schedule and calculate duties, so vague or missing entries can hold up a shipment or lead to civil penalties. What follows is what the regulation actually asks for, category by category, and what happens when the invoice falls short.

How the Rule Works

Section 141.89 sits on top of the baseline commercial invoice requirements in 19 CFR 141.86. Every import needs a compliant 141.86 invoice; if your goods fall into one of the categories listed in 141.89, you add the extra data points that section calls for. The list is organized alphabetically by merchandise type, which makes it straightforward to check whether your product carries additional requirements.¹

Two baseline rules from 141.86 catch importers regularly. The invoice and any attachments must be in English or accompanied by an accurate English translation detailed enough for CBP to examine the merchandise and determine duties. And quantities must be stated in the weights and measures of the country of shipment or of the United States; if the invoice fails to disclose the weight, gauge, or measure needed to calculate duties, the importer pays for CBP to weigh or measure the goods before release.²

Metals: Aluminum, Copper, Iron, and Steel

Metal classifications hinge on exact chemical composition, and the invoice data has to come from certified laboratory or mill reports rather than estimates.

Aluminum and aluminum alloys under HTSUS subheadings 7601.10.60, 7601.20.60, 7601.20.90, or 7602.00.00 require a statement of the percentages by weight of every metallic element in the article.
Copper articles classifiable under Chapter 74 require the article’s weight and the percentage of copper along with all other elements by weight.
Iron and steel under Chapter 72 or headings 7301 through 7307 require percentages by weight of carbon and any metallic elements, provided as a mill analysis or mill test certificate.

Get these reports from the foreign smelter or mill before the invoice is drafted. Reconstructing metallurgical data after the shipment arrives creates delay and risk.¹

Chemicals, Dyes, and Related Products

Chemical compounds in Chapters 27, 28, and 29 need two things on the invoice: the intended use of the compound and its Chemical Abstracts Service (CAS) number. That is the full requirement for those chapters.

Colors, dyes, stains, and related products under HTSUS heading 3204 are far more granular. The invoice must show:

The product’s invoice name and trade name
The identity and percentage by weight of each component
The Color Index number and Color Index generic name, or a statement that none exists
The CAS number of the active ingredient
The class of merchandise (acid dye, basic dye, disperse dye, vat dye, toner, and so on)
The material the product is designed to be applied to

Missing any single field can stall the entry.¹

Textiles, Wearing Apparel, and Footwear

Fiber content controls both tariff classification and eligibility for preferential trade programs, so textile invoices draw heavy scrutiny.

Wearing Apparel

Every textile apparel invoice needs a component material breakdown in percentages by weight for every fiber in the entire garment. On top of that total, the invoice must give separate fiber breakdowns for the outer shell (excluding linings, cuffs, waistbands, collars, and trimmings) and for the lining. Garments made from more than one type of material, such as knit combined with woven fabric, or fabric combined with leather, fur, or plastic, need a fiber breakdown by weight for each separate textile material and a percentage by weight for each non-textile material.

Woven garments must state whether the fabric is yarn-dyed and whether there are two or more colors in the warp or filling. All-white T-shirts and singlets must note whether they contain pockets, trim, or embroidery. Mufflers must include exact dimensions in length and width. Separately, textile fiber products must identify the manufacturer by name or by an identification number registered with the Federal Trade Commission, and state the country where the product was processed or manufactured.¹

Footwear

Footwear under HTSUS headings 6401 through 6405 requires the manufacturer’s style number, the importer’s style or stock number, and a material breakdown expressed as a percentage of the external surface area. Those percentages must be reported separately for the upper and the outersole, covering leather, composition leather, rubber or plastics, textile materials, and any other material present. Each “other” material needs its own separate percentage rather than being lumped together.

Bed Linen and Bedspreads

Invoices for bed linen and bedspreads must state whether the article contains any embroidery, lace, braid, edging, trimming, piping, or appliqué work. A yes-or-no answer satisfies the rule, but omitting it causes classification problems because decorated and undecorated versions often fall under different tariff lines.¹

Watches, Bearings, and Machine Tools

Watches and Watch Movements

For complete watches under HTSUS Chapter 91, the invoice must describe the composition of the case and the bracelet, band, or strap, and give the movement’s commercial description: ebauche caliber number, ligne size, and number of jewels. Battery-operated watches must identify the battery by manufacturer name and reference number. For watch movements imported separately, the same commercial description applies, plus the manufacturer of the movement and the country where it was manufactured. Importers who source movements from one country and cases from another should confirm that both suppliers understand these requirements before shipping.

Ball and Roller Bearings

Bearings under HTSUS subheadings 8482.10.50 through 8482.80.00 require a statement of whether the bearing is a ball or roller type. Roller bearings must specify the subtype: spherical, tapered, cylindrical, needle, or other. Combination bearings that contain both ball and roller elements must be identified as such. For ball bearings that are not integral-shaft types, the invoice must state whether the bearing is radial (meaning it primarily supports loads perpendicular to the shaft axis) and provide the outside diameter of each bearing.

