- Identify why the product is moving and preserve the supporting record: sample request, marketing approval, original sale, RMA, repair record, transfer instruction, or other transaction evidence.
- Make one factual invoice line per product type. Include product/material/function wording, quantity, value, currency, origin, and a candidate HS code when required.
- Determine a supportable value basis. Do not leave the value blank or assume the customer price is zero simply because the recipient was not charged.
- Use a concise no-charge explanation that matches the records. For example, write “warranty replacement under RMA 1234” only when the shipment is actually a warranty replacement.
- Prepare the draft in the Commercial Invoice Generator, then run the Invoice Consistency Checker against the packing list and shipment facts.
- For a US-bound shipment, review current CBP invoice-value guidance. For a UK-bound free-charge shipment, review current HMRC free-charge-goods guidance. Do not transfer either market’s rule to another destination.
- Check carrier and destination documentation instructions for the actual service. A postal label, commercial invoice, pro forma invoice, customs declaration, or repair/return record can have different requirements.
- Save the invoice draft, value-basis record, shipment reason, origin evidence, and carrier instruction with the order before dispatch.
Guide
Commercial Invoice for Free-of-Charge Shipments
Prepare a commercial invoice for samples, promotional goods, warranty items, and other no-charge shipments without confusing no sale with zero customs value.
Answer Summary
Preparation checklist
A shipment can be free of charge to the recipient while still requiring a commercial or pro forma invoice and a defensible customs value.
Samples, promotional goods, warranty replacements, gifts, returns, branch transfers, and replacement parts are not interchangeable reasons. The reason, product facts, value basis, and supporting record should agree.
Customs valuation differs by importing market. This guide is a document-preparation workflow, not a universal rule for declaring zero value or an instruction to avoid duty.
Required fields or decision table
Fields to prepare before the document draft
| Field or decision | What to prepare |
|---|---|
| Reason for shipment | State the actual reason: sample, promotional item, warranty replacement, return, repair, gift, branch transfer, or another supported transaction. Do not choose a reason merely to reduce charges. |
| Goods description | Describe each line by product type, material/composition, function, model/SKU, condition, and quantity. “Free goods” and “sample” alone do not identify the article. |
| Value and currency | Enter a supportable value basis and currency. Keep the purchase, production-cost, original-sale, price-list, or comparable-goods record that explains the number. |
| No-charge explanation | Add a brief factual explanation such as “warranty replacement under RMA 1234” or “non-sale product sample,” where the carrier/destination workflow supports it. |
| Country of origin | Record where the goods were manufactured or substantially transformed; do not substitute warehouse, sender, or repair-center location. |
| HS code candidate | Include a candidate only when the carrier or destination workflow asks for it, and verify the applicable national code. A no-charge reason does not classify the product. |
| Parties and references | List exporter, recipient, consignee/importer where applicable, and the order, RMA, sample request, repair, or transfer reference supporting the transaction. |
| Package and document match | Reconcile quantity, weight, value, origin, description, currency, and package count with the packing list, label, order record, and carrier booking. |
Step-by-step preparation
How to prepare the draft
Ecommerce example
How this looks in a seller workflow
A brand sends a stainless steel bottle to an influencer as a product sample without charging the recipient. The invoice does not say only “free sample.” It describes the bottle, quantity, origin, value and currency, and includes a supported “promotional sample, not for resale” explanation when appropriate for the actual carrier/destination process.
A warranty replacement uses a different document trail: the seller keeps the original order, RMA, replacement product details, and a value basis. Neither shipment should be marked as a gift or left with a zero value simply because no new payment was collected.
- Sample: product facts + supporting price/production record + non-sale sample explanation.
- Warranty: replacement product facts + original order/RMA + value basis + replacement reason.
- Return/repair: original export or import record + return/repair reference + current carrier/destination instructions.
Verification checklist
Review the draft before it travels with the shipment
- The shipment reason matches the transaction record and is not being used to disguise a sale or avoid duty.
- Every invoice line identifies the actual product, material/function details, quantity, value, currency, and origin.
- The declared value has a documented basis even when the recipient did not pay for the goods.
- The invoice, packing list, label, order/RMA/sample record, and carrier booking use consistent facts.
- The final carrier and destination rules have been checked for the correct document type and any required wording.
- The seller has retained the source records needed to explain the no-charge transaction and value basis.
Source-backed checks
What external guidance supports this workflow?
- HMRC: Customs valuation for free-charge goodsOfficial UK guidance explaining that free-charge goods still require a customs-value basis and distinguishing such goods from assists.
- CBP: Commercial invoice value guidanceCBP says an invoice needs a value and identifies certain additions that may matter for US imports; this is US-specific guidance.
- Trade.gov: Commercial invoiceOfficial US export guidance on commercial-invoice content and transaction documentation.
- CBP warranty replacement ruling H321592US ruling illustrating that warranty replacement valuation can be fact-dependent and may not use transaction value.
Internal workflow links
Use the same catalog data in the next review step
Common mistakes
What to avoid
- Writing only “free,” “gift,” or “sample” without identifying the actual goods and transaction reason.
- Leaving the customs value blank or using arbitrary zero because no customer payment was collected.
- Using a warranty replacement label for promotional goods, a sale, or an unrelated return.
- Copying one destination’s valuation method into another market without checking the local rule.
- Using a warehouse location as country of origin.
- Letting invoice, packing list, order record, and label disagree on item quantity, value, or description.
Editorial
Editorial review note
Written by the TariffCatalog Editorial Team for ecommerce document preparation workflows. The page is designed as a preparation checklist, not a filing outcome.
Maintained by Ryan Cole, with review focused on ecommerce catalog, document, and source-check workflow clarity.
Document requirements may be required differently by carrier, destination, shipment value, and product facts. Use the methodology, sources, and corrections pages to understand how the page is maintained.
Official source note
References to verify
Use official sources, carrier guidance, postal operator rules, and destination requirements to verify before filing or shipping.
USITC HTS
Use this official source when checking final classification, duty treatment, or customs requirements.
CBPUse this official source when checking final classification, duty treatment, or customs requirements.
EU TARICUse this official source when checking final classification, duty treatment, or customs requirements.
UK Trade TariffUse this official source when checking final classification, duty treatment, or customs requirements.
FAQ
Common questions
Can I put zero value on a free-of-charge commercial invoice?
Do not assume so. A no-charge transaction can still require a customs-value basis. Follow the destination and carrier method and retain records supporting the stated value.
Is free of charge the same as a gift?
No. A gift, sample, warranty replacement, return, and promotional shipment can have different facts and document treatment. State the true reason for the actual shipment.
Do samples need a commercial invoice?
Often they do, depending on the carrier, destination, and shipment channel. Prepare an accurate description, value basis, origin, and quantity instead of relying on the word sample alone.
How should I show a warranty replacement?
Use the actual warranty/replacement reason, identify the replacement product, include a supportable value basis, and retain the original order or RMA record. Verify the destination process before dispatch.
What value should I use for promotional goods?
Use a documented basis appropriate to the destination workflow, such as a supported price, production record, or comparable value where applicable. Do not invent a nominal amount without support.
Does free of charge change the HS code?
No. Classification depends on the goods. A no-charge reason does not change the material, function, construction, origin, or destination tariff review needed for the product.
Disclaimer
TariffCatalog provides informational tools and preparation workflows only. Verify final classification, rates, document requirements, and filing treatment with official sources or licensed professionals.