Goods entering the US: which fields 19 CFR 141.86 requires on the commercial invoice

Bottom line:

The commercial invoice used for US entry is written in 19 CFR 141.86. CBP’s importing guide restates the same set for importers and brokers.
Write the port of entry; the time, place and parties to the sale; a detailed goods description and package marks; quantities; purchase price in the currency of sale, or value if not a purchase; the kind of currency; itemised charges; rebates; country of origin; production assists not in the price; and a named exporter employee who knows the deal. It must be in English. What is in each package must be clear.
Membership wired to ALIBABA.COM HONG KONG LIMITED buys a showcase. It does not issue invoices. Do not invent a duty rate or a second “entry price.” Corpable does not issue the invoice and does not guarantee release.

Friday afternoon the Long Beach broker returns a mail: “Commercial invoice rejected. Store name is not the seller. Need 19 CFR 141.86 fields, in English, with a named person who knows the deal.” The attachment is a pro forma the store exported: seller is the showcase name, goods say gifts, currency is blank, no port of entry, no itemised freight, no contact at the bottom. Sales adds a scan of a Chinese VAT invoice. The broker says that is another tax system. It will not fill this box.

On the same booking the packing list uses the inland factory, the invoice uses the Hong Kong company, and the bill of lading shipper is the forwarder. The broker asks whether the three papers are one sale. Sales has ticked the document checklist and has not walked 141.86 box by box. Finance wants a second “entry price,” saying duty will be lower. The broker replies: purchase price, discounts and rebates belong on the invoice or an attachment; a second low price damages the entry and the later review.

Do not reply “any invoice will do.” Stop three things first: do not use a store name as seller, do not make a second entry price, and do not treat a Chinese tax invoice as the English original. Letterheads sit on Hong Kong entity document titles. Whether the goods are Hong Kong origin sits on China goods are not Hong Kong origin. The usable order is: name whether this paper is a commercial invoice, then the people, then the goods, then money and origin, then English and the contents of each package, and only then how a Hong Kong invoice lines up with a plant packing list.

Name this paper first: a commercial invoice, not a pro forma or a store export

CBP’s guide for commercial importers writes that a commercial invoice signed by the seller, the shipper or their agent is acceptable if it is prepared under 141.86 through 141.89 and in the manner customary for goods of that kind. Importers and brokers on the Automated Broker Interface may transmit invoice data electronically. Paper or electronic, the fields are the same set.

A pro forma locks a quote and a specification. It is not the default entry text. If the goods are sold on the documents while in transit from the export port to the port of entry, 141.86 wants the original invoice that started the journey to the United States, plus the resale invoice or a statement of sale; if the original cannot be obtained, a pro forma that reflects the original values and transaction is filed with the resale invoice. “PI confirmed” is not the same as a commercial invoice in hand.

A PDF exported from the store admin often lacks the port of entry, the legal seller, itemised charges and a named contact who knows the deal. A store name, a campaign price and a Chinese specification will not fill 141.86. It can be a draft. It cannot be the entry paper.

Do not mix samples and consignment onto one “whatever” invoice. Goods shipped under a purchase write the purchase price. Goods not shipped under a purchase — gifts, consignment, stock transfers — write the value 141.86(a)(6) asks for: the value in the currency usually used, or, if there is no such value, the price the manufacturer, seller, shipper or owner would have accepted in the ordinary course in the country of exportation, in usual wholesale quantities. Samples still need an English description, quantity, origin and a named contact. Do not write “value for customs: 1 USD” to “keep it simple,” unless that is the real deal.

Related-party prices and intra-group charges do not open a door that says “purchase price may be omitted.” You still write who sold to whom, at what price, and whether discounts or rebates exist. If the broker or the Center director wants more, add an attachment on their written list. Do not leave the 141.86 box empty because “it was an internal transfer, no invoice.”

Seller, buyer, place of sale: legal names, not the store name

141.86(a)(2) wants the time, the place, and the person by whom and to whom the merchandise is sold or agreed to be sold; if it is not imported under a purchase, the place from which shipped, the time, and the persons to whom and by whom it is shipped. Seller and buyer use legal names and addresses. A Hong Kong invoice writes the registered Hong Kong name, not “Alibaba store / showcase name.” The buyer is the legal name on the US contract, not a purchaser’s personal mailbox.

If non-purchased goods are shipped by someone other than the manufacturer, 141.86(b) also wants when, where and from whom those goods were purchased, and the price paid in the currency of that purchase. A Hong Kong trading company that bought from an inland factory and sold to a US buyer must be able to tell that purchase story. A last-page selling price is not enough.

