1. How the two values diverge
The commercial invoice shows the price agreed with the buyer.
The customs declaration shows the value declared to Chinese customs at export.
These should correspond, and sometimes they do not.
2. Why they diverge
Deliberate understatement
The invoice is prepared for a customs purpose at a value lower than the transaction, and a different figure is used for the export declaration.
This is the case that carries risk.
Timing
The invoice was issued at one price, then amended, and the declaration used the earlier figure.
Terms
The invoice is on CIF terms and the declaration on FOB, so the figures differ by freight and insurance without any error.
Related-party pricing
Where buyer and seller are related, the transfer price may differ from the market price, and the customs value rules may require an adjustment.
3. The consequence at export
China’s export declaration is subject to the customs value rules.
A declared value that differs from the invoice may be queried at the Chinese end, and where the difference suggests understatement, the consequence can include inspection and penalties.
4. The consequence at import
The destination customs authority compares the invoice value against its valuation database and against the declared value in the export declaration where the data is exchanged.
A low invoice value against a reference price triggers a valuation query, which means a delay while the importer provides evidence.
5. The legalization problem
Where the invoice is legalized and the value is later found to be inconsistent with the declaration, the legalized document records the discrepancy.
This is the risk that exporters underappreciate: legalization converts a correctable inconsistency into a certified one.
6. The legitimate differences
Two differences are legitimate and should be documented rather than corrected.
Trade term differences: the invoice is on CIF, the declaration on FOB.
Currency conversion: the declaration is in RMB, the invoice in USD, using different rates.
Both are explained in the declaration and do not raise a query.
7. What the exporter should do
Reconcile the invoice and the declaration before submission.
Where a difference is legitimate, document the explanation.
Where a difference is not, correct it before legalization.
8. The reference price problem
Destination customs authorities maintain reference prices for many products, and a low invoice value against the reference price produces a query regardless of the transaction.
The query is not an allegation. It is a valuation procedure.
Where the transaction price is genuinely below the reference price, the importer has to evidence it: the contract, the market conditions, the related-party relationship, the quality difference.
9. Common errors
Preparing two different values
The high-risk version.
Not documenting a legitimate difference
Queried because unexplained.
Legalizing before reconciling
Certified discrepancy.
Ignoring the reference price
Queries on every shipment.
10. Closing view
The invoice value and the declared value have to reconcile, and where they do not, the reason has to be documented before any document is legalized.
The reconciliation is a five-minute check that prevents weeks of delay.
*This article is based on Chinese customs valuation rules and destination customs valuation practice. Exporters should confirm requirements with their clearing agent and customs broker.*