Customs value of imported goods: how to calculate it, what to add and what to leave out

MONDAY, 9 NOVEMBER 2026

Price paid, moulds, packing, royalties, freight and insurance to the border: the rules of Articles 70-74 of the Union Customs Code, the excluded items and a worked example with 5,000 water bottles imported from China.

The customs value of imported goods is the base for import duty and import VAT: you start from the price paid to the supplier and add only the items listed in Article 71 of the Union Customs Code, such as moulds, packing, licence fees, freight and insurance to the EU border. Everything else, from buying commissions to transport inside Italy, stays out.

It looks like a formality, but it is where many reassessments start: a forgotten cost raises the duty owed, a cost added by mistake makes you pay twice. This guide sets out the rules of Regulation (EU) 952/2013, the Union Customs Code, and of its implementing acts, and applies them to a worked example with figures.

Customs value of imported goods: what it is and why it matters

Most EU duties are ad valorem, meaning a percentage of the value of the goods. The customs value is that value, expressed in euro and calculated under rules shared by every EU country. The rules sit in Articles 69 to 76 of the Customs Code, in Delegated Regulation (EU) 2015/2446 and in Articles 127 to 146 of Implementing Regulation (EU) 2015/2447, and they derive from the international agreement on Article VII of the GATT.

The customs value does not only drive the duty. It is also the first building block of the import VAT base, to which the duty itself and the forwarding costs to the destination in Italy shown on the transport document are added. A mistake on the value therefore carries through to both taxes.

The starting point: the price actually paid

The main method is the transaction value of Article 70: the price actually paid or payable for goods sold for export to the Union, adjusted where necessary. The price covers every payment the buyer makes, or must make, to the seller or to a third party for the seller's benefit as a condition of the sale.

This means the value does not always match the total on the commercial invoice. A deposit paid separately, a tooling charge billed on a separate document or a payment to a third company named by the supplier are part of the price if they are tied to the sale of those goods. For invoices in dollars or yuan you use the monthly customs exchange rate, as explained in our guide to calculating import duty.

The four conditions for using the invoice price

The transaction value applies only if all four conditions of Article 70(3) are met. If even one is missing, you move to the secondary methods:

• no restriction on the buyer's use or resale of the goods, apart from those imposed by law, those limiting the geographical area of resale and those that do not substantially affect the value;
• the sale or the price is not subject to conditions or considerations whose value cannot be determined;
• no part of the proceeds of a later resale goes back to the seller, unless it can be added to the value;
• buyer and seller are not related, or the relationship did not influence the price.

The last condition mostly concerns groups with subsidiaries in Asia. For a company buying from an independent supplier in China, the first three are almost always met, but it is worth reading exclusivity and licence agreements: that is where the conditions that change the calculation tend to hide.

What to add to the price: the Article 71 list

Article 71 lists the items to be added to the price when they are borne by the buyer and are not already in the invoice. The list is closed: paragraph 3 says that only these items, and nothing else, are added to the price.

• Point (a): commissions and brokerage, except buying commissions; the cost of containers treated as one with the goods; the cost of packing, both materials and labour.
• Point (b): goods and services supplied by the buyer free of charge or at reduced cost and used to make the goods, such as materials and components, moulds and tools, materials consumed, and engineering, design and drawings done outside the Union.
• Point (c): royalties and licence fees related to the goods that the buyer must pay as a condition of sale.
• Point (d): the share of proceeds from later resale or use that goes to the seller.
• Point (e): transport, insurance, loading and handling up to the place of entry into the Union, which for sea freight is the first EU port of arrival.

Royalties are the trickiest item. Under Article 136 of the Implementing Regulation, the payment is a condition of sale also when the goods cannot be bought without paying the owner of the trademark or patent: for importers of products carrying licensed logos, the fee can enter the customs value even if the supplier does not collect it.

Moulds, tools and design supplied to the factory

When importing customised products, such as promotional items, point (b) is the one most often forgotten. The mould for a custom shape, the plate for printing the logo or the artwork paid for by the buyer are part of the value of the goods made with them, even when they are invoiced separately or paid only once.

