# The Five Additions Importers Miss in Customs Value

Source: https://landedcosthq.com/blog/2026-11-09-five-additions-customs-value-missed/

Cross-border operations guide · November 8, 2026


**Short answer:** The price on the invoice is the starting point, not the customs value. Five additions belong on top of it: packing costs, selling commissions, assists, royalties paid as a condition of the sale, and resale proceeds owed to the seller. Miss one and CBP can reject transaction value entirely.

## The invoice is one input, not the answer

Most importers treat the invoice price as the customs value. The law treats it as the starting point. Transaction value is the price actually paid or payable for the goods sold for export to the United States, plus five statutory additions, and the additions are where the valuation disputes live. Get them right and the entry is defensible. Miss one and the method can fail outright.

The five are specific. Packing costs, including the cost of the packing materials and the labor to pack. Selling commissions, where the seller paid a commission to sell the goods. Assists: the molds, tools, engineering, and materials the buyer supplied free or at a reduced cost for use in producing the goods. Royalties and license fees paid as a condition of the sale. And proceeds from a subsequent resale that accrue to the seller, where an appropriate adjustment can be calculated. Each one has its own rule, its own documentation, and its own way of going wrong.

## The assist is the one that sinks entries

Assists are the most commonly missed addition, and the most expensive to miss. A mold the buyer paid for and shipped to the factory is an assist, and its value belongs in the customs value, apportioned across the units it produces. The trap is the apportionment: failing to document a royalty does not make the royalty vanish from the base, and it can make the entire transaction value method fail, which pushes the entry to identical or similar merchandise, then to deductive value, then to computed value. Each step down the hierarchy derives the number from something other than the importer's own commercial relationship, and each step costs control.

CBP has ruled on the apportionment question directly. In ruling 545031, the agency rejected using IRS depreciation schedules to apportion an assist, because depreciation can leave part of the assist's value permanently outside the duty calculation. The assist has to be apportioned on a basis CBP accepts, and the documentation has to show the math. [The forgotten line](https://landedcosthq.com/blog/2026-11-08-landed-cost-formula-line-forgotten/) in most landed cost models is exactly this: the mold was paid for months ago, in a different budget, and nobody connected it to the entry.

## A checklist for the five

Run the five against every entry, not just the ones that look complicated. Packing: is the packing on the invoice, or billed separately? Commissions: did anyone take a selling commission on this sale? Assists: did the buyer supply a mold, a tool, engineering work, or materials? Royalties: is there a license fee tied to the sale? Resale proceeds: does any part of the resale price flow back to the seller? If the answer to any of those is yes, the amount belongs in the value, and the documentation belongs in the file.

The penalty for getting it wrong is not a rounding adjustment. Undervaluation is penalized under 19 USC 1592, and negligence tops out at twice the duty lost, or 20 percent of dutiable value where no duty was lost. [Brokerage fees](https://landedcosthq.com/blog/2026-11-06-brokerage-fees-landed-cost/) are the visible cost of the entry. The additions are the invisible one, and the importers who check all five before the entry files are the ones who never have to explain the sixth one to CBP.

## Frequently asked questions

## What are the five additions to customs value?

Packing costs, selling commissions, assists, royalties paid as a condition of the sale, and resale proceeds owed back to the seller. They are added to the price actually paid or payable to arrive at transaction value.

## What is an assist in customs valuation?

An assist is a mold, tool, engineering work, or material the buyer supplied free or at reduced cost for use in producing the imported goods. Its value belongs in the customs value, apportioned across the units it produces.

## What happens if I miss an addition?

Missing an addition can make the entire transaction value method fail, pushing the entry down the valuation hierarchy to identical merchandise, deductive value, or computed value. Undervaluation can also draw penalties under 19 USC 1592.

## Can I apportion an assist using depreciation schedules?

No. CBP ruled in 545031 that IRS depreciation schedules are not an acceptable basis for apportioning an assist, because depreciation can leave part of the assist's value permanently outside the duty calculation.