How to Fill Out a Commercial Invoice for Customs: HS Codes and Incoterms

A commercial invoice tells customs who is shipping what to whom, for how much, and under what terms, and knowing how to fill out a commercial invoice for customs comes down to getting six things right: the parties, the goods, the classification, the value, the shipping terms, and any product-specific declarations. Federal regulations spell out exactly what must appear on the document.¹ Miss a required element and your shipment sits at the border. Understate the value or misdeclare origin and you can face civil penalties up to the full domestic value of the merchandise.²

Identify the Parties

Start with who is on each end of the transaction. Under 19 CFR 141.86, the invoice must state the person by whom and the person to whom the merchandise is sold, the place from which it was shipped, and the date of the transaction.¹ List full legal names and physical addresses for the shipper and the consignee, plus a direct phone number for each so a customs agent or carrier can resolve issues without returning the shipment.

The consignee should be the party actually receiving the goods, not a freight forwarder acting as a pass-through. If the shipment routes through a third party before reaching the end buyer, list the ultimate consignee separately.

Include tax identification numbers. U.S.-based shippers typically provide an Employer Identification Number. For shipments into the European Union, the importer needs an Economic Operators Registration and Identification (EORI) number, which is mandatory for any customs operation in the EU whether it’s an import, export, or transit.³ Missing a required tax ID is one of the most common reasons shipments get held.

Make sure the party details on the invoice match the bill of lading and any other transport documents exactly. Customs officers cross-reference these, and even a minor name mismatch can trigger a hold.

Describe and Classify Each Product

Vague descriptions cause more invoice problems than any other single issue. The regulation requires “a detailed description of the merchandise, including the name by which each item is known, the grade or quality, and the marks, numbers, and symbols under which sold by the seller or manufacturer.”¹ A line item that says only “parts” will likely trigger an inspection. “Stainless steel industrial bolts, 10mm, for automotive assembly” gives an officer what they need to classify and assess the goods without opening the box.

Give each product its own line with a quantity and unit of measure (kilograms, liters, individual pieces, or whatever fits). You may use the weights and measures of either the exporting country or the United States.¹ A table with columns for description, quantity, unit measure, and value makes verification fast.

Harmonized System Codes

Every item needs a Harmonized System (HS) code. The system is maintained by the World Customs Organization and used by more than 200 countries, with the first six digits identical worldwide and additional digits added by individual countries for their tariff schedules.⁴ U.S. classifications use a 10-digit number under the Harmonized Tariff Schedule.⁵ You can look up codes through the International Trade Administration’s tools or the Census Bureau’s Schedule B search. A wrong code doesn’t just delay the shipment; it can mean the wrong duty rate, and CBP can reclassify and bill you the difference plus interest later.

Country of Origin

List the country of origin for every product, meaning where the goods were manufactured or underwent a substantial transformation, not where they were purchased or warehoused.¹ Country of origin determines which tariff rates, trade agreements, antidumping duties, or sanctions apply. Misrepresenting origin can result in penalties reaching the full domestic value of the merchandise under the fraud tier of 19 USC 1592.²

State the Value and Every Charge

The invoice must show the purchase price for each item in the currency of the transaction. If the goods weren’t sold (samples or returns, for example), list the value the seller would have received in the ordinary course of trade at wholesale quantities in the exporting country.¹ Identify the currency (USD, EUR, GBP, and so on).

Beyond unit and total prices, itemize every charge on the merchandise separately: freight, insurance, commissions, packing, and any other expense incurred to bring the goods from the export port to the first U.S. port of entry.¹ Packing costs and inland freight to the export port don’t need separate line items if they’re already rolled into the invoice price, but you must note that they’re included. List any rebates, drawbacks, or bounties allowed upon exportation separately. These details feed into the customs valuation that determines duty owed.

Penalties for getting value wrong are steep. Under 19 USC 1592, fraudulent undervaluation can bring a civil penalty up to the full domestic value of the merchandise; gross negligence carries up to four times the duties the government lost; simple negligence caps at two times the lost duties.² If you discover a valuation error after filing, voluntarily disclosing it before CBP starts investigating can significantly reduce penalty exposure.

Also identify any assists. These are goods or services furnished for the production of the merchandise that aren’t included in the invoice price, such as dies, molds, tools, or engineering work provided to the manufacturer. Customs adds the value of assists to the transaction value when calculating duties, so omitting them creates an undervaluation problem.¹

Incoterms

Specify which Incoterms rule governs the transaction. Incoterms are standardized trade terms published by the International Chamber of Commerce, currently in the Incoterms 2020 edition, that define which party pays for shipping and insurance and bears the risk of loss at each stage of transit.⁶ Common terms include FOB (Free On Board), where the seller’s responsibility ends when goods are loaded onto the vessel, and DAP (Delivered At Place), where the seller bears costs and risks until the goods arrive at destination. The chosen term also affects dutiable value, since some terms include freight and insurance in the price while others don’t.

Shipping Details and Reason for Export

List the total number of packages and the gross and net weight of the cargo. Customs checks these against the carrier’s manifest, and discrepancies can signal tampering or mispackaging.

State the reason for export: commercial sale, gift, return for repair, sample for testing, or whatever applies. Different transaction types qualify for different duty treatments. A sample with no commercial value, for example, may enter under a different tariff provision than a sale.