Every invoice of imported merchandise must name a responsible employee of the exporter who has knowledge of the transaction, or who can readily obtain it — 141.86(j). Do not leave only a shared sales@ mailbox, and do not leave a salesperson who has already left. When the broker calls on Tuesday night about a unit price that does not match the contract, that person has to pick up.

Box	What the regulation wants	The usual wrong version
Seller / buyer	Legal names, addresses, time and place of the sale	Store name, buyer nickname, country with no address
Port of entry	The US port the goods are destined to	Blank, or “USA”
Named contact	One exporter employee who knows the deal	A shared mailbox, or a departed salesperson

Invoice and page numbers, when more than one invoice sits on the same entry and invoice data are not transmitted electronically, are numbered consecutively by the importer at the bottom of the face of each page. The seller first locks how many pages this booking’s invoice has. Do not send three versions the same day that are all called INV-001.

Description, quantity, package marks: the words on the carton have to match

141.86(a)(3) wants a detailed description: the name by which each item is known, the grade or quality, the marks, numbers and symbols under which the seller or manufacturer sells to the trade in the country of exportation, and the marks and numbers of the packages. (a)(4) wants quantities in the weights and measures of the place of shipment, or of the United States.

“Gifts / parts / wooden items” will not fill this box. A dining chair writes material, whether it is upholstered, and how many pieces in the set. A lamp writes whether it ships with a light source and the voltage. A screw writes size and material. Package marks match the stencil on the carton and the carton numbers on the packing list. Several cartons on one booking do not collapse into one line of “assorted.”

141.86(e) wants each invoice to state in adequate detail what merchandise is in each individual package. That is the packing information CBP wants. It may sit on the invoice or on an attachment. The packing-list letterhead still has to point back to the same seller and the same booking. Whether the four flows tell one story sits on four-flow consistency.

If the invoice and the entry do not disclose a weight, gauge or measure that is needed to ascertain duties, 141.86(f) writes that the consignee pays for weighing, gauging or measuring before release from CBP custody. What the seller can do is write gross and net weight and measure on the invoice or an attachment before the box leaves. Do not wait for the terminal to weigh it again.

Price, currency, freight and insurance, origin, tooling assists: one empty box and the broker sends it back

Goods shipped under a purchase write the purchase price of each item in the currency of the purchase. Goods not shipped under a purchase write the value in the currency usually used; if there is no such value, write the price the manufacturer, seller, shipper or owner would have accepted in the ordinary course in the country of exportation, in usual wholesale quantities. The kind of currency — gold, silver or paper — must be stated. In today’s practice that means a clear currency name, for example USD. Do not leave it blank.

All charges upon the merchandise are itemised by name and amount: freight, insurance, commission, cases, containers, coverings, cost of packing; and, if not already included, the costs of bringing the goods from alongside the carrier at the export port to alongside the carrier at the first US port of entry. Packing, cases, containers and inland freight to the export port need not be broken out by amount if they are included in the invoice price and so identified. Anything missing from the face of the invoice must appear on an attachment.

Rebates, drawbacks and bounties allowed on exportation are itemised separately. Every discount from list or other base price that has been or may be allowed in fixing each purchase price or value is set out in detail, 141.86(g). Do not make a second “entry price” to “optimise duty.” Duty, antidumping and Section 301 follow classification and origin, see 301 follows origin. They do not follow how willing you are to write a lower unit price.

Country of origin must be stated. Assembled in China with a Hong Kong invoice seller still follows the origin rules for the goods. Do not write Hong Kong because a Hong Kong company invoiced. Goods or services furnished for production and not included in the invoice price — dies, molds, tools, engineering — must be stated; goods or services furnished in the United States are excluded. Annual reports approved by the Center director may prove those goods or services were provided.

Money and origin	What to write	What not to write
Purchase price / value	Unit price and total in the currency of the deal	A second entry price, or a blank currency
Freight, insurance, commission, packing	Name and amount, or “included in price” if that is true	One “all in” figure that cannot be split
Country of origin	Origin of the goods	Hong Kong because the invoice is Hong Kong
Tooling assists	Molds, tools, engineering not in the price	Pretend there are none, or a figure that cannot match the tooling contract

The regulation allows any required information to sit on the invoice or on an attachment. Attachments still need English or an accurate translation, and they must point back to the invoice number. A WeChat thread is not an attachment.

It must be in English; per-package detail may be an attachment, it may not be omitted

The most common Tuesday rejection is not a missing stamp. It is English fields that do not match the carton. The invoice says dining chair, the carton says stool, the packing list says furniture. 141.86 wants the name by which the item is known in the trade, plus package marks. Before the box leaves, put invoice lines, packing-list lines and carton marks on one check sheet, three rows for the same article. If they do not match, fix the papers, then send the terminal.

