How to Fill Out and Submit a Customs Invoice Form

A customs commercial invoice is a document the seller or shipper prepares that tells U.S. Customs and Border Protection (CBP) what is in the shipment, who is sending it to whom, and what it is worth. To fill out a customs commercial invoice correctly, you need to cover the eleven categories of information listed in 19 CFR 141.86, describe the goods precisely enough for classification, and state a value CBP can use to calculate duty. The invoice is not a government form — you draft it yourself, and CBP will accept any format that contains everything the regulation requires.

The Information Every Invoice Must Contain

Under 19 CFR 141.86, a commercial invoice for imported merchandise has to set forth the following:

The U.S. port of entry where the goods will arrive.
The names of the buyer and seller, and the time and place of the sale. If the goods were not purchased (samples, gifts, warranty replacements), list the shipper, the recipient, and the place and date of shipment instead.
A detailed description of each item: the name it is known by in trade, its grade or quality, and any marks, numbers, or brand symbols used in the exporting country, along with the marks and numbers on the packages themselves.
Quantities, in the weights and measures of the exporting country or in U.S. units.
The purchase price of each item in the currency of the purchase. For goods that were not sold, use the price the seller would have accepted in an ordinary wholesale transaction in the exporting country.
The type of currency: gold, silver, or paper.
Itemized charges for freight, insurance, commissions, containers, packing, and any other expense of moving the goods from alongside the carrier at the foreign port to alongside the carrier at the first U.S. port of entry. If packing and inland freight are already built into the price, say so on the invoice.
Any rebates, drawbacks, or government bounties allowed on the merchandise when it was exported, listed separately.
The country of origin — where the product was manufactured or substantially transformed.
Any assists: goods or services such as dies, molds, tools, or engineering work furnished for the production of the merchandise that are not reflected in the invoice price. Assists furnished within the United States are excluded.

If the buyer and seller are related parties, the invoice must include a statement disclosing the relationship and its nature.¹ CBP scrutinizes related-party transactions more closely to check that the declared value has not been artificially lowered.

Describing the Goods Precisely

Vague descriptions are one of the fastest ways to get a shipment flagged. “Clothing” will not do; “100% cotton men’s t-shirts, crew neck, size medium” will. The regulation asks for the trade name, grade or quality, and identifying marks because CBP uses that description to apply the correct tariff classification.

Classification is set by the Harmonized Tariff Schedule of the United States (HTSUS), which assigns a six-to-ten-digit code and a duty rate to every product category. CBP has the final word on classification, but listing the HTSUS code you believe applies speeds review and narrows disputes. The U.S. International Trade Commission publishes a free search tool at hts.usitc.gov.²

Country of origin ties directly to the duty rate. Goods from free trade agreement partners may qualify for reduced or zero duty; goods from countries subject to antidumping or countervailing duty orders may owe more. If your product was assembled in one country using components from another, the origin you list is the country where it was substantially transformed into a new article of commerce.

Stating the Value Correctly

The declared value drives the duty calculation, so accuracy is not negotiable. For purchased goods, the value is the price actually paid or payable — the amount the U.S. buyer paid the foreign seller, not the price the goods will eventually sell for in the U.S. market.³ State it in the currency of the purchase.

Several costs that may not feel like part of “the price” still have to appear on the invoice:

Selling commissions, assists, and royalties. Payments for production tools, molds, engineering work, or license fees that the buyer supplied to the seller but that are not in the unit price must be reported. Leaving them off is treated as undervaluation.¹
Shipping charges. Itemize freight, insurance, packing, and every other cost of moving the goods from the foreign port of export to the first U.S. port of entry.
Rebates and drawbacks. If the exporting country’s government refunded any taxes or duties when the goods left, list the amounts separately.

If the goods were not sold, you still need a value. Use the price the seller would have accepted for the same goods in an ordinary wholesale transaction in the exporting country.¹

Discounts

Unconditional discounts already reflected on the invoice at the time of entry — volume pricing, trade discounts, market-grade discounts — can be deducted from the declared value. Conditional discounts work the same way if the condition was satisfied before the goods entered the country. Rebates or credits applied after entry are not deducted from the declared value.⁴

Currency

The invoice states the purchase price in its original currency and identifies whether the currency is gold, silver, or paper. Foreign-currency amounts must be converted to U.S. dollars on the entry documents.³ If you provide no value at all, CBP will assess one, and that assessed value is unlikely to favor you.

