Importers often use the commercial invoice or a CIF figure as customs value without reviewing freight, insurance, packing, royalties, assists, commissions and related-party pricing. An incorrect value affects not only import duty but also other import taxes, landed cost and post-clearance compliance. This article explains the legal basis, transaction-value conditions, the six sequential methods and the evidence needed before declaration.

B2B logistics operational guide · Updated 17 July 2026

QUICK FACTS

Invoice price is not automatically customs value

The commercial invoice is only the starting point. Conditions, additions, deductions and evidence must be tested.

Transaction value comes first

The primary basis is the price actually paid or payable for the imported goods, adjusted as required.

Six methods apply sequentially

The importer cannot select the lowest result. A later method is used only when the earlier one cannot determine the value.

The first import checkpoint defines the cost boundary

Freight, insurance and related costs must be allocated to the correct transport segment without omission or double counting.

Evidence protects the declared value

Contracts, payments, freight, insurance, royalties, assists and related-party files must form a traceable record.

SCOPE

This article addresses imported goods sold for export to Vietnam and is designed for pre-declaration review, customs value queries and post-clearance self-audits.

Boundary: leased, loaned, donated, free-of-charge, processing, complex royalty, related-party and change-of-use transactions require declaration-specific analysis.

KEY TERMS

Term	Meaning	Operational role
Customs Value	Value determined for customs control, taxation and statistics.	Tax base for import duty and potentially other import taxes.
Transaction Value	Price actually paid or payable for the imported goods after required adjustments.	Primary valuation method.
Price Actually Paid or Payable	All direct or indirect payments to, or for the benefit of, the seller.	Extends beyond the invoice face value.
Additions	Buyer-borne, import-related and quantifiable items not already included in the price.	Bring the value to the legal import boundary.
Deductions	Separately identified items already included in the price but legally excludable.	Prevent post-import costs or domestic taxes from being overvalued.
Assist	Goods, tools, moulds, designs or services supplied free or at reduced cost for production.	May require objective allocation and addition.
Related Parties	Buyer and seller connected under statutory relationship tests.	Does not automatically reject transaction value, but price influence must be addressed.
First Import Checkpoint	The legal boundary for import-related transport costs.	Must be established from the route and records, not assumed from Incoterms alone.

LEGAL BASIS OF IMPORT CUSTOMS VALUE

For imported goods, the legal basis is the actual price payable up to the first import checkpoint. Customs value is therefore not automatically FOB, CIF or the invoice total. The importer must establish whether transaction value is acceptable, what is already included, what is paid outside the invoice and what post-import costs can be separately excluded.

Starting data	Required question	Risk if misread
Commercial Invoice	Does the price include freight, insurance, packing, royalties or assists?	Omitted or duplicated adjustments.
Incoterms	What cost scope is intended, and do the actual records match it?	Treating CIF or FOB as a complete valuation answer.
Contract and payment	Are there indirect payments, offsets, rebates, credit notes or third-party payments?	Understating the price actually paid or payable.
Logistics records	Which freight and insurance segment reaches the first import checkpoint?	Incorrect allocation of pre- and post-import costs.
Buyer–seller relationship	Are the parties related and did the relationship influence price?	Transaction value challenge.
Royalty/technical agreement	Is the fee related to the goods and a condition of sale?	Failure to add a qualifying royalty.

WHEN TRANSACTION VALUE MAY BE USED

Transaction value requires reliable evidence and satisfaction of the legal conditions. Customs may request supporting documents when records conflict, the price presents a risk signal or a related-party relationship may have influenced pricing.

Test	Compliant indicator	Indicator requiring explanation
Use/disposal restrictions	No unusual restriction materially affecting value.	Contractual restriction distorts the price.
Conditions of sale	No condition whose value cannot be determined.	Price depends on bundled obligations or cross-subsidies that cannot be quantified.
Subsequent proceeds	No resale proceeds revert to the seller, or they are adjustable.	Seller receives an undeclared share of later revenue/profit.
Related parties	No relationship, or evidence that the relationship did not affect price.	Unusually low intercompany price without comparable support.
Objective documents	Contract, invoice, payment, freight and technical records agree.	Missing, altered or untraceable records.

THE SIX CUSTOMS VALUATION METHODS

Order	Method	Primary data	When used
1	Transaction value of the imported goods	Actual price paid/payable plus lawful adjustments.	First method if all conditions are met.
2	Transaction value of identical goods	Accepted value of identical imports at or about the same time.	Method 1 cannot determine value.
3	Transaction value of similar goods	Accepted value of comparable goods with similar materials and functions.	No suitable identical-goods data.
4	Deductive value	Vietnam sale price less allowable profit, general expenses, inland transport and taxes.	Reliable domestic sales data exist.
5	Computed value	Materials, production, profit, general expenses and delivery-to-import-boundary costs.	Reliable producer records are available.
6	Fall-back method	Reasonable, sequential and flexible use of earlier methods based on data available in Vietnam.	Methods 1–5 cannot determine value; arbitrary or minimum values are prohibited.

