Customs Clearance and Incoterms for China–US Imports: Complete Guide

Customs & Incoterms · Complete guide · Reviewed November 14, 2026 · 8 minute read

Container port at dawn with stacked shipping containers and a cargo vessel, customs documents theme — Illustrative AI-generated image.

Customs clearance and Incoterms decide who files what, who pays duty and when goods can leave the port. The seller and buyer split responsibilities under the chosen Incoterm, and the import moves only when the invoice, packing list, bill of lading and entry data all agree.

1. Clearance is a document match, not a formality

Clearance is the point where the shipment stops being a booking and becomes an import. The importer, or the broker acting for the importer, files an entry with U.S. Customs and Border Protection (CBP) and presents the commercial invoice, packing list and transport document. CBP checks the filing against the goods, and the goods are released only when the entry is accepted and any duty and fees are settled. A shipment can sit at the port long after the vessel has berthed if the paperwork is incomplete or inconsistent.

The most common cause of a hold is a mismatch between documents. The invoice value, the packing list quantities, the bill of lading description and the entry data must describe the same goods in the same way. A product described one way on the invoice and another way on the bill of lading invites questions, and a value that does not match the payment record invites more. Check every document against the others before the vessel sails, because corrections after arrival are slow and the cargo cannot move while they are pending.

2. Incoterms decide who does what — and who pays duty

Incoterms are the standard trade terms published by the International Chamber of Commerce (ICC) that allocate transport, risk and customs responsibilities between seller and buyer. Under EXW (Ex Works), the buyer collects the goods at the seller's premises and handles almost everything from there. Under FOB (Free on Board), the seller delivers the goods on board the vessel at the origin port, and the buyer takes over from that point. Under DAP (Delivered at Place), the seller delivers the goods to the named destination, ready for unloading, while the buyer handles import clearance and duty. Under DDP (Delivered Duty Paid), the seller also handles import clearance and pays the duty.

The choice changes the quote as much as it changes the work. An EXW price covers the goods at the factory gate; a DDP price is expected to cover transport, import clearance and duty as well. That is why two quotes for the same goods can look far apart: they may simply be priced under different terms. Compare quotes only after confirming which Incoterm each one uses, and confirm in writing what each side is expected to arrange, file and pay.

Incoterms allocate responsibilities; they do not decide whether the goods are allowed in. A DDP shipment still needs the right product data, classification and certificates, and the seller acting as importer still needs an importer of record able to file the entry. Terms also do not remove the need for insurance or for a written agreement on what happens if the cargo is held, examined or refused. Read the term together with the contract, not instead of it.

3. The import document set

The core set is small and every item matters: the commercial invoice stating the seller, buyer, goods, value and terms; the packing list stating quantities, weights and carton marks; the bill of lading or air waybill as the transport document; and the entry filing itself. For ocean shipments to the United States, the Importer Security Filing (ISF) must also be filed before the goods are loaded at origin. Missing or late filings can lead to penalties and holds, so the filing plan should be settled before the cargo leaves the warehouse.

Regulated goods add documents to the set. Wood packaging must meet the ISPM 15 mark where the rule applies. Wood products may need a Lacey Act declaration with supplier data. Some goods need a certificate, a test report or a prior notice, depending on the product and the agency involved. Confirm the extra documents product by product, because a requirement that applies to one shipment may not apply to the next, even for the same buyer.

The bill of lading deserves its own check. Consignee and notify party are different roles: the consignee is the party entitled to take delivery, while the notify party is the party told that the goods have arrived. An original bill of lading, a sea waybill and an express release each work differently at destination, and the wrong choice can leave the cargo undeliverable even after customs release. Review the draft bill of lading line by line — names, marks, piece count, weight and description — before it is issued.

4. Classification, duty and landed cost in general terms

Duty starts with classification. Every imported product is assigned a Harmonized Tariff Schedule (HTS) code, and the code, together with origin and value, decides the duty treatment. Classification is a product question, not a guess: the material, function and construction of the goods decide the code, and a wrong code can mean the wrong duty and a correction after entry. Ask the supplier for the full product specification and confirm the classification with the broker before the first shipment, not after it arrives.

