What a customs declaration needs from the invoice

For an import into the EU, the commercial invoice does two jobs. It is the required supporting document for the declared transaction value [2], and it is where most of the declaration's data about the sale comes from: the seller and the buyer, the delivery terms, the invoice currency, the amount per item, the description of the goods and, usually, their country of origin [3]. What the invoice does not say, the declarant has to get from the other shipping documents or from the people behind the shipment.

The invoice is the value document

The Implementing Regulation to the Union Customs Code says it in one sentence: "The invoice which relates to the declared transaction value is required as a supporting document." [2] The Code itself adds when: supporting documents must be in the declarant's possession and at the disposal of the customs authorities at the time the declaration is lodged [1].

German customs describes the commercial invoice as the paper on the basis of which the customs value of the goods is declared, and asks for a pro forma invoice where the goods have no commercial value, for example a gift [4]. Dutch customs says the invoice must always be present when goods are declared for release for free circulation, and shown on request [7]. Since 16 May 2026, documents that Dutch customs asks for during a control of an import or export declaration are delivered through a link between the customs software and DMS, not by e-mail [8].

What the declaration takes from it

Annex B of Delegated Regulation (EU) 2015/2446, as replaced by Delegated Regulation 2021/234, lists the data a declaration for release for free circulation carries, in its column H1 [3]. These are the elements that normally come from the invoice:

Annex B marks the total amount invoiced as optional for the declarant [3]. German customs guidance asks for the seller and the buyer where the customs value of the consignment exceeds EUR 20,000, unless the same seller supplies the same buyer continuously on the same terms or the import is not commercial [5].

The delivery terms matter beyond their own box: they decide whether freight and insurance to the EU border have to be added to the price. The guide on customs value, CIF and FOB works through that.

The description has to be enough to classify

For a declaration in column H1, Annex B defines the description of goods as "the normal trade description", expressed "in terms sufficiently precise to enable immediate and unambiguous identification and classification of the goods" [3]. The German customs guidance for 2026 asks for the usual trade name, precise enough for immediate and unambiguous identification and classification, and where that is not enough, details of the material, the processing and the intended use [5].

An invoice written for a buyer often names the product and stops there. "Ceramic dinner plate, 27 cm" identifies the goods; it does not say whether the plate is porcelain, which the tariff needs to know. The guide on when the invoice is not enough to classify takes that example apart.

Currency, exchange rate and the value threshold

The invoice currency is declared as it is. For customs valuation, a euro-area member state converts at the rate the European Central Bank publishes on the second last Wednesday of each month, and that rate applies for the whole of the following month [2].

Some valuation data can be waived for smaller consignments. Annex B tells the member state to waive the additions and deductions and the valuation indicators, except where they are essential for the correct customs value, when the customs value of a consignment does not exceed EUR 20,000 and it is not a split or multiple consignment from the same consignor to the same consignee; the same waiver applies to non-commercial imports and to continuing traffic between the same seller and buyer on the same commercial conditions [3]. German customs may dispense with the separate value declaration, the D.V.1, under the same threshold, and adds that the documents must be kept even when it does [6].

What the invoice usually leaves open

• Freight and insurance to the border that are not in the price, as under EXW, FCA, FAS or FOB [9]. They come from the freight invoice and the insurance certificate.
• The material or construction that the tariff splits on, when the description is written for a buyer rather than for customs.
• Proof of preferential origin, such as a movement certificate EUR.1 or an origin declaration on the invoice, when a reduced duty rate is claimed [4].
• Whether buyer and seller are related, and whether that influenced the price, which is one of the conditions for using the transaction value at all [1].

Checking before the declaration is lodged

Lodging a declaration makes the person who lodges it responsible for the accuracy and completeness of the information in it and for the authenticity, accuracy and validity of the documents supporting it; a customs representative who lodges it is bound in the same way [1]. That makes a short check of the invoice worth doing every time: the lines add up to the total, the Incoterm names a place, each line has a description that classifies and a country of origin, and the seller and buyer match the other documents.

For a specific shipment, the customs office in Germany or the Netherlands is the authority on what it needs.

Athren prepares the case from the shipment email; your declarant checks what is open and files it. Athren files nothing.