Wood Packaging

If the shipment uses wood pallets, crates, or dunnage, most importing countries require compliance with the ISPM 15 standard for heat treatment or fumigation. Compliant wood carries a standardized mark showing country code, facility ID, and treatment type.⁷ The mark itself appears stamped on the wood, but some destinations want a statement on the shipping documents confirming compliance. Non-compliant wood packaging can lead to the entire shipment being refused entry or fumigated at the importer’s expense.

Extra Requirements for Regulated Goods

A standard invoice covers the baseline. Certain merchandise needs more.

FDA-Regulated Products

Food, drugs, medical devices, cosmetics, and tobacco products fall under FDA jurisdiction. Entry documentation must include the applicable FDA product code, and you may need the FDA Establishment Identifier (FEI) number for the manufacturer or shipper, along with affirmation-of-compliance information such as facility registration numbers.⁸ The specifics vary by product type; check FDA’s Supplemental Guide for your commodity.

Chemicals Under TSCA

If you’re importing chemical substances in bulk or as part of a mixture, the Toxic Substances Control Act requires a written certification on the commercial invoice or an attachment to it. The statement must certify that all chemical substances in the shipment comply with TSCA and its applicable rules. If the chemicals are exempt (such as pesticides regulated under a different statute), a separate certification stating that they are not subject to TSCA is required instead.⁹ Certifications must be typed or stamped directly on the invoice or on an attachment.

Commodity-Specific Fields

19 CFR 141.89 lists dozens of product categories that require additional invoice information beyond the standard fields. Common examples:¹⁰

Chemicals in HTSUS Chapters 27–29: intended use and Chemical Abstracts Service (CAS) number.
Textile articles: whether coated or laminated with plastics or rubber, and on which surface.
Aluminum and aluminum alloys: percentage by weight of each metallic element.
Ball or roller bearings: bearing type, outside diameter, and whether it is radial.

The list is extensive. For metals, chemicals, textiles, and machinery components, check the regulation for your specific HTSUS classification before completing the invoice.

Language

The invoice and all attachments must be in English or must include an accurate English translation with enough detail for customs officers to examine the merchandise and determine duties.¹ If a supplier provides an invoice in another language, attach a full translation, not a partial summary.

The $800 De Minimis Exemption No Longer Applies

Section 321 of the Tariff Act historically allowed shipments valued at $800 or less to enter the United States duty-free with simplified documentation.¹¹ That exemption has been effectively eliminated. A February 2026 executive order suspended duty-free de minimis treatment for shipments from all countries, meaning commercial shipments now require formal entry with applicable duties, taxes, and fees regardless of value.¹² Products from China and Hong Kong lost de minimis eligibility earlier, in May 2025.¹³ If you’re shipping low-value goods, don’t assume the old exemption still applies. A complete commercial invoice with proper HS classification and formal entry through the Automated Commercial Environment is now required.

Submitting the Invoice

Standard practice calls for three copies of the completed invoice: one for the customs authority at the port of entry, one for the carrier’s records, and one for the consignee. CBP will accept a copy in place of the original, though a non-photographic copy must include a declaration from the seller, shipper, or importer that it is a true copy.¹⁴

Attach the physical copies in a clear, waterproof adhesive pouch on the outside of the primary shipping container. Customs agents need to access the documents without opening the package.

Most major carriers offer electronic submission through portals that feed invoice data directly into the Automated Commercial Environment. The Automated Broker Interface accepts electronic signatures in place of ink signatures, treating the digital certification as the legal equivalent.¹⁵ Electronic submission often speeds up pre-clearance, but keeping physical copies on the shipment is a smart backup against system outages at the destination port.

Keep the Records for Five Years

Your obligations don’t end when the shipment clears. Federal regulations require importers and exporters to retain commercial invoices and related entry records for five years from the date of entry.¹⁶ CBP can request them during a compliance audit at any point in that window.

Failure to produce records due to negligence carries a penalty up to $10,000 per release of merchandise, or 40 percent of the appraised value, whichever is less. Willful failure pushes the ceiling to $100,000 per release or 75 percent of the appraised value.¹⁷ Store invoices, entry summaries, and supporting documents in a system that lets you retrieve them quickly.

1
eCFR. 19 CFR 141.86 – Contents of Invoices and General Requirements
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Office of the Law Revision Counsel. 19 USC 1592 – Penalties for Fraud, Gross Negligence, and Negligence
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Taxation and Customs Union. Economic Operators Registration and Identification Number (EORI)
4
World Customs Organization. What Is the Harmonized System (HS)?
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International Trade Administration. Harmonized System (HS) Codes
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ICC – International Chamber of Commerce. Incoterms Rules
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Animal and Plant Health Inspection Service. Export ISPM 15-Compliant Wood Packaging Material From the United States to Another Country
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U.S. Food and Drug Administration. Entry Submission
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eCFR. 19 CFR 12.121 – Reporting Requirements
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eCFR. 19 CFR 141.89 – Additional Information for Certain Classes of Merchandise
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U.S. Customs and Border Protection. Section 321 Programs
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The White House. Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries
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Federal Register. Notice of Implementation of Additional Duties on Products of the Peoples Republic of China
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eCFR. 19 CFR Part 141 Subpart F – Invoices
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eCFR. 19 CFR 143.32 – Definitions
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eCFR. 19 CFR Part 163 – Recordkeeping
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eCFR. 19 CFR 163.6 – Production and Examination of Entry and Other Records and Witnesses; Penalties