Article 135 of the Implementing Regulation sets out how to count them. The value is the purchase price, meaning everything the buyer paid to obtain them; if the buyer or a related company made them, the production cost. If they had already been used, depreciation is taken into account. The value is apportioned pro rata over the imported goods. Research costs and preliminary design sketches stay out, while design work done outside the Union and needed for production is added.

What stays out of the customs value

Article 72 lists the items not to be included. Under the Union Customs Code they no longer need to be shown separately on the invoice, but you must be able to document them:

• transport after entry into the Union, such as the leg from the port of Genoa to the warehouse;
• construction, installation, assembly, maintenance or technical assistance started after entry into the Union;
• interest under a written financing agreement for the purchase, if the rate is in line with market rates and the goods are sold at the declared price;
• buying commissions paid to your own agent, rights to reproduce the goods in the Union and distribution rights that are not a condition of sale;
• duties and other charges payable in the Union on import or sale, even when delivery is DDP.

Buying commissions deserve attention. Those paid to an agent who works for the buyer, finds suppliers and follows orders stay out; those paid to an intermediary acting for the seller are selling commissions and are added. What counts is the real role, not the name written in the contract.

When customs reject the price: reasonable doubts and secondary methods

If the declared price looks low compared with values of similar transactions, Article 140 of the Implementing Regulation lets customs ask for additional information. If the doubts remain, customs may decide that the transaction value cannot be used, after hearing the importer and with a reasoned decision.

At that point Article 74 sets a strict order of secondary methods: the transaction value of identical goods, then of similar goods exported at or about the same time, then the deductive method based on the resale price in the Union, then the computed value based on production costs, profit and transport. The last two can be swapped at the declarant's request. If none works, the fall-back method remains, but it cannot use minimum, arbitrary or fictitious values, nor the price on the domestic market of the exporting country (Article 144 of the Implementing Regulation). This is why it pays to keep orders, contracts, proof of payment and price lists: they are the tools to prove that the price is real.

A worked example: 5,000 water bottles from Ningbo

The example is hypothetical, with rounded figures. An Italian company buys 5,000 steel water bottles with a logo, at a FOB Ningbo price of 4.20 dollars each, that is 21,000 dollars. It pays the supplier a separate 1,800 dollars for the custom-shape mould, used only for this order, and 600 dollars for gift boxes invoiced separately. It also pays 3% of the price, 630 dollars, to its own buying agent in China. Sea freight and insurance to Genoa cost 1,150 dollars; transport from the port to the warehouse 450 euro.

The customs value adds up price, mould, packing, freight and insurance: 24,550 dollars. At a hypothetical rate of 1.16 dollars per euro that is 21,163.79 euro. The buying commission and the transport in Italy stay out. At a hypothetical duty rate of 3% the duty is 634.91 euro. The VAT base is 21,163.79 plus 634.91 plus 450 euro of transport to destination, that is 22,248.70 euro, and VAT at 22% comes to 4,894.71 euro. Had the mould been forgotten, the declared value would have been 1,551.72 euro lower: a gap customs can challenge in a later audit, recovering the missing duty and VAT.

Customs value of imported goods in brief: the checklist

Before each import declaration it is worth checking these points with your customs broker:

• whether the price includes every payment made to the supplier or to third parties on its behalf, including deposits and separate invoices;
• whether moulds, tools, printing plates, components or design supplied by the buyer have been added and apportioned over the goods;
• whether there are royalties or licence fees tied to the goods and whether paying them is a condition of sale;
• whether freight and insurance run only to the first EU port or airport and whether later costs are documented;
• whether the commissions paid are really buying commissions and whether the agent agreement proves it.

With La Merce, the customs value of a custom order is prepared before shipment: moulds, special packing and commissions are separated and documented with the supplier, so the declaration includes the 1,800 dollars of the mould where they belong and leaves out what Article 72 excludes.

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