Commercial invoice requirements for US customs (19 CFR 141.86)
Commercial invoice requirements for US customs under 19 CFR 141.86: the eleven required elements, English, currency, itemized charges, origin and assists.
Documents needed to import from China to the USA on a first order: commercial invoice, packing list, bill of lading, ISF, bond, importer number and entry.
To clear a first production run from China through US Customs and Border Protection (CBP) you need, at minimum: a commercial invoice, a packing list, the bill of lading or air waybill, a correct HTS classification, an importer number, a customs bond, and an entry plus entry summary (CBP Form 7501). Ocean shipments also need an Importer Security Filing (ISF 10+2) before the container is loaded in China. Some products need partner agency paperwork on top (FDA, FCC, CPSC, or a Lacey Act declaration).
You and your supplier produce the first group. A licensed customs broker normally files the second group in CBP's ACE system on your behalf. The legal responsibility for all of it stays with you as importer of record.
| Document | Who prepares it | When | What CBP uses it for |
|---|---|---|---|
| Purchase order and pro forma invoice | You and the factory | Before production | Fixes price, terms and product spec; not filed with CBP but supports the entry |
| Commercial invoice | Factory (you check it) | Before shipping | Value, classification, origin (19 CFR 141.86) |
| Packing list | Factory | Before shipping | Contents of each carton, examination (19 CFR 141.86(e)) |
| HTS classification and duty estimate | You, with your broker | Before the factory ships | Duty rate, Chapter 99 tariffs, ISF element |
| ISF 10+2 (ocean only) | You or your agent (broker or forwarder) | At least 24 hours before loading at the Chinese port | Cargo security screening (19 CFR 149.2) |
| Bill of lading or air waybill | Carrier or forwarder | At loading | Evidence of the right to make entry (19 CFR 141.11) |
| Importer number (CBP Form 5106) | You, usually via the broker | Before the first entry | Identifies the importer of record in ACE |
| Customs bond (CBP Form 301) | Surety, arranged by the broker | Before the entry | Guarantees duties, taxes and compliance (19 CFR 142.4) |
| Power of attorney | You, to the broker | Before the broker files anything | Lets the broker act for you (19 CFR 141.46) |
| Entry (CBP Form 3461 data) | Broker | Before or at arrival | Release of the cargo (19 CFR 142.3) |
| Entry summary (CBP Form 7501) | Broker | Within 10 working days after entry | Duties, fees, statistics (19 CFR 142.12) |
| Partner agency filings | You, filed by the broker | With the entry | FDA, CPSC, FCC, Lacey Act, as applicable |
| Arrival notice and delivery order | Carrier or forwarder | At arrival | Pickup at the port or airport |
| FBA shipment plan and labels | You, in Seller Central | Before delivery | Amazon receiving; not a CBP document |
19 CFR 141.86 lists what every invoice of imported merchandise must show: the port of entry, the parties and the date and place of sale, a detailed description of each item, quantities, the purchase price per item in the currency of the purchase, all charges itemized (freight, insurance, packing, commissions), the country of origin, and any tooling or molds you paid for that are not in the price. The invoice must be in English or carry an English translation, and it must name a responsible employee of the exporter. Most factory invoices miss two or three of these points. The full field list, with the common rejections, is in Commercial invoice requirements for US customs.
The regulation folds the packing list into the invoice rules: "Each invoice must state in adequate detail what merchandise is contained in each individual package" (19 CFR 141.86(e)). In practice the factory issues a separate packing list with carton numbers, units per carton, net and gross weight, and carton dimensions. Match it to the invoice line by line before the goods leave. CBP examiners and Amazon receiving both work from it.
The carrier issues the bill of lading (ocean) or air waybill (air) when the cargo is loaded. Under 19 CFR 141.11 it is the evidence of your right to make entry. Check that the consignee and notify party are correct. For FBA, the consignee is you (or your broker or forwarder as your agent), not Amazon. Amazon may appear as the delivery address only when marked "in care of" Amazon.
Every line on the entry needs a 10-digit Harmonized Tariff Schedule number. You, not the factory, are responsible for it, and 19 CFR 141.90 requires the importer or broker to note the HTS subheading and duty rate on the invoice data. The number drives the base duty rate and decides which Chapter 99 tariffs (Section 301 lists, the Section 301 forced-labor duty in force since 24 July 2026, Section 232 metal and timber measures) stack on top. Work it out before the factory ships, not at the port: How to find the HTS code for my product.
Not a document, but a check that fails often. 19 CFR 134.11 requires every article of foreign origin, or its container, to be marked "in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit" with the English name of the country of origin. "Made in China" on a removable sticker over a "Made in PRC" mold mark is a frequent examination finding.
CBP releases goods only after the relevant agency has cleared them. At a high level, for the products first-time sellers usually pick:
Ask the factory for test reports and certificates before you pay the balance. A missing certificate at the port means storage charges while you chase it.
CBP identifies the importer of record by an IRS Employer Identification Number, a Social Security Number for a sole proprietor, or a CBP-assigned number. The Create/Update Importer Identity Form (CBP Form 5106) registers that number in ACE. Brokers submit it electronically; CBP says activating a new importer typically takes two business days. File it before the ISF, because the ISF itself needs your importer number.
