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Export Invoices: How to Properly Value Free Samples

On: January 20, 2020    |    By: Catherine J. Petersen Catherine J. Petersen    |    3 min. read

Export Invoices: How to Properly Value Free Samples | Shipping SolutionsDear Cathy,

I found an article online that you wrote regarding the value on a commercial invoice titled Repaired Goods: Import and Re-Export. I am a transportation coordinator for my current employer, and there has always been a question in my mind that I'm not sure how to answer.

Many times we ship items to customers free of charge as an incentive for a bulk order or just as samples for them to try out. I've always thought that their actual value must be listed on the commercial invoice whether we charge the customer or not. Usually when I do that, however, I always make a notation on the commercial invoice stating there was no charge to the customer. The value was for customs use only.

Is that the correct approach to a shipment of this nature? Thanks in advance for your assistance.

All the best,
Storm Clouds in Minnesota


Commercial InvoiceDear Storm Clouds in Minnesota:

You are on the right track. There is guidance available in the Foreign Trade Regulations regarding value to be reported with your Electronic Export Information (EEI) through AESDirect on the ACE portal. This will supplement your understanding of valuation. These resources are like an umbrella in rainstorms!

The buyer may want you to state a lower value to reduce their obligation for duty payment, but that is incorrect from the perspective of the U.S. government's regulations as well as the regulations of the buyer's country.

If the products being shipped are indeed samples, then have the packaging and the packing marked with an indication that the goods are for testing and sample purposes, not intended for resale.

If the sample has been compromised in any way to ensure that the product will not be resold in the market of the customer, then the value is nominal or zero. One example is a t-shirt that has been slit up the front or back, so it cannot be worn.

Thanks for your question! All the best (and stay out of the rain)!

Cathy


In the webinar What You Need to Know About Exporting Samples and Repaired Goods, Robert Imbriani explains more about describing and assigning a value to samples on your commercial invoice. Watch the clip below to learn more and then watch the entire webinar here.


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This article was first published in August 2011 and has been updated to include current information, links and formatting.

Catherine J. Petersen

About the Author: Catherine J. Petersen

In 1992, Catherine Petersen founded C J Petersen & Associates, LLC, a research, instruction and consulting firm located in St. Paul, Minnesota, USA. She has designed documentation and procedure manuals for exporters and has authored/co-authored five books.

Ms. Petersen has had day-to-day practical experience at a freight forwarder, a trading company, and an ocean carrier; she has been active in international business since 1980. Her background led her to develop C J Petersen & Associates, LLC, which is a collaborative consultancy that works with clients to identify compliance gaps and to resolve them. Ms. Petersen retired in 2022.

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