Import documents by incoterm: who provides each one for a container from China

The documents customs asks for when a container arrives from China are the same under every incoterm; what changes is who provides each one. The seller always issues the commercial invoice and the packing list, the shipping line issues the bill of lading, and the importer lodges the import declaration with its EORI number. The incoterm decides who books the sea freight, who clears export in China and who clears import and pays duties in the EU: the buyer under every term except DDP.

Your checklist by incoterm

With FOB, the term selected when the checklist opens, the buyer has four items: booking the freight, its EORI number, the import declaration and the duties. Switch to DDP and all four move to the seller, which becomes the importer and needs its own EORI number in the EU. Pick CBAM goods and one more row appears: the authorised declarant.

What the incoterm changes, and what it doesn’t

The International Chamber of Commerce (ICC) Incoterms 2020 rules split costs, risks and formalities between seller and buyer. What they do not do is say which documents the seller must hand over for clearance in the buyer’s country; that comes from the customs rules at destination, as the US International Trade Administration points out. That is why the list above combines two sources: the ICC split and what EU customs asks for.

The export and import columns (import includes paying the duties) come from the ICC guidance note on tariff risk (April 2025): EXW is the only rule where the buyer clears export, and DDP the only one where the seller clears import and pays the duties. The buyer books the freight under the F rules and the seller under the C and D rules (ICC Academy: FOB and FAS; C and D rules). On insurance, the ICC rules set a level of cover in CIF and CIP: under CIF the default minimum is Institute Cargo Clauses (C), and higher cover can be agreed. In the rest of the table, insurance is left to the contract.

Since 2020, FCA has one particular feature: if a bank asks for a bill of lading with an on-board notation, the parties can agree that the buyer instructs the carrier to issue it to the seller once the goods are loaded (ICC).

The documents, one by one

Everything below comes from the European Commission’s guide for importers on Access2Markets, unless another source is cited.

• Commercial invoice. Always required for customs clearance. The exporter prepares it, with no set form, and it carries at least the parties, the goods, quantities and values, the currency, the payment terms, the incoterm and the means of transport. The original and at least one copy are submitted; it can be in any language, though English is recommended. Its price is where the customs value starts; if your purchase price tracks copper, see the metal-indexed price list guide.
• Packing list. Customs uses it as the inventory of the cargo: type and number of packages, contents, marks, net and gross weight and measurements. The exporter prepares it too.
• Bill of lading. Issued by the shipping line. It acknowledges the goods were received on board, evidences the contract of carriage and conveys title to the goods.
• Certificate of origin, if required. Non-preferential certificates are normally issued by chambers of commerce. Preferential certificates only apply where there is a preferential agreement with the country of origin.
• Insurance. The insurance invoice is only needed for clearance when the premium is not shown on the commercial invoice.
• Entry summary declaration (ENS). The carrier lodges it at the first customs office of entry into the EU; for container cargo, at least 24 hours before loading starts in the port of origin. It uses data from the exporter’s documents.
• EORI number. Mandatory for any customs operation in the EU. It is assigned by the customs authority of the country where the operator is established; an operator from outside the EU gets one in the country of its first operation (European Commission, DG TAXUD).
• Import declaration. In Spain it is the DUA, lodged with the customs department of the Agencia Tributaria directly or through a customs representative (AEAT). Customs value data (price, freight, insurance, links between buyer and seller) now go inside the H1 import declaration; the old DV1 form is no longer used.
• Release. The goods sit in temporary storage under customs supervision, for no longer than 90 days, until a procedure is assigned. They are released for free circulation once the applicable duties and charges are paid and any licences and certificates presented.

Goods under CBAM or anti-dumping

If you import goods under the Carbon Border Adjustment Mechanism (CBAM), such as iron, steel or aluminium, there is one more requirement. Under the CBAM Regulation as amended by Regulation (EU) 2025/2083, above 50 tonnes of CBAM goods a year per importer, customs does not let anyone but an authorised CBAM declarant import them (Articles 2a and 25(1) of the consolidated text). That importer is the buyer under every term except DDP. How the threshold adds up is in the CBAM 50-tonne threshold guide.

Anti-dumping duties are set measure by measure, in the regulation that imposes them, and this checklist does not add documents for them. The Chinese copper tube case is in the copper tube anti-dumping guide.

Five checks before the container sails

1. The incoterm, with its version and place, on the invoice. The commercial invoice carries the terms of delivery under the incoterm (European Commission), and it is worth always stating the version, “Incoterms 2020” (ITA).
2. The seller’s documents, in time for the ENS. The carrier lodges the entry summary with data from the invoice and the bill of lading, at least 24 hours before loading.
3. Under DDP, the seller’s EORI. The seller is the importer and needs an EU EORI number to lodge the declaration.
4. Under CIF, the insurance cover. The default is the minimum, Clauses C. And if the premium is not on the commercial invoice, customs asks for the insurance invoice.
5. Under FCA with a letter of credit, the on-board bill of lading. If the bank requires it, agree that the buyer instructs the carrier to issue it to the seller.

You will find more guides on pricing, rules and containers in the guides index.

How HeavyDeals keeps the file

HeavyDeals, the commercial system for industrial distribution, opens a file for each order with its incoterm. For each of the 11 Incoterms 2020 rules it shows which documents the operation needs and who provides each one (seller, buyer or a third party such as the shipping line), lets you upload the ones that come from outside, like the bill of lading, straight from their row, and generates the three the seller issues: commercial invoice, packing list and certificate of origin. For CBAM goods it adds up each importer’s tonnes in the year against the 50-tonne threshold. See how it works.

Every figure and rule was checked against the sources above, on the date shown next to each; last review of this guide: 11 October 2026. The examples use illustrative figures, not today’s quotes. This is not legal or tax advice. Written with the help of AI and reviewed by the HeavyDeals team.