The Short Answer
A commercial invoice is the document customs uses to decide what is in your parcel, where it was made, what it is worth and how much duty is owed. For years, small parcels into the US and the EU slipped through with almost no duty. That ended. The US suspended its $800 duty free rule for every country on 29 August 2025, and the EU scrapped its €150 customs duty exemption on 1 July 2026, charging a flat €3 per item in its place.
So a commercial invoice is no longer a formality you can fill in lazily. It needs a clear description, the right HS code, the country of origin, the real price in a stated currency, and who pays the duty. Get those right and parcels clear. Get them wrong and they sit in a warehouse while your customer waits.
If you sell handmade goods on Etsy, run a small Shopify store, or post prints, parts or samples to customers abroad, this change reached you whether you noticed or not. The courier started asking more questions, some parcels came back, and some customers were hit with charges at the door and asked for a refund.
This guide explains what changed in the US and the EU, what a commercial invoice must contain, why the HS code suddenly decides how much your parcel costs, and the mistakes that get parcels held. You can make a commercial invoice with the same invoice generator you use for any other invoice, as long as it carries the fields below.
The End of Duty Free Parcels
For a long time, both of the world's biggest consumer markets let small parcels in without customs duty. The US allowed up to $800 per person per day under what is known as Section 321, or de minimis. The EU exempted consignments worth up to €150 from customs duty, although it has charged VAT on every import since 2021. Cheap parcels flooded in, and both governments decided the rules had to go.
United States: $800 rule suspended for every country
After first ending the exemption for China and Hong Kong in 2025, the US suspended duty free de minimis treatment for all countries from 29 August 2025, under Executive Order 14324. Goods of any value now pay the duties, taxes and fees that apply to them. A few narrow exemptions remain, including genuine gifts under $100 and personal items brought back by travellers under $200. A sale is not a gift, whatever the label says.
European Union: €150 duty exemption removed
From 1 July 2026, the EU removed the customs duty exemption for consignments up to €150 sold in distance sales to consumers. Until the EU's customs data hub for e-commerce is ready, which is planned for 1 July 2028, a temporary flat duty of €3 per item applies. The European Commission says it is charged per item in a consignment based on tariff classification, not on quantity, and that it falls on the declarant, meaning the seller or the importer, not the consumer.
VAT is a separate charge. All goods imported into the EU have been subject to VAT since 1 July 2021, when the old €22 VAT exemption was removed. Sellers can collect that VAT at checkout and declare it through the Import One Stop Shop, known as IOSS, for consignments up to €150.
Small Parcels by the Numbers
| Figure | Number | Source |
|---|---|---|
| US de minimis parcels in 2015 | 134 million | US Customs and Border Protection |
| US de minimis parcels in 2024 | 1.36 billion, more than 4 million a day | US Customs and Border Protection |
| US $800 duty free rule suspended for all countries | 29 August 2025 | Executive Order 14324, CBP |
| Low value items shipped from outside the EU to EU consumers, 2025 | Almost 5.9 billion | European Commission |
| EU €150 customs duty exemption removed | 1 July 2026 | European Commission |
| EU temporary flat duty | €3 per item, by tariff classification, until 1 July 2028 | European Commission |
| EU €22 VAT exemption on imports removed | 1 July 2021, IOSS for consignments up to €150 | European Commission |
The US growth figure explains why the rules changed. A tenfold rise in nine years meant customs could not look at more than a sliver of what arrived. The response on both sides of the Atlantic is the same: every parcel pays something, and the paperwork has to say exactly what is inside.
Which Document Is Which
Small sellers often mix up the documents that travel with a parcel. They do different jobs, and customs reads them differently.
| Document | What it is for | When you need it |
|---|---|---|
| Commercial invoice | Tells customs what was sold, its value, origin and terms, so duty can be worked out | Every sale shipped across a customs border |
| Pro forma invoice | A preliminary invoice, used as a quote or for goods that are not being sold | Before a sale, or for samples and returns where your carrier accepts it |
| Packing list | What is in each box, with weights and dimensions | Shipments of more than one box |
| Your normal sales invoice | Bills the customer and records the sale for your own taxes | Every sale, domestic or international |
| CN22 or CN23 customs form | The postal customs declaration stuck to the parcel | When you ship through a national post office |
For a simple one box sale, your commercial invoice and your sales invoice can be the same document, provided it carries every customs field. If you want to be clear on the difference between an invoice and a quote, our guide to invoices, receipts and quotes covers it.
