A supplier from Shenzhen sends a file titled Proforma Invoice: 2,000 pcs, unit price, FOB terms, 100% advance payment. You pay for the shipment, the factory starts production, and a month later, along with the shipping documents, comes the Commercial Invoice—already for 1,940 pcs and a different total amount. The bank saw the payment under the first document, customs will examine the second, and the consolidation warehouse will recount the boxes.
The difference between a proforma and an invoice is not determined by the title in the header, but by who reviews these documents and what is calculated based on them. Every shipment involves three figures: the amount paid, the amount declared, and the actual contents of the boxes. Problems begin when they do not match.
The proforma confirms the agreement, the invoice reflects what was shipped
A proforma invoice (sometimes written as pro forma invoice) is issued by the seller before shipment, and often before production begins. It states what you are ordering, the quantity, price, delivery terms, and the advance payment terms. Based on the proforma, you pay the advance and verify the order against the contract. The numbers in it are preliminary; the factory might produce less than ordered, substitute a model, or adjust the price.
A commercial invoice (often simply referred to in documents as an invoice) is issued by the seller for the batch actually shipped. The EAEU Customs Code classifies commercial invoices as commercial documents alongside specifications and packing lists. Do not confuse it with domestic VAT tax invoices; here, it refers to the seller's bill for the goods. The commercial invoice serves as the basis for entering the goods description, quantity, and price into the customs declaration (CD).
| Attribute | Proforma Invoice | Commercial Invoice |
|---|---|---|
| When issued | Before shipment, often before production | Upon shipment, for the actual batch |
| Figures | Preliminary, subject to change | Final for this specific batch |
| Purpose | To confirm the order and pay the advance | To declare goods and finalize settlements |
| Reviewed by | Buyer, bank (for advance payment) | Customs, bank, warehouse, carrier |
When a client provides us with a document package for clearance, the first thing we check is which document is presented as the invoice. A Proforma header on the document intended for declaring purchased goods is a reason to pause even before filing the customs declaration.
Customs uses the price from the invoice and payments, accepting the proforma only when there is no sale
The Code does not explicitly prohibit submitting a proforma. The list of commercial documents is open, and Art. 108 of the EAEU Customs Code mentions other commercial documents held by the declarant among those accompanying the declaration. However, the customs value under the first method (transaction value) is the price actually paid or payable, and para. 3, art. 39 of the EAEU Customs Code specifies that this is the total amount of all payments made for the goods. The proforma indicates the price agreed upon before production, while the final shipment price is confirmed by the commercial invoice and reconciled with payment records. Even a proforma that matches the final shipment down to the exact unit remains a document of intent, and customs authorities are entitled to request the final invoice.
If the documents fail to support the declared data, customs requests commercial and accounting records and written clarifications from the declarant. This procedure is governed by art. 325 of the EAEU Customs Code. When the information affects duties and taxes, the release period is extended; goods may be released against security, with 60 days granted to submit the required documents. For you, this means funds tied up in collateral security and cargo on hold.
We detailed how the invoice price and delivery terms constitute the customs valuation base for duty and VAT in our guide on how to calculate customs payments. This base is calculated from the commercial invoice and payments; the proforma is not part of this calculation.
Non-sale transactions are a different case. The transaction value method relies on the price of goods sold for export. Samples, gifts, or exhibition displays are not purchased; for customs purposes, the supplier indicates their value on a proforma marked with a non-payment notice, such as “No charge, value for customs purposes only.” Here, the proforma replaces the commercial invoice, which does not exist for free-of-charge shipments.
Purchased goods are declared using the commercial invoice. If the supplier has only provided a proforma, we request the final invoice prior to submitting the declaration, because obtaining it upon a customs inquiry usually takes longer, keeping the shipment on hold.
The three numbers of a shipment must match documentary evidence
Every import shipment involves three figures. The bank monitors how much you paid the supplier or still owe. Customs checks the amount declared in the commercial invoice and customs declaration. The warehouse—and customs officers during an inspection—verifies what is physically inside the packages. The proforma only accounts for the first figure (what the advance payment was for), and only until the commercial invoice is issued.