The deductive and computed methods may be considered in reverse order upon a written request and subject to the applicable rules. Earlier methods cannot be skipped merely because a later method produces a lower value.

COMMON ADDITIONS

Category	Examples	Core condition	Evidence
Selling commission and brokerage	Buyer-paid sales commission or brokerage; excluding a genuine buying commission.	Not in price, related to imported goods and quantifiable.	Agency contract, service invoice, payment.
Containers and packing	Cartons, pallets, retail packaging and packing labour.	Buyer-borne and not included in goods price.	Packing contract, invoice and specification.
Assists	Materials, tools, moulds, designs or engineering supplied free/at reduced cost.	Used to produce the imports and objectively allocable.	BOM, mould contract, issue record, allocation model.
Royalties and licence fees	Trademark, patent, software or other qualifying fees.	Related to the imported goods and a condition of sale under the rules.	Licence agreement, sales contract, payment formula.
Subsequent proceeds	Share of resale revenue or profit accruing to seller.	Directly or indirectly payable to the seller and quantifiable.	Distribution agreement and settlement report.
Freight, handling and insurance to first import checkpoint	International carriage, relevant handling and insurance.	Buyer-borne, not included and objectively evidenced.	B/L or AWB, freight invoice, insurance debit note.

DEDUCTIONS AND ITEMS NOT ADDED

Item	General treatment	Evidence condition	Common error
Freight/insurance after first import checkpoint	May be separated when already included and separately quantifiable.	Segmented scope and price evidence.	Deducting all inland costs without route analysis.
Post-import construction, installation, maintenance or technical assistance	Excluded if post-import and separately identified.	Separate contract, invoice and timing.	Bundled equipment/installation price with no allocation basis.
Vietnam taxes and charges included in the price	Excluded only where legally deductible and separately shown.	Contract/invoice identifies the tax and amount.	Deducting a tax not proven to be included.
Buying commission	Not added if it is a genuine buyer-representation fee.	Buying agency agreement and independent fee.	Label says buying commission but agent effectively represents seller.
Post-import distribution or marketing cost	Normally outside customs value if not a condition of sale or part of price payable.	Separate post-import activity and records.	Deducting a cost that was never included in the price.
Discounts	Considered only under the legal conditions and reliable records.	Transparent contract, timing, policy and payment evidence.	Reducing value based solely on a later credit note.

INTEGRATED TRANSACTION-VALUE EXAMPLE

Technical example: machinery is invoiced FOB at USD 20,000. The buyer pays USD 1,200 international freight, USD 80 insurance and USD 200 packing not included in the invoice. A USD 300 buying commission is documented as genuine; USD 250 domestic carriage after the first import checkpoint is separately identified.

Component	Amount	Treatment	Reason
FOB invoice value	USD 20,000	Starting amount.	Purchase price.
Freight to first import checkpoint	USD 1,200	Add.	Buyer pays and FOB price excludes it.
Insurance to first import checkpoint	USD 80	Add.	Not included.
Packing	USD 200	Add.	Related and buyer-borne.
Buying commission	USD 300	Do not add if fully supported.	Not a selling commission.
Domestic carriage after first import checkpoint	USD 250	Do not add, or separate if included.	Post-boundary cost.
Illustrative customs value	USD 21,480	20,000 + 1,200 + 80 + 200.	Before considering royalties, assists, relationships or other conditions.

Note: this illustrates the mechanism only. The official value depends on the actual first import checkpoint, documents, currency and customs exchange rate for the declaration.

DOCUMENTS AND DATA TO CHECK

Document/data	Issuer/preparer	Purpose	Key reconciliation
Sales contract/PO	Buyer and seller	Price, terms, rebates and royalty obligations.	Goods, model, quantity, Incoterms and pricing conditions.
Commercial Invoice	Seller	Commercial price and components.	Unit price, total, currency, discount and beneficiary.
Payment records	Bank/buyer	Direct, indirect, offset and advance payments.	Amount, beneficiary, invoice reference and deductions.
Packing List/BOM/catalogue	Manufacturer/seller	Goods identity, quantity and assist allocation.	Model, materials, weights and package.
B/L, AWB and freight invoice	Carrier/forwarder	Route, freight, handling and cost boundary.	POL/POD, prepaid/collect, currency and scope.
Insurance certificate/debit note	Insurer/broker	Premium and voyage coverage.	Insured value, route, premium and period.
Royalty/licence agreement	Rights holder/contracting parties	Relationship and condition-of-sale test.	Covered goods, sale condition and calculation formula.
Assist records	Buyer/manufacturer	Value of moulds, designs and supplied materials.	Original value, depreciation and allocation units.
Related-party file	Group/importer	Relationship and price-influence analysis.	Pricing policy, comparables and test values.
Customs valuation declaration/worksheet	Declarant	Method, adjustments and exchange rate.	Consistency with goods declaration and source documents.