141.86(d) writes that the invoice and all attachments must be in the English language, or must have an accurate English translation containing adequate information for examination of the merchandise and determination of duties. A Chinese VAT invoice and a Chinese specification stay as internal drafts. The set you send out uses English legal names, English descriptions and English charge names.

The “packing list” a broker asks for is not a fixed official blank in the regulation. It is “what is in each individual package” stated in adequate detail. It may sit on the commercial invoice or on its own page. On its own page, carton numbers, marks, per-carton description, quantity, and gross and net weight must point back to invoice lines. “10 cartons of furniture” will not do.

When more than one invoice sits on one entry, the importer numbers pages under 141.86(h). The seller first locks the version: ship date, invoice number, page count and attachment list in the same mail to the broker. If the unit price changes after shipment, the old invoice is dead and the new invoice takes a new number. Do not mark up the old PDF.

A Hong Kong invoice and a mainland packing list: how three letterheads line up

A Hong Kong contract seller, a mainland factory packing the boxes, and a forwarder on the bill of lading is a common Hong Kong-channel structure. The commercial-invoice seller should be that Hong Kong company’s legal name, matching the receiving account and the contract. The packing list may name the factory as manufacturer or producer, and it must still explain: the Hong Kong seller sold to the US buyer; the factory is where the goods were made. If the bill of lading shipper is not the invoice seller, the broker will ask why. Write the explainable chain in the note to the broker. Do not change the invoice seller afterwards to chase the bill.

Country of origin follows the goods, not the invoice seller’s place of registration. Chinese goods on a Hong Kong invoice write China under the applicable origin rules. Do not write Hong Kong to “avoid” Section 301 or another origin measure. 301 follows origin, see that page.

If the ocean box also needs ISF, seller, buyer, manufacturer and goods description should match this commercial invoice. ISF will not fill a missing port of entry or missing itemised charges on the invoice. The invoice will not fill ISF’s ten elements.

If molds, fixtures or engineering were furnished free by the US buyer and are not in the invoice price, 141.86(a)(11) wants those assists stated; assists furnished in the United States are excluded. Hong Kong sellers often leave the tooling receipt in finance and never mention it on the invoice. When the broker is asked about molds after entry, the trail returns to this invoice. Write “tooling / fixtures / engineering not included in the price” as an attachment line, with an amount that can match the tooling contract. If tooling is already in the unit price, mark “tooling included in unit price.” Do not add a second amount for the broker to count twice.

Goods sold in transit keep the original invoice that started the journey to the United States, plus the resale invoice or statement. If the original sits with a prior seller and cannot be obtained, a pro forma may reflect the original deal, together with the resale invoice. A Hong Kong company that bought from an inland factory and sold to a second US buyer after the box sailed must let both layers appear in the entry file. Do not keep only the last, higher invoice.

The mail to the broker is a full sentence: “The commercial invoice for this entry is prepared in English under 19 CFR 141.86. The seller is the Hong Kong contract company’s legal name; the buyer is the legal name on the contract; the port of entry is [port]; goods description and carton marks match the packing list; currency and unit price match the contract; freight, insurance and commission are itemised (or marked as included in the unit price); country of origin follows the goods; the named contact is [name]. Attachments are the packing list and the charge breakdown. The pro forma is a quote only and does not replace this commercial invoice.” Do not send only a cloud-drive link.

In the contract and the PI, delete “the invoice may use the store name,” “the entry invoice may be below the contract price,” and “a Hong Kong invoice means Hong Kong origin.” Write: the entry commercial invoice is issued in English under 19 CFR 141.86; the seller is the legal name on the contract; description, quantity, purchase price, itemised charges and country of origin match the packing list and the draft declaration; a named contact sits on the invoice. If an inquiry says “send any invoice,” reply: entry needs a commercial invoice, not a pro forma; the fields follow 141.86.

The broker rejects the invoice, or the buyer only wants a PI: what sales and finance stop

When the broker rejects the invoice, what sales stops that day is the external release promise. Stop: pickup on Monday, invoice already accepted, duty locked on an “optimised” price. Do not stop: walking 141.86 box by box — English legal names, port of entry, description, itemised charges, origin, named contact. Do not click a Trade Assurance “cleared” node before the broker accepts the invoice.

Finance deletes the second “entry price” that day. Purchase price, discounts and rebates sit on the same invoice or attachment. Duty follows classification and origin. Do not lock an “official duty” inside the unit price. Membership receipts do not go in the entry-invoice bag.

What the plant checks that day is whether carton marks still point back to this invoice. If the description is unlocked, pallets do not go to the terminal. Cartons do not print “customs optimized” or a store campaign price.

