Invoice, packing list and bill of lading compared

Three documents, three jobs. The commercial invoice describes the sale and supports the declared value [2]. The packing list says how the goods are packed: the packages, their marks and the net and gross weights. The bill of lading, or the air waybill or road consignment note, is the transport document, whose type and reference the declaration records [3]. A declaration for release for free circulation needs data from all three, and where they disagree, the declarant has to settle which one is right before lodging.

What each document gives the declaration

The codes are the German ATLAS code list for document types [5]; the German customs guidance lists the same transport document codes for data element 12 05 [4]. Annex B marks the transport document, the gross mass, the packaging and the mode of transport at the border as required in column H1, and the net mass too [3].

The invoice: the sale

The invoice is the value document. The Implementing Regulation requires "the invoice which relates to the declared transaction value" as a supporting document [2], and the declaration takes the prices, the currency, the delivery terms and the goods descriptions from it. The guide on what a declaration needs from the invoice goes through it field by field.

The packing list: packages and weights

Annex B defines the net mass as "the mass of the goods without any packaging" and, for a declaration for release for free circulation, the gross mass as the weight of the goods of the item including packaging but excluding the carrier's equipment [3]. When the weight of the pallets is in the transport documents, it goes into the gross mass as well, with stated exceptions [3]. Where items are packed together so that no gross mass per item can be determined, the total gross mass only needs to be given at the level of the declaration [3]. Both masses are in kilograms, and above 1 kg a fraction may be rounded: up from 0.5, down below it [3].

The German guidance reads differently on pallets. It treats pallets as transport equipment, excluded from gross mass, and not as packages, though a pallet may count as a package where the goods are shrink wrapped on it or not otherwise packed; the kind of package to declare is the transport packaging, not the retail packaging [4]. The same guidance notes that ATLAS may still differ from Annex B, so it is worth knowing which rule the customs office applies [3] [4].

When is a packing list needed at all? German customs may ask for one when goods are presented in several packages, listing the contents of each [6]. The Dutch customs handbook names the packing list among the supporting documents for release for free circulation [7].

The bill of lading: the transport

The transport document identifies the consignment in the declaration: its type and number, and the containers the goods travelled in. It also says where the goods arrived. That matters for the value, because freight and insurance are added up to the place where the goods are brought into the EU, which for sea freight is the port where they arrive first [2]. German customs can ask for the transport documents and the documents of a previous customs procedure at any time [6].

Where the three disagree

None of this is written as a rule, but it is where declarations go wrong. A check before lodging compares:

• Packages. The number of packages on the packing list against the bill of lading, and the marks against the container.
• Gross weight. The packing list total against the transport document, allowing for pallets.
• Parties. The buyer on the invoice against the consignee on the bill of lading, and the seller against the shipper.
• Goods. The invoice lines against the packing list lines, so that every declared item has a weight and a package.

The reason to check is responsibility. Lodging a declaration makes the declarant, and a customs representative who lodges it, responsible for the accuracy and completeness of the information and for the authenticity and validity of the supporting documents [1]. Those documents must be in the declarant's possession and available to customs when the declaration is lodged [1].

Handing the documents to customs

In Germany the documents stay with the declarant and are produced when the customs office asks for them or when Union law requires it [6]. In the Netherlands, since 16 May 2026, documents that customs asks for on an import or export declaration are delivered through a link between the customs software and DMS, not by e-mail, and can be sent separately per document code [8].

For a specific shipment, the customs office in Germany or the Netherlands is the authority on which documents it wants.

Athren prepares the case from the shipment email and the invoice, the packing list and the transport document in it; your declarant checks what is open and files it. Athren files nothing.