4.5 Commercial Invoice and Entry Documentation Requirements (19 CFR Part 141, Subpart F)
Key Takeaways
- 19 CFR 141.86 lists the mandatory content of a commercial invoice, including the port of entry, the parties, a detailed description adequate to classify the merchandise, quantities in the weights and measures of the country of shipment, the purchase price in the currency of sale, all charges itemized by name and amount, the country of origin, and all rebates and assists.
- The invoice must be in English or be accompanied by an accurate English translation (19 CFR 141.86(d)).
- 19 CFR 141.89 imposes additional invoice requirements for specified classes of merchandise, so a textile, footwear, machinery, or chemical invoice must carry commodity-specific data beyond the general 141.86 elements.
- Where the required invoice is unavailable, a pro forma invoice may be presented under 19 CFR 141.85 with an undertaking to produce the required invoice.
- A bond for the production of missing documentation is executed on CBP Form 301 under 19 CFR 141.66, and the document must be delivered within 120 days of the CBP notice requesting it, extendable once by up to 60 days (19 CFR 113.43).
4.5 Commercial Invoice and Entry Documentation Requirements (19 CFR Part 141, Subpart F)
Why the invoice is a Category II subject: a released Practical Exercise set handed candidates a commercial invoice, told them a "documents required" notification had issued after the entry summary was filed, and asked which regulation compelled the change to the merchandise description. The answer turns on knowing that the description requirement lives in 19 CFR 141.86 and that commodity-specific additions live in 19 CFR 141.89. You cannot reason your way to that from the invoice; you have to know the sections.
The Mandatory Content of a Commercial Invoice (19 CFR 141.86)
Every commercial invoice presented with an entry or entry summary must set forth the following. The order below follows the regulation, which is the order to learn them in, because a question may ask which element is missing:
| Required Element | What It Means in Practice |
|---|---|
| The port of entry to which the merchandise is destined | Drives the Schedule D port code and, in Practical Exercise sets, the entry filing location |
| The time when, the place where, and the person by whom and to whom the merchandise is sold or agreed to be sold, or, if not a sale, the manner of consignment | Establishes whether there is a sale for exportation supporting transaction value |
| The detailed description of the merchandise, including the name by which each item is known, the grade or quality, and the marks, numbers, or symbols under which it is sold by the seller or manufacturer, together with the marks and numbers of the packages | The element most often deficient — see below |
| The quantities in the weights and measures of the country or place from which the merchandise is shipped, or in the weights and measures of the United States | Must permit reconciliation to the HTSUS unit of quantity |
| The purchase price of each item in the currency of the purchase, if the merchandise is sold or agreed to be sold; or, if not, the value for each item in the currency in which the transactions are usually made | The starting point for the price actually paid or payable |
| The kind of currency | Prevents ambiguity between, for example, U.S. and Canadian dollars |
| All charges upon the merchandise, itemized by name and amount — freight, insurance, commission, cases, containers, coverings, and cost of packing; and if not included above, all charges, costs, and expenses incurred in bringing the merchandise to the first U.S. port | This is what makes non-dutiable charges provable under 19 U.S.C. § 1401a(b)(3) |
| All rebates, drawbacks, and bounties allowed upon the exportation | Reveals adjustments that bear on value |
| The country of origin | Drives the rate column, marking, trade remedies, and preference eligibility |
| All goods or services furnished for the production of the merchandise free of charge or at reduced cost | Discloses assists under 19 U.S.C. § 1401a(h) |
Language and Signature
Under 19 CFR 141.86(d), the invoice must be in the English language, or be accompanied by an accurate English translation. The invoice must also bear enough identifying information for CBP to link it to the entry.
Why the Description Requirement Drives Corrections
The description must be detailed enough that CBP can classify the merchandise from it. An invoice reading "bedspreads, 100% polyester" is not sufficient where the classification depends on whether the article has edging, whether it has outer layers with a filling between them, or how it was constructed. When CBP issues a request for information (CBP Form 28) or a documents-required notification after an entry summary, the most common cause is a description that does not support the declared classification, and the provision compelling the correction is the detailed-description requirement of 19 CFR 141.86.