The amount paid under the contract, declared in the commercial invoice, and verified via the packing list must describe the exact same batch: identical items, quantities, and prices paid or payable. If anything changes, the discrepancy must be supported by documentation—a supplementary agreement, a revised invoice, or a credit note—rather than informal chat messages.
The procedure we recommend to our clients consists of four steps:
- Before paying an advance, verify the models, quantities, prices, and Incoterms in the proforma against the contract or specification.
- Before dispatch, request a draft invoice and packing list from the supplier and compare them line-by-line with the proforma.
- Any discrepancy in price or quantity must be formalized before dispatch with documents acceptable to both the bank and customs.
- At the consolidation warehouse, recount the packages and items, reconciling them with the packing list and invoice.
We perform the fourth step at our warehouses in Shanghai, Shenzhen, and Guangzhou while the shipment can still be halted. In a separate guide, we demonstrated how packing list reconciliation with the commercial invoice is carried out regarding package counts, weights, and declaration fields.
When a separate reconciliation with the proforma is unnecessary
If you pay after shipment against a finalized invoice, the proforma functions merely as a price quote. Since no money was transferred prior to dispatch, there is no advance payment to reconcile; checking the invoice against the packing list and actual cargo is sufficient.
If there is only one proforma, the batch was paid in full upfront, and the factory confirmed shipment without alterations, the commercial invoice will simply duplicate it. Verification takes minutes, so there is no need to turn it into a dedicated procedure.
All of the above applies to commercial imports under a contract by legal entities or individual entrepreneurs. Personal parcels and cargo delivery schemes operate under different rules and are not covered here.
What to do if the invoice does not match the proforma
A discrepancy itself is not a violation. A violation occurs when a discrepancy exists without supporting documentation. Below are four common scenarios and our recommendations.
Less shipped than paid for
You paid for 2,000 pcs, but only 1,940 pcs were shipped. The invoice for 1,940 pcs is correct, and we declare the goods accordingly. However, the payment for the remaining 60 pcs remains with the supplier, and currency control regulations require the resident to repatriate funds paid for undelivered goods within the contractual deadlines (item 2, part 1, art. 19 of Federal Law No. 173-FZ). The supplier must either refund the difference or deliver the missing goods within the contract period. Settle this in writing as soon as you receive the draft invoice, before the bank raises questions.
Supplier provided a discount
The proforma listed $10 per unit, but after negotiations, you agreed on $9.50, and the invoice was issued at the new price. If the discount is documented only in correspondence while contract payments were made at the old rate, customs and the bank will see conflicting figures. Because customs value includes all payments made for the goods, the discount must be documented with an addendum or a revised specification so that the total payments match the invoice.
Factory replaced a model or material
A substitution changes the goods description, which in turn determines the HS code and duty rate. The invoice must reflect what is physically inside the boxes, not what was written in the proforma. If the supplier changes only the quantity and price while leaving the item names unaltered, a customs inspection will uncover unmanifested goods rather than a mere calculation error.
Invoice lacks itemized details
A line item like “Spare parts, 1 lot” may be acceptable for a proforma, but not for customs clearance. For a 900 kg auto parts shipment that we handled as LCL via Kazakhstan, the contract and invoices itemized every single part, with individual HS codes assigned to filters, brake pads, and sensors. Grouping them under a generic name is unacceptable. The cargo was delivered within 12–14 days, and the client received complete documentation for every line item.
Catching invoice errors at a warehouse in China is cheaper than at customs
When consolidating smartphone accessories from three suppliers in Shenzhen (11.6 m³), our audit identified incomplete descriptions, discrepancies across commercial documents, and invoice errors. The valuation of certain items could have prompted customs queries. Before dispatch, we audited the paperwork and verified whether declared values aligned with market levels, allowing customs clearance without value adjustments.
With a garment shipment from Guangzhou (8.4 m³), the situation was more demanding. The physical quantity did not match the factory invoices, and several items lacked labels. We suspended shipment, recounted every position, compiled an accurate packing list, and aligned descriptions in the invoices. Clearance was completed without inspections or inquiries, and the cargo arrived in 26 days. By our estimates, fines and temporary storage warehouse (TSW) costs could have reached up to 15% of the shipment's total value.
