Must the commercial invoice show FOB, freight and insurance separately?

Updated · 4 min read

The short answer

No general rule says a commercial invoice must show the FOB value, freight and insurance separately: Incoterms 2020 decide who pays for carriage and insurance but do not ask for a split price, and a letter of credit asks for it only when the credit says so. Some destinations do require it, among them the United States (19 CFR 141.86), Canada (the customs invoice asks for freight and insurance) and DR Congo (Bureau Veritas wants the breakdown on the final invoice), and elsewhere money depends on it, such as Ghana's FDA import permit fee, which is set on the FOB value on the invoice. When an invoice shows the split, FOB plus freight plus insurance must add up to the total.

The short rule

No general rule says a commercial invoice must split the price into FOB value, freight and insurance. Incoterms 2020 decide who arranges and pays for carriage and insurance, but they do not deal with the payment of the price (ICC, introduction to Incoterms 2020). The letter of credit rules do not ask for the split either: article 18 of UCP 600 sets what a commercial invoice must be, and a separate freight or insurance line is not part of it. So a CIF invoice that shows one total is normal, unless the destination, the buyer or the credit asks for more.

Some destinations do ask for more, and in others the buyer's duties or fees depend on it. That is why an importer may insist on a breakdown that another never mentions.

Where the split is required

Destination or caseWhat is askedRule
United StatesThe invoice lists all charges on the goods by name and amount, including freight and insurance19 CFR 141.86(a)(8)
CanadaThe customs invoice asks for transport charges and insurance from the place of direct shipment as separate amounts. A commercial invoice can replace it if it gives the same informationCBSA form CI1, fields 23 and 24; memorandum D1-4-1
DR CongoThe final invoice shows the breakdown of FOB, freight and insurance charges, and for each line the origin and the expiry dateBureau Veritas pre-export verification datasheet, Rev. 26, June 2024
A letter of credit that asks for itThe invoice shows what the credit asks forThe credit's own terms

The reason in the United States is money. Customs value there leaves out the cost of transport and insurance for the international voyage (19 U.S.C. 1401a(b)(4)(A)), so those costs have to be shown to be left out.

Where money depends on it

  • Ghana. The Food and Drugs Authority sets its verification fee for a frozen meat or fish import permit on the FOB value declared on the invoice (guideline FDA/ICD/GDL-04/05, clause 3.1.7, in force since 2 July 2025). An applicant found to have altered that FOB value pays the fee plus 100% of the unpaid amount as a fine (clause 4.2).
  • The Philippines. Customs value includes the cost of transport and insurance to the Philippine port (Customs Modernization and Tariff Act, Section 701). Customs guidelines from 2007 take the freight from the bill of lading, ask for the shipping line's certificate of the freight paid on reefer cargo, and verify an insurance premium below 2% of the FOB value (Customs Memorandum Order 22-2007). The broker needs the freight and insurance amounts either way.
  • New Zealand. Importers are expected to get a breakdown of the freight and insurance in a CIF price. When none can be had, the whole CIF price may be declared as the customs value (New Zealand Customs Service).

Local cargo insurance

Some countries require imports to be insured with a local insurer. In Ghana this applies to all imported goods except personal effects since 1 February 2026, under Section 222 of the Insurance Act, 2021 (Ghana Shippers' Authority). The Bureau Veritas datasheet for DR Congo says import cargo insurance is paid to an insurer based in DR Congo. In Kenya, marine cargo insurance for commercial imports has had to be placed with Kenyan insurers since 1 January 2017 (Lloyd's).

Under a CIF price the seller buys the insurance, usually in its own country. Where the buyer must insure locally anyway, ask whether the buyer prefers CFR, or wants the insurance shown on its own line.

When the invoice shows the split

An invoice that splits the price is read like any other: the lines must add up to the total, and the trade term on it, such as CIF Manila, is the one in the contract and, under a letter of credit, in the credit. Insurance has a rule of its own under a credit: unless the credit states the amount, the cover must be at least 110% of the CIF or CIP value (UCP 600, article 28(f)(ii)).

A worked example

A made-up invoice for one 40-foot reefer of frozen pork, sold CIF:

LineAmount in USD
FOB value: 24,000 kg at 2.35 per kg56,400.00
Freight4,200.00
Insurance85.00
Total CIF60,685.00

56,400.00 plus 4,200.00 plus 85.00 is 60,685.00, so the split adds up. The insurance certificate should insure at least 110% of 60,685.00, which is 66,753.50.

Now suppose the total had been typed as 60,865.00. Every line looks right, but the lines add up to 180.00 less than the total. A bank, an inspector or a buyer who adds the lines will stop the set, and under a letter of credit that can mean a discrepancy fee and a delayed payment: see the most common letter of credit discrepancies.

For another destination rule that touches the same documents, see cargo tracking numbers such as ECTN, BESC and FERI. For the values that must agree across the whole set, see what must match between the bill of lading, the invoice and the packing list.

Questions people ask

Do Incoterms require freight and insurance to be shown separately on a CIF invoice?

No. Incoterms 2020 decide who arranges and pays for carriage and insurance, and they do not ask the invoice to show those costs on separate lines. A CIF invoice with one total is normal unless the destination, the buyer or a letter of credit asks for a breakdown.

Why does a buyer in Ghana ask for the FOB value on the invoice?

Ghana's Food and Drugs Authority sets the verification fee for a frozen meat or fish import permit on the FOB value declared on the invoice. Since 1 February 2026 imports into Ghana must also be insured with a local insurer, so the buyer may prefer CFR or want the insurance on its own line.

How much insurance should a CIF shipment carry?

At least 110% of the CIF value is the usual minimum. Under a letter of credit that does not state the amount, UCP 600 makes 110% of the CIF or CIP value the minimum, and a credit can ask for more.

Does the freight on the invoice have to match the bill of lading?

If the bill of lading shows a freight amount, the two should agree; Philippine customs guidelines, for example, take the freight from the bill of lading. Many bills of lading only say freight prepaid, which is normal for CIF and CFR.

Sources

  1. US Code of Federal Regulations, 19 CFR 141.86, contents of the commercial invoice (Cornell LII)
  2. US Code, 19 U.S.C. 1401a, transaction value and the price actually paid or payable (Cornell LII)
  3. Canada Border Services Agency, form CI1, Canada Customs Invoice
  4. Canada Border Services Agency, memorandum D1-4-1, CBSA invoice requirements, 2013
  5. Bureau Veritas, DR Congo pre-export verification programme datasheet, Rev. 26, June 2024
  6. Food and Drugs Authority Ghana, guideline FDA/ICD/GDL-04/05 on import permits for frozen meat and fish, 2 July 2025
  7. Ghana Shippers' Authority, mandatory local cargo insurance from 1 February 2026, 9 April 2026
  8. Lloyd's, Kenya: marine cargo insurance to be placed with local insurers, 25 January 2017
  9. Philippines, Republic Act 10863, Customs Modernization and Tariff Act, Section 701 (Lawphil)
  10. Bureau of Customs (Philippines), Customs Memorandum Order 22-2007 on insurance and freight in the dutiable value
  11. New Zealand Customs Service, import entry guidelines for goods purchased on a CIF or similar basis
  12. ICC, Incoterms 2020, introduction
  13. ICC, Uniform Customs and Practice for Documentary Credits (UCP 600), articles 18 and 28