Every Field on a Commercial Invoice, Explained
The US spells out what a commercial invoice must contain in federal regulation 19 CFR 141.86, and it must be in English or come with an accurate English translation. Carriers and customs in other countries ask for the same core details. Here is every field worth including, and what goes wrong when it is weak.
| Field | What to write | What goes wrong if it is weak |
|---|---|---|
| Seller | Your business name, full address and contact details | Customs cannot contact you about a question |
| Buyer and ship to address | The customer's name, address, phone and email | The courier cannot reach them to collect duty, and the parcel waits |
| Invoice number and date | A unique number and the date of sale | Values cannot be matched to the order |
| Description of each item | What it is, what it is made of and what it is for, such as "women's knitted wool scarf" | Words like "gift", "parts" or "clothing" cannot be classified and trigger questions |
| HS code | The six digit Harmonized System code, or the longer national code if you know it | Wrong duty, a delay, or in the EU the wrong number of €3 charges |
| Country of origin | Where the goods were made, which may differ from where you ship from | The wrong duty rate, since rates depend on origin |
| Quantity and weight | Number of units and the weight of each line | The parcel weight does not match the paperwork |
| Unit price and total | The real price the customer paid for each item and in total | Undervaluation, which can mean penalties and seized goods |
| Currency | The currency of the sale, such as USD, EUR or GBP | Customs cannot value the goods with confidence |
| Shipping and other charges | Freight, insurance and packing listed separately | The customs value is worked out on the wrong base |
| Incoterms | Who pays duty and delivery, most often DAP or DDP | Your customer gets a surprise bill at the door |
| Reason for export | Sale, sample, gift, repair or return | A sale marked as a gift is a false declaration |
| Declaration and signature | A statement that the information is true and correct, signed and dated | Some carriers reject the invoice or hold the parcel |
Describe it like you are telling a stranger what is in the box. "Handmade ceramic coffee mug, stoneware, 350 ml" clears. "Mug" might. "Homeware" will probably not. The more specific the description, the less reason anyone has to open the parcel.
Why the HS Code Now Costs Money
The Harmonized System is the shared code list customs offices around the world use to classify goods. The first six digits are the same in every country that uses it. The US adds digits to make a ten digit code, and the EU uses eight digits for its combined nomenclature and ten for its TARIC tariff.
The US regulation does not list the HS code as a required invoice field, but in practice you need it. Carriers ask for it on their electronic customs forms, brokers use it to calculate duty, and in the EU it now decides how much duty your parcel pays. Because the €3 is charged per item by tariff classification, a parcel with three identical scarves pays €3, while a parcel with one scarf, one mug and one print pays €9. Same box, same customer, three times the duty.
You can look up codes on the US Harmonized Tariff Schedule search or your own customs authority's tariff tool. Classify each product once, write the code into your product list, and it goes on every invoice after that without thought.
Who Pays: DAP or DDP
Incoterms are standard trade terms published by the International Chamber of Commerce, and the current version is Incoterms 2020. For small parcels, two of them cover almost every sale.
| Term | What it means | Who pays duty and import tax | What your customer experiences |
|---|---|---|---|
| DAP, Delivered at Place | You deliver to the address, the buyer handles import | The buyer | A bill from the courier before the parcel is handed over |
| DDP, Delivered Duty Paid | You deliver with all import costs already paid | You, the seller | The parcel just arrives, with nothing to pay |
DAP keeps your price lower but moves the surprise to your customer, and a surprise bill is one of the main reasons international buyers refuse parcels or ask for refunds. DDP costs you more up front but feels like a normal domestic delivery. Many small sellers now build duty into their prices for their main markets and ship DDP there, and use DAP only for occasional orders elsewhere. Whichever you choose, say it on the invoice and on your shop's shipping page.
Two Worked Examples
A US maker sells to a customer in Germany
An American ceramicist sells one handmade mug and one wool scarf to a customer in Berlin, a total well under €150. Under the new EU rules the parcel carries two items by tariff classification, so the flat duty is €3 × 2 = €6. VAT is charged on top at the German standard rate of 19%. If the seller is registered for IOSS, they collect that VAT at checkout and the parcel clears quickly. If not, the customer usually pays the VAT and a handling fee to the courier before delivery. Who pays the €6 depends on who declares the goods, which is the seller when they use IOSS or ship DDP.
A Canadian candle maker sells to a customer in Ohio
Before 29 August 2025, a $120 order of candles would normally have entered the US duty free under the $800 rule. Now it does not. Duty depends on the HTS code for candles and on the country of origin, and US tariff rates have changed often since 2025, so the seller should check the current rate before quoting a delivered price. The carrier will usually handle the customs entry and may add a brokerage fee. With a clear description, the right code, "Canada" as origin and the real price, the parcel clears. Without them, it waits.
Never mark a sale as a gift to avoid duty. The US gift exemption covers genuine gifts under $100, not goods someone paid for. Customs can compare the declared value with what the item sells for online, and a false declaration can lead to penalties and seized goods, and can flag your future parcels for inspection.
Why Parcels Get Held
Most delays come from the same few problems on the invoice. Fix these and most of your parcels will move straight through.
| Problem on the invoice | What customs sees | The fix |
|---|---|---|
| Vague description such as "gift" or "parts" | Goods it cannot classify | Name the item, its material and its use |
| No HS code, or a wrong one | A classification it has to work out itself | Look up the code once per product and reuse it |
| Value lower than the real price | Possible undervaluation | Declare the price the customer actually paid |
| Missing country of origin | No way to apply the right duty rate | State where the goods were made |
| No currency shown | An amount it cannot value | Add the currency code next to every price |
| Figures that differ from the order or payment | Paperwork that does not add up | Use the same numbers everywhere |
| No phone or email for the buyer | An importer it cannot reach about duty | Always include the buyer's contact details |
Checklist Before You Ship
- Classify every product you sell once, and keep the HS code and country of origin in your product list.
