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Article··13 min read·Portmind Team

Commercial Invoice Requirements for Customs: A Checklist

There's no official form for a commercial invoice in most countries, but customs expects it to carry specific information. This checklist covers what almost every authority asks for, then what the EU, Switzerland, the UK and the US each add, with the rule behind every item.

Last reviewed: November 4, 2026 • Audience: exporters, importers, and the customs and trade operations teams who prepare or check commercial invoices

The commercial invoice is the document customs relies on for the value of the goods, and in most countries there's no official form for it. What the rules set is the information it has to contain, and the four jurisdictions on this page differ more in the details than in the core. The core comes first, then what the EU, Switzerland, the UK and the US each add, with a link to the rule or official guidance behind each item. It's a practical summary, so on a specific shipment the customs authority or your broker has the final word.

The core checklist

These are the items that almost every customs authority expects to find. Some of them can sit on the packing list instead, but if the invoice is the only document the broker sees before filing, it's safer to have them on the invoice.

  1. Seller or exporter, with name and address, plus the registration number the countries involved use, such as an EORI or VAT number in Europe.
  2. Buyer, and the consignee if the goods go to someone else, with names and addresses.
  3. Invoice number and date.
  4. A description of each item precise enough to classify it: what it is, what it's made of, and its model or part number. "Spare parts" or "samples" on their own aren't enough.
  5. The HS code of each item. The first six digits are the same everywhere, and the importing country adds its own, such as eight digits in the EU and ten in the US.
  6. The country of origin of each item, which can differ from the country the goods ship from.
  7. The quantity of each item, with its unit of measure.
  8. The unit price and line total of each item, and the invoice total.
  9. The currency.
  10. The Incoterm, written the way the ICC asks: the rule, the named place and the edition, for example "FCA Basel, Switzerland, Incoterms® 2020" (ICC).
  11. Charges that aren't in the price, such as freight, insurance, packing and commissions, shown separately.
  12. Packages and weights: the number and kind of packages, their marks and numbers, and net and gross weight.
  13. For goods that aren't sold, such as samples, repairs or returns, the reason for the shipment and a value for customs.
  14. Any origin statement the buyer needs to claim a lower duty rate (see origin statements).

European Union

The EU has no prescribed invoice form. The invoice is a supporting document for the customs declaration, and it's compulsory whenever the goods are declared at their transaction value: the implementing regulation says the invoice relating to the declared transaction value "is required as a supporting document" (Regulation 2015/2447, Art. 145), and supporting documents have to be in the declarant's possession and at the disposal of customs when the declaration is lodged (Union Customs Code, Art. 163).

What makes the invoice matter is valuation. The transaction value is the price actually paid or payable (UCC, Art. 70), and the cost of transport and insurance, plus loading and handling charges, up to the place where the goods enter the EU are added to it (UCC, Art. 71). An invoice that shows freight and insurance separately, with the Incoterm and its named place, lets the broker work out the customs value without having to ask.

In the declaration itself, the invoice is referenced by a document code, which in Germany's ATLAS system is N380 for a commercial invoice (Zoll, ATLAS import guide). German customs offices may also waive the separate value declaration (form D.V.1) when the customs value doesn't exceed EUR 20,000 per consignment, except for split or multiple consignments (Zoll).

The EU has also accepted a 1979 Customs Co-operation Council recommendation on commercial invoices, which asks customs administrations to refrain from requiring a signature on invoices presented in support of a goods declaration (Council Decision 82/457/EEC).

Switzerland

In Switzerland the declarant has to hand in accompanying documents with the customs declaration, and the commercial invoice is one of them. The declarant also has to mark each document so it can be clearly assigned to its declaration, which is one reason the invoice number and date matter. The federal portal for SMEs says the accompanying documents have to show, in particular, the value, weight, origin and tariff number of the goods (KMU portal).

The most complete checklist is a 2025 working paper from the University of St. Gallen's Institute for Law and Economics, which brings together the requirements from the customs, VAT, trade statistics and origin legislation (ILE-HSG Working Paper 2025-24). Besides the core items, it asks for:

  • the Swiss buyer's UID number, which it treats as necessary on the invoice under the VAT Act;
  • the Incoterm with the precise place of delivery and the edition, such as Incoterms® 2020;
  • both gross and net weight;
  • the date of supply, if it differs from the invoice date;
  • for toll manufacturing, the manufacturing fee and the quantity and value of the free-of-charge materials consumed, because declaring only one of the two gives too low a customs value.

The paper itself notes that the legislation and the practice of the authorities prevail over it.

Switzerland abolished customs duties on industrial goods, chapters 25 to 97 of the tariff with a few exceptions in chapters 35 and 38, on 1 January 2024 (BAZG). Origin no longer changes the duty on most manufactured goods coming in, but it still matters for agricultural products, which keep their duties, and for Swiss exporters, whose customers abroad need an origin statement to claim preference.

United Kingdom

The UK government's export guidance lists what an export invoice should include: the invoice number and date, the seller, the buyer and the final recipient, references to related paperwork, the unit price, currency, discounts and payment method, the weight and number of goods, the commodity code with a plain-English description, the Incoterm, the package marks and numbers, the country of origin, transport details, the value and any additional charges. It adds that some destinations want a version in another language, or an invoice certified by a chamber of commerce or embassy (business.gov.uk).

On an import declaration in CDS, the invoice the customs value is based on is declared under document code N935 whenever the transaction value method is used (HMRC). For goods traded with the EU, preference under the Trade and Cooperation Agreement is claimed with a statement on origin, which the exporter adds to the invoice or any other document that describes the goods. An EU exporter needs a REX number for consignments worth more than EUR 6,000, and a UK exporter quotes their EORI number (GOV.UK).

