Key Takeaways
- Packing lists must include 10 essential fields: exporter/consignee details, invoice reference, package count and type, gross and net weight, dimensions, marks and numbers, goods description, HS code (recommended), dangerous goods notation if applicable, and country of origin.
- HMRC requires packing lists and supporting export documents to be retained for 4 years from the date of export under the Customs and Excise Management Act 1979.
- CDS export declarations require specific data fields derived from the packing list: number of packages, package type codes (UN/ECE Recommendation 21), gross mass in kg, net mass in kg, and goods description.
- The packing list and commercial invoice must match exactly on buyer/seller names, invoice number, total package count, and weight totals — mismatches are the most common reason for customs holds.
- Under Incoterms 2020 rules, the seller’s obligation to provide a packing list varies by rule: mandatory under EXW, FCA, FAS, FOB, CIF, CIP, DAP, DPU, and DDP when needed for the buyer to take delivery.
- HMRC accepts digital packing lists submitted via CDS or as PDF attachments since 2024; paper originals are no longer mandatory for UK customs but may still be required by destination countries.
A packing list is one of the most frequently requested yet frequently botched documents in international trade. It travels with your goods from warehouse to destination, serving as the physical verification that customs authorities use to match what you declared against what actually arrived. Get it wrong, and your shipment sits in a bonded warehouse accruing demurrage charges while you scramble to fix a typo.
This guide covers what a packing list must include, the 10 fields that every UK exporter needs, common mistakes that trigger customs inspections, and how Incoterms 2020 rules affect your packing list obligations. We’ll also clarify what HMRC now accepts in digital format and what record-keeping requirements you must meet.
What a Packing List Is (and What It Isn’t)
A packing list is a detailed inventory of the contents of a shipment. It itemises every package, pallet, carton, or container being shipped, along with the weight, dimensions, and description of the goods inside. Unlike a commercial invoice, which focuses on the commercial transaction and value of the goods, the packing list focuses on the physical characteristics of the consignment.
The packing list serves three distinct purposes in the export process. First, it enables customs authorities to verify that the goods described in the customs declaration match the physical shipment. Second, it helps freight forwarders and carriers plan stowage and calculate freight charges based on weight and volume. Third, it allows the consignee to check that all items ordered have been received when the shipment arrives.
A packing list is not a commercial invoice, even though both documents often reference the same invoice number. The commercial invoice establishes the value of the goods for customs valuation and VAT purposes. The packing list establishes the physical characteristics for classification, safety, and handling purposes. Both documents must travel together, and both must be consistent with each other.
A packing list is also not a certificate of origin, which certifies where the goods were manufactured for preferential duty treatment under trade agreements. Nor is it a bill of lading or air waybill, which are contracts of carriage between the shipper and carrier. However, the packing list data feeds into the bill of lading — the gross weight, package count, and marks and numbers on the packing list should match exactly what appears on the transport document.
Under HMRC’s CDS (Customs Declaration Service) requirements, the packing list provides the source data for several mandatory declaration fields. According to UK Trade Tariff Volume 3 for CDS, exporters must declare the number of packages, type of packaging using UN/ECE Recommendation 21 codes, gross mass in kilograms, net mass in kilograms, and a goods description that aligns with the commodity code classification. All of this information comes directly from the packing list.
The 10 Fields Every Packing List Must Include
A compliant packing list for UK exports must contain specific data fields. Missing any of these fields risks customs delays, inspections, or rejection of the export declaration. Here are the 10 essential fields, in the order they should appear on the document.
1. Exporter and Consignee Details
The packing list must clearly identify both the shipper (exporter) and the receiver (consignee). Include full legal names, complete addresses with postal codes, and contact information. For the exporter, include your EORI number if you have one — while not strictly mandatory on the packing list itself, it helps customs officers cross-reference your export declaration quickly.
The consignee details must match exactly what appears on the commercial invoice and the bill of lading. If the goods are being shipped to a freight forwarder’s warehouse for consolidation, list the forwarder as the consignee with “in care of” the ultimate recipient noted separately. Never abbreviate company names or use trading names that differ from the legal entity name on the invoice.
2. Invoice Reference
Every packing list must reference the commercial invoice number it relates to. This creates the audit trail that customs officers use to link the physical shipment to the commercial transaction. The invoice reference should appear prominently at the top of the packing list, typically in a field labelled “Invoice No.” or “Commercial Invoice Reference.”
If you’re shipping multiple invoices in one consignment, list all invoice numbers on the packing list. Some exporters use a master packing list that references multiple invoices, with subsidiary packing lists for each invoice. Either approach is acceptable to HMRC, provided the total package count and weight across all documents reconcile.