- Decide DAP or DDP for each market you sell into, and say so on your shipping page.
- For EU customers, decide whether to register for IOSS so VAT is collected at checkout rather than at the door.
- Create the commercial invoice with the buyer's full contact details, a specific description, the code, origin, quantity, weight, price and currency.
- List shipping and insurance separately, and write the reason for export as a sale.
- Sign and date the declaration, attach copies to the parcel or upload them to your carrier, and keep a copy with the order.
If you sell abroad regularly, our guide to invoicing international clients covers currencies and payment terms, and the currency converter helps you price in your customer's currency.
Frequently Asked Questions
What is a commercial invoice?
It is the document customs uses to identify goods crossing a border and work out the duty. It lists the seller and buyer, a detailed description of each item, its HS code, country of origin, quantity, price and currency, the trade terms, and a signed declaration that the details are true.
Is the US $800 de minimis rule really gone?
Yes, for commercial shipments. The US suspended duty free de minimis treatment for all countries from 29 August 2025. Goods of any value now pay the duties, taxes and fees that apply to them. Narrow exemptions remain for genuine gifts under $100 and personal travel items under $200.
How does the EU €3 duty work?
From 1 July 2026, goods in consignments worth €150 or less sold to EU consumers pay a flat €3 customs duty per item, counted by tariff classification rather than by quantity. Three identical items count once, three different kinds of item count three times. The European Commission plans to replace it with normal duty rates from 1 July 2028.
Do I still need to charge VAT on small parcels to the EU?
Yes. VAT has applied to all goods imported into the EU since 1 July 2021, when the €22 VAT exemption ended. The €3 customs duty is an extra charge on top. Sellers can collect the VAT at checkout through the Import One Stop Shop for consignments up to €150.
Do I need an HS code on my invoice?
In practice, yes. The US regulation does not list it as a required field, but carriers ask for it on their customs forms and brokers use it to calculate duty. In the EU the €3 flat duty is counted per tariff classification, so the code directly affects what your parcel costs.
Should I ship DAP or DDP?
DDP means you pay duty and import tax so your customer pays nothing on delivery. DAP means your customer pays them to the courier before the parcel is handed over. DDP usually leads to fewer refused parcels and refunds, so many sellers use it for their main markets and build the cost into their prices.
Can I mark a parcel as a gift to avoid duty?
Not if the customer paid for it. Gift exemptions cover genuine gifts, such as the US exemption for gifts under $100. Marking a sale as a gift is a false customs declaration and can lead to penalties, seized goods and more inspections of your future parcels.
The Bottom Line
The era of sending small parcels abroad with a one word description is over. The US ended its $800 duty free rule for every country on 29 August 2025, and the EU replaced its €150 exemption with a €3 per item duty on 1 July 2026. A good commercial invoice is now what decides whether a parcel clears in hours or sits for a week.
Write a real description, add the HS code and country of origin, declare the real price in a stated currency, and choose DAP or DDP on purpose. Do it once per product, and every invoice after that takes a minute.
Add your products, prices, currency, HS codes and country of origin, and download a clean PDF to send with your parcel. Your first invoice is free, with no sign up.
Create an InvoiceRelated Guides
Sources
- US Customs and Border Protection. CBP ready to enforce end of de minimis loophole. cbp.gov
- US Customs and Border Protection. Fact sheet: suspension of duty free de minimis treatment. cbp.gov
- European Commission. Guidance and legal text on the temporary flat fee on low value imports, which will apply until 1 July 2028. taxation-customs.ec.europa.eu
- European Commission. The €150 customs duty exemption threshold to be removed as of 2026. taxation-customs.ec.europa.eu
- European Commission. VAT e-commerce One Stop Shop and IOSS. vat-one-stop-shop.ec.europa.eu
- 19 CFR 141.86, contents of the commercial invoice, via the Legal Information Institute. law.cornell.edu
- International Chamber of Commerce. Incoterms 2020. iccwbo.org
- US International Trade Commission. Harmonized Tariff Schedule search. hts.usitc.gov
"According to FreeInvoicePDF.org's 2026 commercial invoice guide for small sellers, the US suspended its $800 duty free de minimis rule for all countries on 29 August 2025, after de minimis parcels grew from 134 million in 2015 to 1.36 billion in 2024 (CBP). The EU removed its €150 customs duty exemption on 1 July 2026 and charges a temporary flat duty of €3 per item, counted by tariff classification, until 1 July 2028. A commercial invoice should state a specific description, HS code, country of origin, real price and currency, and the Incoterms, usually DAP or DDP."
Source: FreeInvoicePDF.org. Commercial Invoice Guide for Small Sellers (2026). https://freeinvoicepdf.org/blog/commercial-invoice-small-sellers-2026/