VALUATION CONTROL PROCESS

Identify the transaction: sale, donation, lease, processing or internal transfer.
Lock the goods and route: model, quantity, Incoterms, transport mode and first import checkpoint.
Reconstruct the price payable: contract, invoice, payments and indirect consideration.
Test transaction-value conditions: restrictions, sale conditions, subsequent proceeds and relationships.
Build an included/excluded matrix: freight, insurance, packing, royalty, assist, commission and post-import services.
Quantify adjustments: use objective data and a documented allocation basis.
Select the method: use method 1 first; document why each earlier method is unavailable before moving on.
Reconcile taxes: HS code, duty rate, exchange rate and related import taxes.
Retain the audit trail: calculations, records, explanations, approvals and customs feedback.

RISKS AND COMMON ERRORS

Error	Cause	Impact	Control
Using invoice value without adjustment review	No included/excluded analysis.	Under- or overvaluation and tax variance.	Mandatory valuation worksheet.
Double-counting freight/insurance under CIF/CIP	Scope not reconciled.	Overstated value and taxes.	Match Incoterms to invoices and debit notes.
Missing royalty or assist	Procurement, engineering and customs data are siloed.	Reassessment, late-payment interest and post-clearance risk.	Mandatory supplier onboarding questions.
Deducting post-import costs without evidence	All-in price cannot be broken down.	Deduction may be rejected.	Require separated contracts/invoices before import.
Assuming related parties cannot use transaction value	Misreading the relationship test.	Unnecessary switch of method.	Prepare evidence that the relationship did not affect price.
Selecting the lowest method	Ignoring sequential rules.	Value rejection, reassessment and penalties.	Document why each prior method fails.
Treating reference prices as minimum customs values	Confusing risk data with valuation method.	Inconsistent with legal/WTO principles.	Reference data may trigger review; the legal methods determine value.
Ignoring later debit/credit notes	Post-clearance process disconnected from procurement.	Tax and accounting mismatch.	Trigger a supplementary-declaration review when price changes.

LEGAL SOURCES

Instrument/source	Authority – status	Use in this article
Customs Law No. 54/2014/QH13, Article 86	National Assembly; effective 1 Jan 2015, read with current amendments.	Principle that import customs value is the actual price payable up to the first import checkpoint.
Law No. 90/2025/QH15	National Assembly; effective 1 Jul 2025.	Current amendment context for the customs legal framework.
Circular No. 39/2015/TT-BTC	Ministry of Finance; effective 1 Apr 2015.	Six methods, transaction-value conditions, adjustments and valuation records.
Circular No. 60/2019/TT-BTC	Ministry of Finance; effective 15 Oct 2019.	Amends the transaction-value rules, adjustments and alternative methods.
Circular No. 06/2024/TT-BTC	Ministry of Finance; effective 15 Mar 2024.	Repeals Article 24 of Circular 39 and Clause 13 Article 1 of Circular 60; it does not replace the six valuation methods.
Decree No. 167/2025/ND-CP	Government; effective 15 Aug 2025.	Updates customs procedures, inspection and value determination under Decree 08.
WTO Customs Valuation Agreement	WTO framework.	Establishes transaction value as the primary basis and the sequential six-method structure.

Sources reviewed on 17 July 2026. Circular 39/2015/TT-BTC must be read together with Circular 60/2019/TT-BTC and subsequent amendment or repeal instruments. English translations in this article are for operational reference only and are not official legal translations.

FAQ

1. Is customs value always equal to CIF value?

No. CIF may be close to a destination-port cost scope, but included items, the first import checkpoint, royalties, assists, commissions and post-import costs must still be tested.

2. Is a low commercial invoice automatically rejected?

No. A low price can trigger review, but acceptance depends on transaction-value conditions and supporting evidence.

3. Can related parties use transaction value?

Yes, where the relationship did not influence the price or the applicable price tests are satisfied.

4. Is domestic transport in Vietnam included?

The segment to the first import checkpoint must be distinguished from the post-checkpoint segment. Exclusion requires separate, quantifiable evidence.

5. Is a royalty paid after importation added?

Payment timing alone is not decisive. The fee must be tested for relation to the goods and condition-of-sale requirements.

6. May the importer choose another method when records are incomplete?

The six methods must be applied sequentially, with documented reasons why the earlier method cannot determine value.

7. Is a customs reference price a minimum taxable value?

It should not be treated that way. Reference data support risk review; the final value must follow the statutory valuation methods.

APPLICATION NOTE: Customs value depends on the full transaction, route, payment structure, relationship and objective evidence. The numerical example must not be used to finalise a declaration without reviewing the original records.

ELECTRICAL – ELECTRONICS – IT EQUIPMENT

F&B

MACHINERY

HOUSEHOLD GOODS

COSMETICS – PERSONAL CARE