3. Package Count and Type
The packing list must state the total number of packages in the shipment and describe the type of packaging used. HMRC’s CDS system uses UN/ECE Recommendation 21 package type codes, which are two-letter abbreviations for common packaging types. The most frequently used codes include:
- CT = carton
- PL = pallet
- BX = box
- DR = drum
- BG = bag
- CS = case
- RL = roll
You can use these codes on your packing list, but it’s best practice to spell out the packaging type in plain English alongside the code. For example: “12 CT (cartons)” or “4 PL (pallets).” This avoids confusion if the consignee’s customs broker isn’t familiar with the UN/ECE coding system.
If you’re shipping mixed packaging types — say, 10 cartons on 2 pallets — list both: “2 PL (pallets) containing 10 CT (cartons).” The total package count for CDS purposes would be 2 (the outermost packaging units), but your packing list should show the full breakdown for the consignee’s receiving team.
4. Gross Weight and Net Weight
The packing list must show both gross weight and net weight in kilograms. Gross weight is the total weight of the goods plus all packaging materials, including the pallet. Net weight is the weight of the goods only, excluding all packaging. This distinction matters because customs duty on many commodities is assessed on net weight, not gross weight.
According to HMRC compliance guidance, customs authorities typically allow a weight tolerance of approximately ±5% between the declared weight and the actual weight at inspection. However, consistent discrepancies beyond this tolerance trigger inspections and may result in penalties for inaccurate declarations. Always weigh your goods on calibrated scales and record the actual weight, not an estimate.
If you’re shipping multiple packages with different weights, list the gross and net weight for each package individually, then show the totals at the bottom. For example:
Package 1: Gross 25 kg, Net 22 kg
Package 2: Gross 28 kg, Net 25 kg
Package 3: Gross 24 kg, Net 21 kg
Total: Gross 77 kg, Net 68 kgThe totals must match what you declare on the CDS export declaration in Data Element 6/5 (gross mass) and Data Element 6/1 (net mass).
5. Dimensions
While not always mandatory for customs purposes, dimensions are essential for freight planning and should be included on every packing list. Show the length, width, and height of each package in centimetres. For palletised shipments, include the pallet dimensions plus the height of the stacked goods.
Dimensions matter for calculating volumetric weight, which carriers use to charge freight when the goods are lightweight but bulky. The formula is typically (length × width × height in cm) / 5,000 = volumetric weight in kg. If the volumetric weight exceeds the actual gross weight, you’ll be charged on the volumetric weight.
For containerised shipments, dimensions help the freight forwarder plan stowage and ensure the goods fit within the container. A standard 20-foot container has internal dimensions of approximately 590 cm × 235 cm × 239 cm, with a maximum payload of around 28,000 kg. A 40-foot container is approximately 1,203 cm × 235 cm × 239 cm, with a maximum payload of around 26,000 kg.
6. Marks and Numbers
Marks and numbers are the shipping marks that appear on the outside of each package. They typically include the consignee’s name or initials, destination port, package number (e.g., “1 of 12”), and sometimes a reference number or handling instructions. The marks on the packing list must match exactly what’s stencilled or labelled on the physical packages.
These marks serve a practical purpose: they enable warehouse staff and customs officers to identify packages quickly without opening them. If customs wants to inspect package 7 of 12, they need to find it by the marks, not by opening every carton. Missing or incorrect marks make inspections slower and increase the risk of damage during handling.
For dangerous goods, the marks must include the UN number, proper shipping name, and hazard class labels as required by the IMDG Code (for sea freight) or ICAO Technical Instructions (for air freight). This is not optional — it’s a legal requirement under international dangerous goods regulations enforced by the UK Maritime and Coastguard Agency and Civil Aviation Authority.
7. Goods Description
The goods description on the packing list must be specific enough to identify what the goods are, but it doesn’t need to be as detailed as the commercial invoice. Avoid vague terms like “general merchandise,” “spare parts,” or “samples.” Instead, use descriptive language: “stainless steel fasteners, grade 304,” “cotton t-shirts, men’s size L,” or “polypropylene packaging film, 500 gauge.”
The description should align with the goods description you declare on the CDS export declaration in Data Element 6/8. While the packing list description doesn’t need to match the commodity code description word-for-word, it must be consistent enough that a customs officer can see the connection. If your commodity code is for “plastic tubes and pipes” but your packing list says “industrial components,” expect questions.
8. HS Code (Recommended)
Including the HS (Harmonised System) code or commodity code on the packing list is not mandatory, but it’s strongly recommended. The HS code is the 6-digit international classification code that forms the basis of the UK’s 10-digit commodity code. Including it on the packing list helps the consignee’s customs broker verify the classification quickly and reduces the risk of misclassification at import.
If you’re shipping goods with multiple commodity codes, list the HS code next to each line item on the packing list. For example:
Item 1: Stainless steel fasteners — HS 7318.15 — 12 cartons
Item 2: Brass washers — HS 7318.22 — 8 cartonsThis level of detail is particularly useful for mixed shipments where different goods may attract different duty rates or require different import licences at the destination.