United States

The US sets out the contents of the invoice in a single regulation. A commercial invoice has to be filed for each shipment that isn't in one of the exempt categories (19 CFR 141.83(c)(1)), and under 19 CFR 141.86(a) it has to show:

  1. The port of entry the goods are destined for.
  2. When, where, by whom and to whom the goods were sold, or for goods that weren't sold, when and where they were shipped and by whom and to whom.
  3. A detailed description of each item, with the name it's known by, its grade or quality, the marks, numbers and symbols it's sold under, and the marks and numbers of the packages.
  4. The quantities, in the weights and measures of the country of shipment or of the US.
  5. The purchase price of each item, in the currency of the sale.
  6. For goods not sold, the value of each item.
  7. The kind of currency.
  8. All charges on the goods, itemized by name and amount, including freight, insurance, commission, containers and packing.
  9. Any rebates, drawbacks and bounties allowed on export.
  10. The country of origin.
  11. Goods or services supplied for producing the goods and not included in the price, known as assists, such as dies, molds, tools or engineering work.

The same section has a few more requirements that catch people out. The invoice and all its attachments have to be in English or come with an accurate English translation (141.86(d)). The invoice has to state in adequate detail what each individual package contains (141.86(e)), which is where it overlaps with the packing list. It has to name a responsible employee of the exporter who knows, or can readily find out, about the transaction (141.86(j)). And when an entry has more than one invoice or runs past two pages, the importer numbers the invoices and pages in sequence, unless the invoice data is sent electronically (141.86(h)). Nothing in the section requires the invoice to be signed.

Low-value shipments get more scrutiny than they used to. The US suspended the de minimis exemption for shipments from every country from 29 August 2025 (Executive Order 14324), and an order in February 2026 kept the suspension in place (Executive Order 14388), so shipments that used to clear duty-free under it are now assessed for duty like any other import.

Origin statements on the invoice

To get a lower duty rate under a free trade agreement, the importer usually needs a statement from the exporter that the goods originate in the partner country, and in most European agreements that statement goes on the invoice or another commercial document. The wording is set by each agreement and has to be copied exactly as it's written there.

  • EU agreements that use the REX system, including those with Japan and the UK, and with Canada, where the statement is called an origin declaration: any exporter can make out the statement for a consignment of originating goods worth up to EUR 6,000, and above that the exporter has to be registered in REX and quote their number (European Commission).
  • The Pan-Euro-Mediterranean convention, under the revised rules in force from 1 January 2025: any exporter can make out an origin declaration for a consignment worth up to EUR 6,000, and an approved exporter can make one out for any value (Decision No 1/2023 of the PEM Joint Committee). Whether the revised rules apply between two particular countries depends on their agreement and its transition period, so check before using the new wording.
  • Switzerland: an origin declaration on the invoice can be made out without approved-exporter status for consignments whose originating goods are worth up to CHF 10,300 or EUR 6,000. The exceptions are the agreement with the Gulf states, which doesn't allow it, and the agreements with Japan and China, where only approved exporters can make one out (BAZG).

If the goods don't qualify, or the buyer isn't claiming preference, leave the statement off, because a statement on goods that don't originate can lead to a duty claim against the importer later.

Invoices under a letter of credit

When the invoice is presented to a bank under a letter of credit, the bank checks it against UCP 600 as well as the credit. Article 18(a) says the invoice must appear to have been issued by the beneficiary, must be made out in the name of the applicant and in the same currency as the credit, and need not be signed, and article 18(c) says the description of the goods must correspond with the one in the credit (ICC). We've gone through the rest in which clauses to check on a letter of credit and MT700 fields explained.

Common myths

"The invoice has to be signed." The EU has accepted a recommendation that customs shouldn't ask for a signature on commercial invoices, US regulations don't require one, the UK government's list of invoice contents doesn't mention one, and UCP 600 says an invoice under a letter of credit need not be signed. Some countries, some trade agreements and some carriers do ask for a signed declaration or a certified invoice, so check the destination before leaving the signature off.

"It has to be in English." That's the US rule. Elsewhere it depends on the country. In Germany, for example, the authorities can ask for a translation of documents in a foreign language (Fiscal Code, § 87). Ask your broker which languages customs accepts at the destination.

"The courier's rules are the customs rules." Couriers and carriers often ask for a set number of copies or their own invoice format, which is what they need to handle the shipment, and customs in the destination country may ask for something different.

"A proforma invoice will do." A proforma invoice is normally used for goods that aren't sold, such as free samples, or before a sale is final. In the US it can stand in for a missing commercial invoice at entry only in limited cases, with a bond and the commercial invoice produced within 120 days (19 CFR 141.91). Either way it still has to carry a value for customs.

Checking invoices at volume

The checklist covers what each invoice needs on its own. Most of the problems teams see in practice come from invoices that are complete but disagree with the packing list or the transport document, which we've covered in commercial invoice vs packing list: what to check.

Sail, Portmind's trade document validation product, checks every invoice that comes in from your suppliers before the data reaches your customs software or ERP. It confirms the fields your team needs are there, such as the currency, total value, Incoterm, origin and a business registration number, recalculates line amounts and totals, and compares the invoice with the packing list and transport documents, holding the shipment when a hard-stop check fails.

Templates

The commercial invoice and packing list generator has fields for most of the core checklist, including the parties, HS codes, origin, the Incoterm with its named place, shipping marks, packages and weights, and it makes a matching packing list from the same form. There are Excel and Word templates on the same page. For a US import, add any freight, insurance, assists and rebates in the notes, since the generator doesn't have separate fields for them, and put the responsible employee's name in the signature block.

Sources

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