Customs value is the number your duty rate multiplies. In the US and most major markets, that number starts with the transaction value: the price you actually paid (or will pay) for the imported goods. It is not your retail price, not your landed cost, and not whatever number appears on the invoice if that invoice understates what changed hands. Packing, selling commissions, royalties tied to the sale, and the value of any materials or tooling you supplied to the factory get added in. Getting this number right matters more than getting your duty rate right, because it applies to every unit you import.
What transaction value actually includes
The base is the price paid or payable: the total payment from buyer to seller for the imported merchandise, adjusted upward or downward by whatever the deal says. Then customs adds specific items that the price alone may not capture. Packing costs incurred by the buyer are dutiable. Selling commissions paid to agents count. Royalties and license fees that the buyer must pay as a condition of the sale, common in branded goods with licensed IP, are dutiable too. And assists: materials, components, tooling, molds, and engineering or design work supplied directly or indirectly by the buyer to the manufacturer must be added to the value of the finished goods.
That last one catches more DTC brands than anything else. If you ship fabric to a cut-and-sew factory, provide molds to a plastics manufacturer, or pay a design firm whose output the factory uses, the value of those contributions is part of the customs value of the imported product. It does not matter that no money changed hands at the factory gate for the assist. Customs adds it anyway, and if your commercial invoice ignores it, your declared value is low.
The mistakes that show up in audits
The most common valuation error is declaring the sample or pro forma price instead of the real one. Some factories issue invoices at an artificially low value to help buyers, and the buyer passes that number to the broker without checking. This is undervaluation, and it is the kind of thing customs authorities test for with purchase order and payment records. The real price paid, verifiable from bank transfers, is what counts.
The second common error is ignoring the freight and insurance split. In the US, customs value generally excludes international freight and insurance, since the US uses an FOB-style valuation. But in the EU and many other markets, customs value includes freight and insurance up to the point of entry. A brand that ships the same goods to the US and to Germany should expect different dutiable values for the same product, and the commercial invoices need to itemize those costs so the broker can include or exclude them correctly by destination.
The third error is the related-party trap. Plenty of DTC brands buy through a related trading company or have the founder's other entity act as the importer of record. Customs allows the transaction value between related parties, but only if the relationship did not influence the price. Authorities test this by comparing against the price in sales to unrelated buyers, test values, or computed buildups. If you buy through a related entity, keep the documentation that proves the price is arm's length before the audit letter arrives.
Why valuation beats tariff engineering for most brands
Teams obsess over HS classification and duty rates, and that work matters. But valuation is the multiplier on the whole import program. A brand importing $2 million of goods at a 20 percent duty rate pays $400,000 in duties. If the declared customs value understated the true transaction value by 10 percent because assists were ignored, that is $40,000 of additional duty owed per year, plus penalties and interest once found. Conversely, brands that overvalue, declaring retail-ish prices or including US domestic freight, overpay on every shipment and rarely notice because nobody audits downward.
The fix is a valuation worksheet per product line. For each SKU family, document the unit price paid, the adds (packing, commissions, royalties, assists), the excludes (international freight for US-bound goods), and the final customs value per unit. Give it to your broker and your 3PL, and recheck it whenever the factory relationship changes, because a new tooling contribution or a new royalty arrangement changes the math immediately.
Is customs value the same as what I paid my supplier?
It starts there. The transaction value is the price paid or payable for the imported goods, but packing costs, selling commissions, royalties tied to the sale, and any assists you supplied must be added in.
Does the retail price matter for customs valuation?
No. Customs values the goods as they cross the border, not as you sell them. Markups, marketing spend, and your margin are not part of the dutiable value.
Can a transfer price between related companies be the transaction value?
Yes, as long as the relationship did not influence the price. Customs will test related-party prices against comparable sales, and you should be ready to show the numbers.