9. Dangerous Goods Notation (If Applicable)
If your shipment contains dangerous goods, the packing list must clearly identify which items are classified as dangerous and provide the required information: UN number, proper shipping name, hazard class, and packing group. This information should ideally appear in a separate section or column for easy identification.
For example:
DANGEROUS GOODS
UN 1263, PAINT, Class 3, Packing Group II, 4 cartons
UN 1950, AEROSOLS, Class 2.1, Packing Group N/A, 2 cartonsThe dangerous goods notation on the packing list must match exactly what appears on the dangerous goods declaration and the transport document. Any discrepancy is grounds for the carrier to refuse the shipment, as they have legal liability for carrying dangerous goods safely.
10. Country of Origin
The country of origin is the country where the goods were manufactured or produced, not necessarily the country they’re being shipped from. This matters for preferential duty treatment under trade agreements and for trade remedy measures like anti-dumping duties. The country of origin on the packing list should match what you declare on the CDS export declaration and the certificate of origin if one is required.
For goods that incorporate materials from multiple countries, the country of origin is determined by the “last substantial transformation” test. If you’re manufacturing goods in the UK from imported components, the country of origin is the UK. If you’re re-exporting goods that were manufactured in China without substantial transformation in the UK, the country of origin is China.
Common Mistakes That Trigger Customs Holds
Customs authorities see thousands of packing lists every day. Most pass through without issue, but certain mistakes consistently trigger inspections, delays, and penalties. Here are the most common errors and how to avoid them.
Invoice and Packing List Mismatches
The single most common reason for customs holds is a mismatch between the commercial invoice and the packing list. Customs officers cross-check these documents line by line. If the invoice says 10 cartons and the packing list says 12, the shipment gets flagged. If the gross weight on the invoice is 500 kg and the packing list says 520 kg, expect questions.
The mismatch doesn’t have to be large to cause problems. Even a discrepancy of one carton or 5 kg can trigger an inspection because it suggests either sloppy documentation or an attempt to conceal goods. Always reconcile the invoice and packing list before submission. The buyer/seller names, invoice number, total package count, and weight totals must match exactly.
Vague or Generic Goods Descriptions
Descriptions like “machine parts,” “electronic components,” or “textile goods” are red flags for customs officers. These terms are too vague to verify the commodity code classification or to assess whether the goods require licences, certificates, or special handling. A vague description suggests the exporter either doesn’t know what they’re shipping or is trying to obscure the true nature of the goods.
Be specific. Instead of “machine parts,” write “hydraulic pump components for agricultural machinery.” Instead of “electronic components,” write “printed circuit boards for automotive control systems.” The extra words take seconds to add but can save days of customs delays.
Missing or Inconsistent Weights
Missing weights are an automatic fail. Every package on the packing list must have both gross and net weight stated. Equally problematic are inconsistent weights — if the sum of individual package weights doesn’t match the total weight shown at the bottom of the packing list, customs will assume an error (or worse, an attempt to misdeclare).
Always double-check the arithmetic. Use a spreadsheet if you’re shipping multiple packages with different weights. Weigh the actual packages, don’t estimate. And remember that gross weight includes the pallet — a common oversight is to weigh the goods on the pallet but forget to add the pallet’s own weight (typically 20-25 kg for a standard wooden pallet).
Wrong Package Counts
The package count on the packing list must match the physical shipment and the CDS export declaration. If you declare 10 packages on CDS but the packing list shows 12, the export declaration is technically incorrect. HMRC’s compliance system may catch this discrepancy during post-clearance audits, resulting in penalties for inaccurate declarations.
The package count for CDS purposes is the number of outermost packaging units. If you’re shipping 100 cartons on 10 pallets, the CDS package count is 10 (the pallets), not 100 (the cartons). However, your packing list should show both: “10 pallets containing 100 cartons.” This gives customs the full picture while maintaining consistency with the declaration.
Inconsistent HS Codes
If you include HS codes on the packing list, they must match the commodity codes you declare on CDS. The first 6 digits of the UK commodity code are the HS code, so these should align. If your packing list shows HS 7318.15 (steel screws and bolts) but your CDS declaration uses 7318.22 (steel washers), you’ve got a classification problem that needs resolving before the goods ship.
Classification errors are among the most costly mistakes in international trade. They can result in underpaid or overpaid duty, penalties for incorrect declarations, and in severe cases, seizure of the goods. If you’re unsure about the correct commodity code, use the UK Trade Tariff online tool or consult a customs specialist before finalising the packing list.
Incoterms and Packing List Obligations
Under Incoterms 2020 rules, the seller’s obligation to provide a packing list varies depending on which rule applies to the contract. The ICC Incoterms 2020 book specifies that the seller must provide the buyer with documents needed to take delivery of the goods, which typically includes a packing list. Here’s how the obligation breaks down by rule.