If an incomplete or incorrect invoice description ends up in the declaration, alters the HS code, and reduces payable duties, it constitutes an offense under Part 2, Art. 16.2 of the Administrative Offenses Code, carrying fines from 50% to 200% of unpaid duties and taxes, with or without cargo confiscation. If excess goods are discovered beyond the declared quantity, it is classified as non-declaration under Part 1 of the same article, with fines based on the value of the goods. As a licensed customs broker under the EAEU Customs Code, TransGID shares joint liability for duty payments with the client; therefore, we will halt dispatch and request an amended invoice from the factory rather than transport goods with paperwork that does not match the actual cargo.
Another issue is an invoice price that matches all documents but falls below market levels. We explained how customs cross-references values with China's export data in our review of the risks of grey-market cargo delivery from China.
Specifications, bills of lading, and packing lists serve different purposes
In an import document package, the invoice is accompanied by three or four other key documents, each serving a distinct verification function.
| Document | Issued by | What it proves | What is verified against the invoice |
|---|---|---|---|
| Contract and specification | Seller and buyer | What is purchased and under what terms | Item names, price, delivery terms |
| Proforma invoice | Seller | Terms of a specific order prior to dispatch | Models, quantity, price |
| Packing list | Seller | Cargo packaging breakdown, weights | Quantity, packages, weight |
| Bill of lading, CMR, SMGS | Carrier; CMR signed by shipper & carrier | Goods accepted for carriage | Number of packages, weight, consignee |
Specifications can be easily confused with invoices, as both list goods and prices. A specification is part of the contract, outlining the total scope of deliveries or an individual order. The commercial invoice applies to a single dispatch and relies on the specification. Delivery terms from the contract are carried over into the invoice, defining freight responsibilities and risk transfer. This is covered in detail in our article on Incoterms 2020 delivery terms.
A bill of lading is not about financial terms; the Customs Code classifies it as a transport document. Issued by the carrier, it is required to claim cargo at the port of destination. For trucking, the CMR consignment note fulfills this role, and we reconcile it against the packing list for package counts and weight. Field-by-field instructions are provided in our guide on how to complete a CMR consignment note.
What to check before paying the proforma and before dispatch
Errors are most costly when funds are transferred to a supplier based on preliminary paperwork. For an online store purchasing robotics components, an order from a new supplier totaled nearly 4 million rubles, and the client had concerns regarding board quality and packaging. We carried out a factory audit before invoice payment. Our inspector cross-checked the batch against specifications, captured photos and videos for each board type, and reviewed supplier documentation. As the client suspected, the factory packaging was inadequate. At our warehouse, we repacked the shipment into rigid wooden crates, and the 350 kg consignment arrived in 18 days without damage.
A document issued for advance payment may be labeled by the supplier as either an invoice or a proforma. What matters is that the figures remain preliminary and must be verified before funds are remitted.
Before paying an advance, verify that:
- The document displays a number, date, and contract or specification reference, enabling the bank to link the transaction;
- Item descriptions are detailed enough to classify the HS code, rather than using generic terminology;
- Price, currency, delivery terms, and payment terms align with the contract;
- The contract specifies what happens to the advance payment if fewer items are shipped.
In addition, before sending an advance, it is advisable to calculate duties and VAT for your shipment. If the calculated duties appear disproportionately low for the goods, it is better to resolve pricing questions before payment than after a customs inquiry.
Before dispatch, check that:
- The header reads Commercial Invoice, not Proforma;
- Quantities and descriptions match the packing list, and the total matches the contract, payment records, and remaining payables;
- Any variance from the proforma is supported by documentation acceptable to both your bank and customs.
If any item does not align, the supplier can simply amend the document before dispatch. After the declaration is filed, correcting the same error will trigger customs inquiries, security deposit requirements, and costly cargo delays.
Send us your proforma, contract, and draft invoice prior to shipment. At TransGID, we begin customs clearance by cross-checking these documents and calculating duties based on HS codes while the numbers can still be adjusted with your supplier.