Do You Have to Sign It

No. A CBP ruling directly addressed this and found that 19 CFR 141.86 contains no signature requirement for a commercial invoice.⁵ A signature is only required on a pro forma invoice. Many carriers and foreign customs authorities do expect one, though, so signing is harmless and often smooths things at the other end of the shipment.

When the Commercial Invoice Isn’t Ready

Sometimes the seller’s commercial invoice does not arrive before the goods do. In that case, the importer can file entry using a pro forma invoice, a substitute document supplying the best available information about the shipment’s value, description, and origin. The pro forma invoice follows a format set out in 19 CFR 141.85 and requires the importer’s signature certifying that the values are accurate to the best of their knowledge.⁶ You must state the basis for the pricing: the agreed purchase price, correspondence with the exporter, comparable past shipments, or market knowledge. Once the real commercial invoice arrives, submit it to CBP promptly.

Submitting the Invoice

The importer of record — the party legally responsible for clearing the goods — files entry documentation with CBP, and the commercial invoice is a core part of that filing.⁷ Most commercial shipments today go through CBP’s Automated Commercial Environment (ACE) system electronically, with the invoice data transmitted before or at the time the goods arrive.

For formal entries, generally shipments valued at $2,500 or more, CBP itself suggests working with a licensed customs broker.⁸ Brokers handle classification, duty calculation, and ACE filing on the importer’s behalf. Informal entry for lower-value shipments is simpler and individual importers often handle it themselves.

Shipments with a fair retail value of $800 or less generally qualify for duty-free entry under the de minimis threshold in 19 U.S.C. 1321.⁹ Even for these, carriers usually still want a commercial invoice for their records and for any customs inquiries.

Shipping Terms and Who Owes the Duty

The invoice should state the agreed shipping terms, because those terms determine who bears import duties and clearance costs. Under Delivered Duty Paid (DDP), the seller covers all costs through delivery, including duties and taxes. Under Delivered at Place (DAP), the seller delivers to an agreed destination but the buyer is responsible for import clearance, duties, and taxes. Under Free on Board (FOB) and similar terms, responsibility shifts to the buyer even earlier.

Getting this right on the invoice matters because it affects who CBP holds responsible for shortfalls or penalties. If the invoice says DDP but the seller never actually pays the duties, the importer of record is still liable. CBP does not chase foreign sellers.

What Happens if the Invoice Is Wrong

Federal law makes it illegal to enter or attempt to enter goods using documents with material false statements or omissions. Under 19 U.S.C. 1592, penalties scale with the level of culpability: negligence, gross negligence, and fraud each carry progressively higher civil penalties, with fraud reaching up to the full domestic value of the merchandise. Voluntarily disclosing an error before CBP begins a formal investigation can substantially reduce penalty exposure and protects the goods from seizure.¹⁰ The most common invoice mistakes that draw enforcement are undervaluing goods, omitting assists or royalties, and misidentifying the country of origin.

If CBP finds your invoice insufficient for classification or valuation but not necessarily wrong, it will send a CBP Form 28, a Request for Information, identifying what additional documentation or clarification it needs. That could be a breakdown of component costs, laboratory analysis of materials, or supporting contracts.¹¹ Responding is technically voluntary but ignoring it means the agency may either hold the goods (with storage charges accruing) or classify and value them however it sees fit.

Keeping the Records

Once the goods clear, the invoice still matters. Federal regulations require importers to retain all entry records — including the commercial invoice, purchase orders, and correspondence with CBP — for five years from the date of entry.¹² CBP can request them for audit at any point in that window, and failing to produce them carries its own penalties. Digital copies organized by entry number and date will save trouble later.

1
eCFR. 19 CFR 141.86 – Contents of Invoices and General Requirements
2
U.S. International Trade Commission. Harmonized Tariff Schedule
3
U.S. Customs and Border Protection. What Value Should Be on the Commercial Invoice Submitted to U.S. Customs and Border Protection?
4
U.S. Customs and Border Protection. Request for Internal Advice Concerning Printing Paper – Discounts
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Customs and Border Protection. Customs Ruling HQ 224858
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eCFR. 19 CFR 141.85 – Pro Forma Invoice
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Office of the Law Revision Counsel. 19 U.S.C. 1484 – Entry of Merchandise
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U.S. Customs and Border Protection. Filing a Formal Entry
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Office of the Law Revision Counsel. 19 U.S.C. 1321 – Administrative Exemptions
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Office of the Law Revision Counsel. 19 U.S.C. 1592 – Penalties for Fraud, Gross Negligence, and Negligence
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U.S. Customs and Border Protection. CBP Form 28 – Request for Information
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eCFR. 19 CFR 163.4 – Record Retention Period