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.
Landed cost calculator for Amazon FBA sellers importing from China: product, freight, stacked duties, MPF, HMF, broker and prep, with a worked example.
Landed cost per unit is the total of product cost, freight and insurance, customs duties and stacked tariffs, CBP fees, broker and filing charges, US delivery and FBA prep, divided by the number of sellable units. For a first order from China in September 2026 the duty stack alone is often 20% to 55% of the product price, and since de minimis ended on 29 August 2025 there is no shipment size small enough to avoid it. This guide gives the formula, explains each line, works a dated example and sets out a spreadsheet layout you can reuse.
Every dollar figure in the example is illustrative. The duty and fee rates are correct as of 3 September 2026 and are dated; check them against the linked CBP, USTR and USITC pages on the day you order.
Landed cost per unit = (Product cost + Freight + Insurance + Duties + CBP fees + Broker and filing + US delivery + FBA prep) / Sellable units
Where:
Duty is computed on customs value, which for an arm's-length purchase is transaction value: "the price actually paid or payable" for the goods when sold for export to the United States, plus statutory additions such as assists (molds, tooling, artwork you supplied), packing and selling commissions (19 CFR 152.103). International freight and insurance are not part of customs value, but only if the invoice itemizes them; a single CIF price with no breakdown gets valued in full. That is why the invoice matters: Commercial invoice requirements for US customs.
Get an all-in quote from origin pickup to your US delivery address, with origin, ocean or air, destination terminal, and trucking shown separately. Ocean LCL is priced per cubic meter, FCL per container, air per chargeable kilogram. Cargo insurance is optional but cheap relative to the duty exposure.
| Layer | How to find it | Rate |
|---|---|---|
| HTS base rate | General column for your 8-digit subheading at hts.usitc.gov | Product-specific |
| Section 301 China list | Chapter 99 note 20; USTR list pages | 25% (Lists 1 to 3) or 7.5% (List 4A); List 4B suspended |
| Section 301 forced-labor duty | Heading 9903.05.31 for China (CSMS 69326983) | 12.5% since 24 July 2026 |
| Section 232 | Chapter 99 notes for steel, aluminum, copper, timber and derivatives | Applied on full customs value since 6 April 2026 for metals; product-specific |
| IEEPA tariffs | Headings 9903.01.xx, inactive | 0% since 24 February 2026 (struck down 20 February 2026) |
| Section 122 surcharge | Heading 9903.03.01, expired | 0% since 24 July 2026 (was 10%) |
Goods subject to Section 232 are excluded from the forced-labor duty; everything else from China gets it. Antidumping and countervailing duties are a separate product-specific layer. The mechanics of finding each layer are in How to find the HTS code for my product.
| Fee | Basis | Until 30 September 2026 (FY2026) | From 1 October 2026 (FY2027) |
|---|---|---|---|
| Merchandise processing fee, formal entry | 0.3464% of entered value | Minimum $33.58, maximum $651.50 | Minimum $34.58, maximum $670.86 |
| Merchandise processing fee, informal entry (automated) | Flat | $2.69 | $2.77 |
| Harbor maintenance fee | 0.125% of value, vessel cargo only | 0.125% | 0.125% |
The MPF minimum bites on small orders: any ocean or air entry with a customs value under about $9,700 pays the minimum. HMF does not apply to air freight (19 CFR 24.24 covers cargo "loaded on or unloaded from a commercial vessel").
A licensed customs broker charges an entry fee, an ISF filing fee for ocean shipments, and either a single transaction bond per entry or an annual continuous bond. These are commercial prices; get a written quote. What each of them is, and when a continuous bond pays for itself, is in Customs bond, ISF 10+2 and hiring a broker.
Port or airport pickup, trucking to a prep center or directly to the Amazon fulfillment center on your shipment plan, and prep (poly bags, FNSKU labels, bubble wrap, carton labels) either at the factory or in the US. Amazon will not act as importer of record and will not pay duties, so a shipment cannot arrive at a fulfillment center with charges owing.
