Commercial invoice for import: mandatory details for customs

The commercial invoice is the document issued by the seller, the Chinese factory or trading company, in the buyer's name, once the sale is concluded and the goods have shipped. Unlike the proforma, it records an actual transaction: it carries final quantities and prices, not an estimate.

On arrival in the European Union, this is the document that the declarant, the importer itself or its freight forwarder, attaches to the customs declaration filed on the Single Administrative Document (SAD). Customs authorities use it to check the nature of the goods, their declared origin and, above all, the value on which import duties and VAT are calculated.

Beyond the general details required on any invoice by VAT rules (full identity of the seller and the buyer, invoice number and date, description of the transaction), an invoice meant for customs clearance in the European Union must carry additional elements specific to international trade. A vague product description, the type of generic wording copied from the supplier's catalogue, is one of the leading causes of a customs hold.

The invoice must stay consistent with the other shipping documents, in particular the packing list and the bill of lading or air waybill: a discrepancy in quantity or value between these documents is enough to trigger an inspection.

Customs value is one of the three pillars of import taxation, alongside tariff classification and origin. The reference method, known as transaction value, starts from the price actually paid or payable for the goods sold for export to the European Union, as shown on the commercial invoice. Article 70 of the Union Customs Code (Regulation (EU) 952/2013) sets out this principle.

This price is not always enough to reach the final customs value. Article 71 requires adding certain elements if they are not already included in the invoiced price: selling commissions, packing, transport and insurance up to the place of introduction into the Union, loading and handling, royalties linked to the goods. Article 72 conversely allows deducting certain charges incurred after import, such as inland transport or assembly carried out once the goods have arrived.

The incoterm chosen directly determines what must be added. Under EXW, the buyer bears transport from the factory onward: the entire freight and insurance cost up to the Union border is added to the invoiced price to reach the customs value. Under FOB, only the main sea or air transport and its related insurance are added. Under DDP, the invoiced price already includes transport to destination: most of the adjustment work disappears, but the importer must then check that the seller has correctly isolated the portion of transport occurring after entry into the Union, which can be deducted.

The proforma invoice is a preparatory document, sent before the sale, which looks like an invoice but does not legally commit the buyer to payment: it serves to formalise an offer, to obtain internal approval or a bank guarantee, or to prepare an import licence application. It can still be changed up to the point of firm order.

The commercial invoice, on the other hand, is issued once the goods have shipped: it records what was actually sold and serves as an accounting and customs record. Using a proforma as the sole supporting document at the time of customs clearance risks refusal or delay, since the proforma does not carry the evidentiary value of a final invoice.

A third case applies to shipments with no commercial transaction, free samples, returns for repair, loaned equipment: the appropriate document is neither a commercial invoice nor a proforma, but a document stating the absence of payment and the value used for customs purposes only. Confusing it with a proforma is a frequent source of a customs hold.

The commercial invoice and the packing list serve two different purposes and never substitute for one another. The invoice carries the values: unit price, total value, currency, payment terms. The packing list carries the physical content of the shipment: number of packages, net and gross weight, dimensions, breakdown of items per carton.

The two documents must remain strictly consistent, same items, same total quantities. A discrepancy between the invoiced quantity and the quantity listed in the packages is one of the most frequent causes of a physical inspection of the goods.

Certain mistakes recur regularly in import files from China, often because the invoice is drafted by the factory without knowledge of European customs practice. Correcting them before shipment costs a few email exchanges; correcting them after the container arrives costs days of demurrage and storage fees.

Under-invoicing consists of declaring a value lower than the price actually paid, to reduce customs duties and import VAT. It is fraud under the Union Customs Code: the declared value must always match the price actually paid, including elements to be added, whichever invoice is presented at clearance.

An imprecise description of the content or a proforma wrongly presented as the final value document can, in practice, lead to such an undervaluation, whether intentional or not. These practices expose the importer, even acting in good faith, to a reassessment of the evaded duties, to fines and, in the most serious cases, to seizure of the goods.

Sorva is a brokerage and trading house between Europe and China, with a Chinese-speaking team based in Guangzhou and a team in Paris. When we buy the goods on your behalf and resell them delivered, we prepare invoicing consistent with the incoterm used and the documentation expected by European customs: precise description, tariff code, origin, value aligned with the packing list.

Before committing to an order, our team can review the invoice or proforma sent by a factory and flag missing or ambiguous details before they turn into a hold on arrival. For a broader project, from supplier selection through to delivery to you, the plan that covers the whole file includes this document review ahead of each shipment.