How discounts are written: 141.86(g) wants every discount from list or other base price that has been or may be allowed in fixing each purchase price or value, for each class or kind of merchandise. A store campaign price, a tiered price, a full-container allowance — if it entered the deal, it goes on the invoice or an attachment. Do not say “we will send a credit note later” while the entry invoice sits at the undiscounted price, unless that is still the real price at entry. A discount already given and not written is as damaging as a second low price.

Commissions, rebates and export bounties are itemised. A commission to a purchaser, a booking commission to a forwarder, a bounty received on the export side — name and amount, separately. If you are unsure whether a line belongs on the invoice, ask this booking’s broker for a written list. Do not let sales delete a line “from experience” in a group chat. Deleting the wrong line is harder to repair than adding an attachment.

One set of goods on two invoices — samples on one, bulk on the other — is numbered consecutively by the importer under 141.86(h). The seller first writes in the mail which cartons INV-A covers and which cartons INV-B covers, and whether buyer, origin and named contact are the same set. Do not call both INV-001 and let the broker guess which one is dead.

Air express into the United States, when the commercial value is already a formal entry, still wants this set of fields. “Commodity: gifts” on an express label will not fill 141.86. The commercial invoice that travels with the goods still needs an English legal seller, a description, a currency price, origin and a named contact. Do not assume “it went express, so a pro forma is enough.”

If the inquiry says “just send PI, our broker will fix the invoice,” copy that sentence into an attachment and add: the entry commercial invoice is issued by the seller under 141.86; the broker may ask for attachments; a store export or a pro forma retitled as the body will not do. Empty words become a who-delayed-the-vessel fight after a rejection.

That day, tick 141.86(a) on this booking’s invoice: port of entry, parties, description and marks, quantity, currency price, itemised charges, rebates, origin, assists, named contact.
Chinese drafts stay inside. What goes to the broker is the English set, or a bilingual set whose English translation is accurate.
The packing list describes each carton. Three letterheads can be explained. The seller is not rewritten after the fact.
Until the broker accepts the invoice, sales does not click Trade Assurance cleared and does not publish a pickup date.
There is no second entry price. The store name is not the seller.

Corpable can sit with you on which 141.86 box is empty and how a Hong Kong letterhead lines up with the plant packing list. We do not issue the invoice, do not become the broker, and do not guarantee release. Membership still goes to ALIBABA.COM HONG KONG LIMITED.

Questions teams actually ask

The buyer only wants a pro forma. Can that clear US Customs?

CBP wants a commercial invoice that meets 19 CFR 141.86 through 141.89, signed by the seller, the shipper or their agent, and prepared in the manner customary for goods of that kind. A pro forma can lock a price. It does not fill the entry box. If the goods are sold in transit, the regulation also wants the original invoice plus the resale paper; only when the original cannot be obtained may a pro forma reflect the original deal, together with the resale invoice.

Can the invoice seller be only the Alibaba.com store name?

No. 141.86 wants a clear statement of who sold to whom. The seller uses a legal name and address that can match the contract, the declaration and the receiving account. A store display name may be noted. It cannot replace the legal name. How a Hong Kong letterhead lines up with a mainland packing list sits on the document-title page.

We have a Chinese invoice plus a packing list. The broker says it is not enough. What else?

The invoice and attachments must be in English, or must carry an accurate English translation sufficient for CBP to examine the goods and determine duties. What is in each package must be stated in adequate detail — that is the packing-list requirement in the regulation, on the invoice or as an attachment. Missing port of entry, itemised freight and insurance, origin, or tooling assists will still come back.

Freight and insurance are already in the unit price. Must we still list them?

141.86 wants charges itemised by name and amount, including freight, insurance, commission, cases, containers, coverings and packing. Costs from alongside the carrier at the export port to alongside the carrier at the first US port, if not already included, must also be listed. Packing, cases, containers and inland freight to the export port need not be broken out by amount if they are included in the invoice price and so identified. Anything missing from the face of the invoice must appear on an attachment.

If we write a lower unit price, will duty be lower?

Do not make a second “entry price.” Purchase price, discounts, rebates and export bounties must be written as the regulation requires. False or misleading figures damage the entry and the later review. Duty and antidumping follow classification and origin, see the origin pages. Do not “optimise” an official rate on the invoice.

Can Corpable issue the US customs invoice?

We do not issue it and we do not guarantee release. An advisor can sit with you on which 141.86 box is empty and how a Hong Kong letterhead lines up with the plant packing list. Membership buys a showcase. It is not invoice-issuing. Membership still goes to ALIBABA.COM HONG KONG LIMITED.