Machine Tools

Requirements here layer by HTSUS heading:

Headings 8456 through 8462: state whether the tool is equipped with computer numerical control (CNC) or the electrical interface for CNC.
Headings 8458 through 8463: disclose whether the tool is used or rebuilt.
Subheading 8456.30.10: specify whether the electrical discharge machine is a traveling-wire (wire-cut) type.
Subheading 8457.10.00: indicate whether the machining center has an automatic tool changer; vertical spindle machining centers with an automatic tool changer must also report Y-axis travel distance.
Subheadings 8458.11.0030 through 8458.11.0090: horizontal numerically controlled lathes must state the rated horsepower or kilowatt rating of the main spindle motor, using the continuous rating rather than the 30-minute rating.¹

Beads, Fur, Earthenware, and Other Covered Goods

Bead imports need three data points: the length of the string (if strung), the size of each bead in millimeters, and the material, such as glass, ivory, or imitation pearl. This prevents synthetic materials from being misidentified as natural stones.

Fur products must identify the animal species using the names from the Fur Products Name Guide (16 CFR 301.0), state whether the fur is used, and disclose any bleaching, dyeing, or artificial coloring. Earthenware and crockery sets must list the kinds and quantities of articles in each set, the exact maximum diameter of all plates in centimeters, and the unit value for each style and size of plate, cup, saucer, or other piece.

The full list runs to dozens of categories. If you deal in specialized goods, work from the regulation itself rather than a summary.¹

Sugar and Fish

Raw sugar is assessed estimated duties based on a polariscopic test of at least 96 degrees unless the commercial invoice indicates a lower grade than an ordinary commercial shipment. The “degree” is an International Sugar Degree determined by polarimetric testing, which measures the percentage of sucrose. A wrong figure means duties are calculated on the wrong base, and the discrepancy shows up at liquidation.³

Fish or fish livers imported in airtight containers under HTSUS Chapter 3 require a statement of whether the articles contain any oil, fat, or grease that existed separately before being added, along with the name and quantity of any such oil, fat, or grease.¹

When a Commercial Invoice Isn’t Ready

Under 19 CFR 141.83, if no commercial invoice is available at entry, the importer must file a pro forma (substitute) invoice with enough information for CBP to examine the merchandise and determine duties. Any invoice, memorandum invoice, or bill in the importer’s possession should go along with it. The pro forma must also include the statistical information required under 19 CFR 141.61(e).⁴

One boundary worth flagging: shipments with a fair retail value of $800 or less in the country of shipment, imported by one person on one day, generally qualify for duty-free entry under 19 CFR 10.151 through informal entry procedures and do not face the full formal commercial invoice requirements. The exemption does not apply to shipments deliberately split to avoid compliance.⁵

Penalties for Inaccurate or Incomplete Invoices

Materially incorrect or missing invoice information can lead to civil penalties under 19 U.S.C. 1592, which covers fraud, gross negligence, and negligence in import transactions. Statutory maximums escalate with culpability:

Negligence: up to two times the lawful duties lost, or the domestic value of the merchandise, whichever is less. If the violation did not affect duty assessment, the ceiling is 20 percent of the dutiable value.
Gross negligence: up to four times the lawful duties lost, or the domestic value, whichever is less. If no duties were affected, the ceiling is 40 percent of the dutiable value.
Fraud: up to the full domestic value of the merchandise.

CBP applies internal mitigation guidelines that typically settle cases below the statutory ceiling. For grossly negligent duty-loss violations, actual penalties usually range from 2.5 to 4 times the lost duties; for negligent violations, from the lost duties up to 2 times that amount.⁶⁷

The line between negligence and gross negligence typically comes down to whether the importer failed to exercise reasonable care or acted with actual knowledge of, or reckless disregard for, the relevant facts. Providing rough estimates instead of verified test data when the regulation demands specifics is the kind of shortcut that pushes a case from negligence toward gross negligence. Getting the metallurgical report, the fiber breakdown, or the CAS number right the first time is considerably cheaper than contesting a penalty afterward.

Recordkeeping

Keep commercial invoices and related entry records for five years from the date of entry. CBP can request them at any point in that window. A few categories run shorter: packing lists must be kept for 60 calendar days after the release period ends; records for informal entries by a consignee who is not the owner or purchaser must be kept for two years; records for duty-free articles must also be kept for two years. Records related to drawback claims must be retained until three years after the date of payment on the claim.⁸

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eCFR. 19 CFR 141.89 – Additional Information for Certain Classes of Merchandise
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eCFR. 19 CFR 141.86 – Contents of Invoices and General Requirements
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eCFR. 19 CFR Part 151 Subpart B – Sugars, Sirups, and Molasses
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eCFR. 19 CFR 141.83 – Pro Forma Invoice
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eCFR. 19 CFR 10.151 – Importations Not Over $800
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Office of the Law Revision Counsel. 19 USC 1592 – Penalties for Fraud, Gross Negligence, and Negligence
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eCFR. Appendix B to Part 171 – Guidelines for the Imposition and Mitigation of Penalties for Violations of 19 USC 1592
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eCFR. 19 CFR Part 163 – Recordkeeping