US Customs Invoice Requirements: The 11 Fields CBP Demands

You ship goods to the United States. Your commercial invoice lists the price, quantity, and description. Everything looks right. Then CBP sends a notice. The declared value is wrong. You owe more duty than expected.

The problem is not your price. It is what you left off the invoice. U.S. customs law requires 11 specific fields on every commercial invoice entering the country. This guide walks through each one, explains the field most exporters miss, and shows what happens when your invoice falls short.

What does U.S. customs require on a commercial invoice?

U.S. Customs and Border Protection (CBP) requires every commercial invoice to contain 11 specific data fields. These requirements are set out in 19 CFR 141.86, which is the federal regulation governing invoice contents for imported merchandise. The invoice must be in English, or include an accurate English translation.

CBP uses the commercial invoice to determine three things: what the goods are, what they are worth, and how much duty is owed. If any required field is missing, CBP may delay the shipment, request additional documentation, or reassess the declared value.

There is no required format. CBP does not mandate a specific template. But the regulation is clear about what information must appear. If it is not on the invoice, it must be on an attachment filed with the invoice.

What are the 11 required fields under 19 CFR 141.86?

Each commercial invoice for goods imported into the United States must include the following 11 fields. These are listed in 19 CFR 141.86(a)(1) through (a)(11). Missing any one of them can trigger a customs review.

• Port of entry — The U.S. port where the goods will arrive.

• Sale details — When and where the sale happened, and who the buyer and seller are. If the goods are not purchased, state who shipped them and to whom.

• Detailed description — The name, grade, quality, marks, and numbers of each item, plus the marks and numbers on the packages.

• Quantities — Weights and measures, either in the units of the exporting country or in U.S. units.

• Purchase price — The price of each item, stated in the currency of the purchase.

• Value (if not a purchase) — If the goods are not sold, the value the manufacturer or seller would have received in the ordinary course of trade.

• Currency type — Whether payment is in gold, silver, or paper currency.

• All charges — Freight, insurance, commission, packing, containers, and all costs to bring the goods from the export port to the first U.S. port of entry. These must be itemized by name and amount.

• Rebates, drawbacks, and bounties — Any export incentives, listed separately.

• Country of origin — Where the goods were manufactured, not where they were shipped from.

• Assists — All goods or services the buyer provided for the production of the merchandise that are not included in the invoice price. Examples include dies, molds, tools, and engineering work.

In addition to these 11 fields, 19 CFR 141.86(j) requires the invoice to include the name of a responsible employee of the exporter who has knowledge of the transaction. This is a separate requirement but equally mandatory.

Why do most exporters miss "assists" on their invoice?

Of the 11 required fields, "assists" is the one most likely to be missing. Most exporters handle the first 10 fields without issue. Assists are different because they involve something the buyer — not the seller — provided.

Under 19 CFR 152.102(a)(1), an "assist" is defined as any of the following, if supplied by the buyer directly or indirectly, free of charge or at reduced cost, for use in connection with the production of the imported goods:

• Materials, components, or parts incorporated in the merchandise

• Tools, dies, molds, and similar items used in production

• Merchandise consumed in production

• Engineering, development, artwork, design work, and plans or sketches done outside the United States

Here is a common scenario. A U.S. buyer orders custom parts from a factory in Korea. The buyer pays $12,000 for an injection mold and ships it to the factory. The factory uses the mold to produce the parts and invoices the buyer at $50,000.

The invoice price is $50,000. But the customs value is $62,000. The $12,000 mold is an assist, and its value must be added to the transaction value for duty calculation. According to 19 CFR 152.103, CBP adds the value of assists to the price actually paid or payable.

The exporter often does not know the mold exists. The buyer purchased it separately. It never appears on the commercial invoice. But CBP still expects it to be declared under field 11 of 19 CFR 141.86.

If the assist is used across multiple shipments, the value can be apportioned. According to 19 CFR 152.103(e), the importer may spread the mold cost over the first shipment, all units produced to date, or the entire anticipated production run. The method must follow generally accepted accounting principles.

What happens if your commercial invoice is wrong?

Submitting a commercial invoice with false or incomplete information is a violation of 19 USC 1592. This is the primary penalty statute for customs violations in the United States. It applies regardless of whether the government lost any revenue.

Under 19 USC 1592, penalties are assessed at three levels of culpability:

• Negligence (failure to exercise reasonable care): maximum penalty is 2 times the unpaid duties, or if no duty loss, 20% of the dutiable value.

• Gross negligence (actual knowledge or wanton disregard): maximum penalty is 4 times the unpaid duties, or if no duty loss, 40% of the dutiable value.

• Fraud (voluntary and intentional): maximum penalty is the full domestic value of the merchandise.

CBP can audit past entries going back 5 years. If they find consistent errors across multiple shipments, the penalties compound. According to a customs law analysis by Nakachi Eckhardt & Jacobson, the government can recover duties and fees accrued over the full 5-year period, plus civil penalties calculated as a multiple of lost revenue.

There is one important exception. Under 19 USC 1592(a)(2), clerical errors or mistakes of fact are not violations unless they are part of a pattern of negligent conduct. A single typo will not trigger a penalty. But repeated errors on the same field across multiple entries can establish a pattern.

If you discover an error after filing, a prior disclosure under 19 USC 1592(c)(4) can significantly reduce penalties. When an importer voluntarily discloses a violation before CBP starts a formal investigation, the merchandise cannot be seized, and the penalty is capped at the amount of unpaid duties.

Do some products require extra invoice information?

Yes. Beyond the 11 standard fields, 19 CFR 141.89 lists additional invoice requirements for specific product categories. If your goods fall into one of these categories, the invoice must include extra details for CBP to classify and appraise the merchandise correctly.

Examples include:

• Aluminum and aluminum alloys — percentage by weight of each metallic element

• Textiles and apparel — fiber content, construction method, and whether the fabric is coated or laminated

• Footwear — material composition of the upper and sole, and the percentage of exterior covered by each material

• Paper products — weight in grams per square meter, thickness in micrometers, and sheet dimensions

These requirements exist because tariff classification for these products depends on technical specifications that a generic product description cannot capture. A commercial invoice that says "aluminum parts" is not enough. CBP needs the alloy composition to assign the correct HTS code and duty rate.

How do you make your commercial invoice CBP-compliant?

Before shipping to the United States, run through this checklist. Every item maps directly to a legal requirement under 19 CFR 141.86.

• U.S. port of entry is stated

• Buyer and seller names, addresses, and sale date are listed

• Each item has a detailed description with grade, quality, and shipping marks

• Quantities are stated in specific weights and measures

• Unit price is listed per item in the currency of the transaction

• Currency type is specified

• All charges are itemized: freight, insurance, commission, packing

• Any export rebates or drawbacks are listed separately

• Country of origin is stated (where manufactured, not where shipped from)

• Assists are declared: molds, tools, dies, engineering work provided by the buyer

• A responsible employee of the exporter is named on the invoice

• The invoice is in English or has an English translation attached

If your product falls under 19 CFR 141.89 (textiles, aluminum, footwear, paper, or other listed categories), add the required technical specifications.

If the buyer has provided any tooling, molds, or design files, ask them for the value. Declare it on the invoice or on an attached statement. This single step prevents the most common valuation dispute with CBP.

The commercial invoice is not just a sales document. For U.S. customs, it is the primary record used to assess duties, verify classification, and determine admissibility. Getting the 11 fields right is not optional. It is the law.