Landed cost is the sum of the goods, the freight, the duty and the destination charges, and it is the only cost figure that matters for a buying decision. A low product price can be undone by high freight, and a low freight quote can be undone by destination charges at the U.S. port. Destination charges for LCL (less-than-container-load) shipments, terminal handling and delivery all sit outside the ocean freight rate, so ask for them in writing as part of the quote and check which charges are included and which are billed separately.

Treat every landed-cost figure as an estimate until the entry is filed. Duty depends on the classification and the value declared, freight depends on the packed dimensions and the route, and destination charges depend on the port and the handling the shipment needs. A quote that does not state its Incoterm, its classification basis or its excluded charges cannot be compared with one that does. Keep the written quote with the shipment file and check the final invoice against it.

5. Release, holds and recordkeeping

Arrival does not mean delivery. The cargo becomes deliverable only after both customs release and carrier release are in place, and the two do not always arrive together. An arrival notice from the carrier or forwarder is the trigger to check both: who holds the transport document, what is still outstanding, and which release is pending. The importer should confirm these points before booking a pickup, because the terminal will not release cargo on a promise.

A hold can come from several directions. CBP may examine the cargo, ask for more data or hold it pending a review. The carrier may hold it for unpaid charges. A document mismatch can hold it until the correction is filed. Each hold has a different owner and a different fix, so the first step is always to find out which hold applies and who must act. Keep the broker, the forwarder and the supplier in the same conversation while a hold is open, so the same facts reach every party.

Recordkeeping is part of the import, not an afterthought. U.S. rules require the importer to keep the entry records — invoice, packing list, transport document, entry summary and supporting data — for a set retention period, and to produce them if CBP asks. Split shipments need the same care: each lot should carry its own aligned set of documents, and the records should show how the lots relate to the original order. A shipment file that is complete at the time of entry is far easier to defend than one rebuilt later.

6. How to request a customs and Incoterms review

A useful review request reads like a shipment file, not a question: product and packing, origin and destination, the Incoterm under discussion, the HTS code if known, and any regulation that may apply. With that data, a forwarder or broker can check the document set, the filing needs and the cost components and confirm what is still missing — without it, any answer is only a general estimate.

Treat every reply the same way: confirm the scope in writing — which term applies, who files the entry, who pays the duty, which charges are separate, and what happens if the cargo is held or examined. An inquiry or estimate is not a filing, and a quote is not a customs decision. Keep the written confirmation with the shipment file and check it against the entry draft before the goods are shipped.

Customs and Incoterms guides

Related guides

Official references

Note: This guide provides general logistics planning information. It is not legal, customs, tax, safety or carrier acceptance advice. Requirements, services and schedules depend on the actual goods, route, contract, provider and current rules. Verify shipment-specific questions with the responsible carrier, customs broker or authority before dispatch.

For a route-specific logistics review, provide the product, origin, destination, packed dimensions, weight and ready date.

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Frequently asked questions

What is the difference between customs release and carrier release?

Customs release means CBP has accepted the entry and the goods may leave customs control; carrier release means the carrier will hand the cargo over, usually once the transport document is surrendered and outstanding charges are settled. The cargo becomes deliverable only when both are in place, and they do not always arrive together.

Does DDP mean the seller handles everything at destination?

Under DDP the seller handles import clearance and pays the duty, but the seller still needs the right product data, classification and certificates, and an importer of record able to file the entry. Terms allocate responsibilities; they do not decide whether the goods are allowed in, and they do not remove the need for insurance or a written agreement on holds and examinations.

Which documents should match before an import is filed?

The commercial invoice, packing list, bill of lading or air waybill and the entry data should all describe the same goods, quantities, values and parties. A mismatch between any two invites questions and can hold the cargo, so check every document against the others before the vessel sails.