A formal entry cannot be released without a single transaction or continuous bond on CBP Form 301 (19 CFR 142.4). The bond is sold by a surety, almost always through your broker. Which type to buy, and how CBP sets the amount, is covered in Customs bond, ISF 10+2 and hiring a broker.
For vessel cargo, the ISF importer (the goods' owner, purchaser, consignee or an agent such as a licensed broker) must transmit ten data elements, eight of them no later than 24 hours before the cargo is laden aboard the vessel at the foreign port (19 CFR 149.2). CBP's bond conditions provide for liquidated damages of $5,000 per violation for late, inaccurate or missing filings. The factory or forwarder gives you the container stuffing location and consolidator details; you give the filer everything else.
The entry (CBP Form 3461 data) secures release of the goods. 19 CFR 142.3 lists what goes with it: evidence of the right to make entry, the commercial invoice, a packing list where appropriate, other documents required by CBP or other agencies, and the importer's name, address and identification number. The entry summary (CBP Form 7501) follows within 10 working days after entry, with estimated duties (19 CFR 142.12(b)). Both are transmitted through ACE by the broker, who also pays the duties, merchandise processing fee and harbor maintenance fee and bills you, or sets you up to pay CBP directly by ACH.
Shipments valued at $2,500 or less may use informal entry (19 CFR 143.21), which carries a small fixed processing fee. Two catches matter for goods from China. First, 143.21(a) excludes from informal entry any article worth more than $250 that is classified in Chapter 99, Subchapter III of the tariff schedule, which is where the Section 301 headings sit. Second, CBP may require a formal entry for any shipment (19 CFR 143.22). Plan on a formal entry for any real production run.
Amazon's staff guidance for sellers is explicit: "Amazon will not act as the IOR for your FBA inventory, regardless of the shipment size or value." The importer of record must be you or a party you appoint, and the IOR is the one CBP holds liable. Amazon will not pay duties, so a shipment arriving with duties owed will be refused. If your forwarder offers "DDP to Amazon," ask who is named as importer of record on the CBP Form 7501 and whose bond is used. If it is not your company, the entry record and any later duty refund belong to them.
For a Shopify seller shipping to a 3PL or your own garage, nothing changes on the CBP side; only the ship-to party and delivery address differ.
Duty-free de minimis entry for shipments valued at $800 or less ended for products of China and Hong Kong on 2 May 2025 and for all countries on 29 August 2025 (Executive Order 14324). After the Supreme Court struck down the IEEPA tariffs in February 2026, the suspension was continued by Executive Order 14388 of 20 February 2026, and CBP's interim final rule of 24 June 2026 now suspends the exemption in the regulations themselves. The One Big Beautiful Bill Act repeals the statutory exemption on 1 July 2027. Samples, small air parcels and split test orders from China all need an entry and pay the applicable duties and fees.
19 CFR 163.4 requires records relating to an entry to be kept for 5 years from the date of entry. Keep, per shipment:
Next step: get the invoice right before anything ships; it feeds the ISF, the classification, the value and the entry.
No. CBP does not issue a general import license. You need an importer number (normally your EIN, registered on CBP Form 5106), a customs bond for a formal entry, and any product approvals that a partner agency such as FDA, FCC or CPSC requires for your goods.
Usually a licensed customs broker files it electronically in ACE under your power of attorney. The entry summary is due within 10 working days after entry under 19 CFR 142.12, and you remain responsible for its accuracy even when a broker prepares it.
No. The Importer Security Filing in 19 CFR Part 149 applies only to cargo arriving by vessel. An air shipment needs the air waybill, the commercial invoice, the packing list and the normal entry documents.
No. Amazon states that it will not act as importer of record for FBA inventory regardless of shipment size or value. You, or a party you appoint, must be the importer of record. Amazon may appear as ultimate consignee only when the shipment is marked in care of Amazon.
No. Duty-free de minimis treatment ended for China and Hong Kong on 2 May 2025 and for all countries on 29 August 2025. CBP codified the suspension by rule on 24 June 2026 and the statute repeals the exemption on 1 July 2027. Every commercial shipment now needs a formal or informal entry.
The commercial invoice records the sale: parties, description, quantities, price, currency, charges and country of origin, as required by 19 CFR 141.86. The packing list shows what is inside each carton, with counts, weights and dimensions. CBP values and classifies from the invoice and examines cargo against the packing list.
For first-time Amazon FBA and Shopify sellers importing into the US. The customs paperwork laid out in order, blanks ready to fill in, plus a landed-cost spreadsheet and a shipment log.
Blank templates built from the public law. Not legal advice, and not a filled-in document.
Commercial invoice requirements for US customs under 19 CFR 141.86: the eleven required elements, English, currency, itemized charges, origin and assists.
Do I need a customs bond to import from China? Yes for a formal entry: single vs continuous bonds, ISF 10+2 deadline and penalty, and what a broker files.
How to find the HTS code for my product: HTSUS structure, USITC search, the General Rules of Interpretation, CROSS rulings and the Chapter 99 tariff stack.
Landed cost calculator for Amazon FBA sellers importing from China: product, freight, stacked duties, MPF, HMF, broker and prep, with a worked example.