Commodity-Specific Additions: 19 CFR 141.89
19 CFR 141.89 requires additional information on invoices covering specified classes of merchandise. This is a lookup list, and it is exactly the kind of provision an open-book exam rewards. Representative examples of the classes it reaches include:
- Textile fibers, yarns, and fabrics — fiber content by weight, construction, whether bleached or colored, width, and weight per unit area;
- Footwear — the constituent material of the upper and the outer sole, the type of construction, and the intended wearer;
- Machinery and machine parts — the identity of the machine for which a part is intended and its function;
- Chemicals — the chemical name, CAS number where applicable, and the percentage composition of mixtures;
- Iron and steel products — chemical composition, dimensions, and whether further worked;
- Articles of precious metal, jewelry, and watches — metal content, fineness, and the components of the movement.
HOW TO USE 141.89 ON EXAM DAY: When a question describes an invoice for one of these commodity families and asks what information is missing or what CBP may require, go straight to 19 CFR 141.89 rather than reasoning from 141.86. The general description requirement and the commodity-specific list are separate obligations, and both apply.
When the Required Invoice Is Not Available
The Pro Forma Invoice (19 CFR 141.85)
Where the required commercial invoice cannot be produced at the time of filing, the filer may present a pro forma invoice. The pro forma is a statement, in the form prescribed by 19 CFR 141.85, of the information the commercial invoice would contain, executed with an undertaking to produce the required invoice. A pro forma invoice permits the entry to proceed; it does not excuse the eventual production of the real document.
The Missing-Document Bond (19 CFR 141.66 and 113.43)
Where a bond is required to secure production of a document not available at the time of entry:
- The bond is executed on CBP Form 301, containing the conditions set forth in 19 CFR 113.62 or 113.69, as appropriate (19 CFR 141.66).
- The missing document must be delivered within 120 days from the date of the CBP notice requesting it.
- On written application, the port director may grant one further extension not to exceed 60 days (19 CFR 113.43).
- The missing document is identified in the Missing Docs block of the entry summary — block 18 on both the current CBP Form 7501 (02/26) and the pre-2026 revisions.
Failure to produce the document within the period breaches the bond condition and exposes the principal and surety to liquidated damages.
Bond for Production of a Bill of Lading (19 CFR 141.15)
A related but distinct instrument arises where the filer cannot produce evidence of the right to make entry. Under 19 CFR 141.15, the port director may accept a bond on CBP Form 301 containing the conditions of 19 CFR 113.69 for the production of the bill of lading or air waybill. Under CBP's Monetary Guidelines this is bond activity code 7, and the amount is not less than 1.5 times the invoice value of the merchandise. The bond is cancelled on production of the bill of lading or air waybill.
Reading an Invoice Like an Examiner
Practical Exercise sets are built on invoices that contain deliberate errors, and the printed instruction warns that they may. A repeatable checklist:
- Does the description support the declared classification? If the classification depends on a fact the invoice does not state, that is the error.
- Is every charge itemized by name and amount? A CIF price with no breakout cannot support a deduction for international freight and insurance.
- Do the quantities reconcile to the HTSUS unit of quantity and to the packing list?
- Is the country of origin stated, and is it consistent with the marking, the manufacturer's address, and any preference claim?
- Are assists disclosed? Tooling, molds, dies, and foreign-performed design supplied free or at reduced cost are dutiable additions under 19 U.S.C. § 1401a(b)(1)(C).
- Is the destination port on the invoice consistent with the port where entry is being filed? A mismatch is a common planted error.
- Does the commodity fall within 19 CFR 141.89? If so, check the commodity-specific elements before concluding the invoice is complete.
After an entry summary is filed, a broker receives a documents-required notification. Reviewing the commercial invoice for woven polyester bedspreads, the broker realizes the description omitted that the bedspreads have a sewn-on contrasting edging — a fact that bears directly on the classification — and handwrites the addition on the invoice. Which requirement compelled that change?
An importer cannot produce a required document at the time of entry and gives a bond for its production. CBP issues a written notice requesting the document on May 1. By when must the document be delivered, and what relief is available?
A filer presents an entry for a shipment of women's footwear. The commercial invoice states the port of entry, the parties, the quantity in pairs, the CIF price in euros with freight and insurance itemized, the country of origin, and a description reading 'ladies' shoes, assorted styles.' Which statement is correct?