Product: plastic drawer organizer, classified 3924.90.56 (other household articles of plastics), General rate 3.4%, on Section 301 List 4A (heading 9903.88.15, 7.5%), subject to the forced-labor duty (heading 9903.05.31, 12.5%). Not a Section 232 article. Order: 1,000 units at $4.20 FOB Shenzhen, ocean LCL to Los Angeles, then trucked to a prep center.
| Line | Calculation | Amount |
|---|---|---|
| Product cost | 1,000 x $4.20 | $4,200.00 |
| Ocean freight, origin and destination charges (LCL, about 3 cbm) | Forwarder quote | $950.00 |
| Cargo insurance | Quote | $40.00 |
| Customs value | FOB price of the goods | $4,200.00 |
| Duty, HTS base | 3.4% x $4,200 | $142.80 |
| Duty, Section 301 List 4A | 7.5% x $4,200 | $315.00 |
| Duty, Section 301 forced labor | 12.5% x $4,200 | $525.00 |
| Merchandise processing fee | 0.3464% x $4,200 = $14.55, below the minimum | $33.58 |
| Harbor maintenance fee | 0.125% x $4,200 | $5.25 |
| Broker entry fee | Quote | $150.00 |
| ISF filing | Quote | $35.00 |
| Single transaction bond | Quote | $60.00 |
| Trucking, port to prep center, and delivery to FBA | Quote | $450.00 |
| FBA prep and labeling | 1,000 x $0.30 | $300.00 |
| Total landed | $7,206.63 | |
| Landed cost per unit | $7,206.63 / 1,000 | $7.21 |
Duties and CBP fees come to $1,021.63, or 14.2% of landed cost; the product itself is 58%. The same math on a $9.00 backpack of man-made fibers (4202.92.31: 17.6% base, List 3 at 25%, forced labor 12.5%, total 55.1%) adds $4.96 of duty per unit before a single fee, which is why the HTS code needs to be settled before you accept the factory's quote.
If you allow 2% for defects and samples, divide by 980 sellable units instead: $7.35 per unit.
Until May 2025 a seller could route small quantities from China direct to customers or to FBA in parcels valued under $800 with no duty and no entry. That path closed for China and Hong Kong on 2 May 2025 and for every country on 29 August 2025 under Executive Order 14324. The suspension was continued by Executive Order 14388 on 20 February 2026 (the day the Supreme Court struck down the IEEPA tariffs), CBP wrote it into its regulations by interim final rule effective 24 June 2026, and the One Big Beautiful Bill Act repeals the statutory exemption on 1 July 2027.
For your spreadsheet this means: the fixed costs of an entry (MPF minimum, broker fee, ISF, bond) now apply to every shipment, so a 200-unit test order carries a much higher landed cost per unit than a 1,000-unit order of the same product. Model the order size, not just the unit price.
One row per SKU per shipment, with these columns:
Keep the rate columns as inputs with a "checked on" date next to them. Rates in this space changed at least five times between February 2025 and July 2026.
Keep the landed-cost sheet for each shipment with the CBP Form 7501 as filed, the broker's invoice showing duties and fees paid, the freight and insurance invoices, and a note of where you took each rate from (USITC revision number, USTR list, CSMS bulletin number, Federal Register citation) and the date you checked it. Entry records must be kept for 5 years (19 CFR 163.4), and this sheet is what you will use to reconcile any refund, such as the IEEPA refunds CBP is paying through CAPE, against the entry it belongs to.
Landed cost is everything it takes to get one unit into Amazon's warehouse: the product, freight and insurance, customs duties and Chapter 99 tariffs, CBP fees, broker and filing charges, US delivery and FBA prep. Amazon referral and fulfillment fees are charged after that and are not part of landed cost.
The merchandise processing fee on a formal entry is 0.3464% of entered value with a minimum of $33.58 and a maximum of $651.50 until 30 September 2026, rising to $34.58 and $670.86 from 1 October 2026. The harbor maintenance fee is 0.125% of value on cargo unloaded from a vessel and does not apply to air freight.
No. Duty is assessed on transaction value, the price actually paid or payable for the goods, plus additions such as molds or tooling you supplied. International freight and insurance are excluded when they are itemized on the invoice.
No. De minimis treatment ended for China and Hong Kong on 2 May 2025 and for all countries on 29 August 2025. CBP suspended it by regulation on 24 June 2026 and the statute repeals it on 1 July 2027. Every shipment now pays the applicable duties and fees through an entry.
The HTS base rate, the Section 301 China list rate (25% for Lists 1 to 3, 7.5% for List 4A), the 12.5% Section 301 forced-labor duty in force since 24 July 2026, and Section 232 duties where the product is a covered metal or timber article. The IEEPA tariffs have not been collected since 24 February 2026 and the Section 122 10% surcharge expired on 24 July 2026.
CBP refunds IEEPA duties through the CAPE function in ACE. Only the importer of record or the broker that filed the entries can submit the declaration, refunds are paid by ACH to the importer's bank account, and CBP says valid refunds are generally issued within 60 to 90 days of acceptance. Check the CBP IEEPA duty refunds page for current phases.
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.
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.
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.