Pro forma invoices for free samples and replacements

What to put on a pro forma for free goods, how to support the customs value, and why no charge does not mean no duty.

By Lucas Duys. Published 2026-11-04.

Free samples and free replacements still need a supported customs value. A pro forma invoice records goods sent without a payment request. It is not a valuation method or a grant of duty relief. First explain why the goods are free, then establish how they should be valued. [1] [2]

Prepare these five details

Ask the supplier for a pro forma and keep the evidence behind it:

Identify the shipment. Add the sender, recipient, date and document number. Link each item to the packing list.
Describe the goods. Give the product, material, use and quantity. “Samples” alone does not identify the item.
Explain the free supply. Say whether it is a sample, a warranty replacement or another arrangement. Give the original order reference where relevant.
Show the value and its basis. State the currency and value per item. Attach the evidence used to establish it, rather than inserting EUR 1 or zero because no payment is due.
Separate delivery costs. Include the delivery terms and named place. Provide freight and insurance evidence so the declarant can check the costs already included. [1] [2]

For a replacement, also collect the original invoice, warranty terms and any return or earlier import records. These let the declarant check the transaction and any proposed customs procedure.

Check the method before copying a price

The transaction-value method starts with a sale for export to the EU. A standalone free supply with no sale cannot use a made-up sale price. If that method does not apply, examine the Article 74 methods in their legal order. The deductive and computed methods can be reversed at the declarant's request. [2]

A supplier's normal price list may provide evidence. It does not, by itself, choose the legal method. Also check whether the “free” goods are already covered by a wider paid contract.

Check relief separately

Calling a shipment a sample does not make it duty-free. Article 86 relief requires negligible-value samples whose presentation and quantity limit their use to seeking orders. Customs may require them to be marked or made unusable for other purposes. [3]

Likewise, “warranty replacement” on the pro forma is not approval of a relief. Keep the valuation decision and any relief claim separate in the shipment file.