EXW (Ex Works)
Under EXW, the seller’s only obligation is to make the goods available at their premises. However, ICC Incoterms 2020 Article A9 requires the seller to provide the buyer with any documents needed to take delivery, which includes a packing list if the buyer needs it for transport or customs purposes. In practice, the buyer almost always needs a packing list, so the seller should provide one.
FCA, FAS, FOB (Free Carrier, Free Alongside Ship, Free on Board)
Under these rules, the seller delivers the goods to the carrier or alongside the vessel. Article A9 for each rule requires the seller to provide documents needed for the buyer to take delivery, including a packing list. The packing list should be provided at the seller’s expense and in a timely manner to allow the buyer to arrange transport and customs clearance.
CFR, CIF (Cost and Freight, Cost, Insurance and Freight)
Under CFR and CIF, the seller pays the freight to the destination port and must provide the buyer with the usual transport documents. Article A9 explicitly requires the seller to provide a packing list as part of the shipping documents package. Under CIF, the seller must also provide insurance documents, but the packing list requirement is the same as CFR.
CPT, CIP (Carriage Paid To, Carriage and Insurance Paid To)
CPT and CIP are the multimodal equivalents of CFR and CIF. The seller pays freight to the named destination and must provide documents needed for the buyer to take delivery. Article A9 requires the seller to provide a packing list along with the transport document and any other documents needed for import clearance.
DAP, DPU, DDP (Delivered at Place, Delivered at Place Unloaded, Delivered Duty Paid)
Under these delivery rules, the seller is responsible for delivering the goods to the named destination. Article A9 for each rule requires the seller to provide documents needed for the buyer to take delivery, including a packing list. Under DDP, the seller also handles import customs clearance, so the packing list must meet both export and import country requirements.
The table below summarises packing list obligations by Incoterms 2020 rule:
| Incoterms 2020 Rule | Seller Packing List Obligation |
|---|---|
| EXW | Provide if needed for buyer to take delivery (A9) |
| FCA | Provide as part of delivery documents (A9) |
| FAS | Provide as part of delivery documents (A9) |
| FOB | Provide as part of delivery documents (A9) |
| CFR | Provide as part of shipping documents (A9) |
| CIF | Provide as part of shipping documents (A9) |
| CPT | Provide as part of delivery documents (A9) |
| CIP | Provide as part of delivery documents (A9) |
| DAP | Provide as part of delivery documents (A9) |
| DPU | Provide as part of delivery documents (A9) |
| DDP | Provide as part of delivery documents (A9) |
Digital vs Paper — What HMRC Now Accepts
Since 2024, HMRC has operated a digital-first policy for customs documentation. Packing lists can be submitted electronically via CDS as PDF attachments to the export declaration. Paper originals are no longer mandatory for UK customs purposes, though you must still retain records for the required period.
The digital packing list must be a clear, legible PDF that contains all the required fields. Scanned copies of signed paper packing lists are acceptable, as are digitally created PDFs generated from warehouse management systems. The key requirement is that the information is complete and readable — HMRC doesn’t require wet signatures on packing lists.
However, destination countries may still require paper originals. Some countries’ customs authorities insist on seeing original signed documents, particularly for high-value shipments or goods requiring import licences. Always check the import country’s requirements before deciding to go fully digital. If paper originals are needed, send them via courier ahead of the goods or enclose them in a document pouch attached to the shipment.
Record-Keeping Requirements
Regardless of whether you use digital or paper packing lists, HMRC requires you to retain copies for 4 years from the date of export. This requirement comes from the Customs and Excise Management Act 1979 and applies to all export documentation, including packing lists, commercial invoices, export declarations, and transport documents.
Digital records are acceptable for HMRC’s record-keeping purposes, provided they’re stored securely and can be retrieved on request. A cloud-based document management system with backup is preferable to paper files stored in a warehouse, which can be lost to fire, flood, or misfiling. The key is that you can produce the records if HMRC requests them during a compliance audit.
Frequently Asked Questions
Do I need a separate packing list for each container?
No, you don’t need a separate packing list for each container if you’re shipping multiple containers in one consignment. You can use a master packing list that covers all containers, with a breakdown showing which packages are in which container. However, some freight forwarders prefer container-specific packing lists for easier stowage planning. Check with your forwarder before finalising the documentation.
Can I combine the packing list and commercial invoice into one document?
Technically yes, but it’s not recommended. While HMRC doesn’t prohibit combined documents, many destination countries’ customs authorities expect separate documents. A combined document can also create confusion about which information is commercial (value, payment terms) and which is physical (weight, dimensions). Keep them separate to avoid delays at import.
What if my goods don’t come in standard packages?
For bulk goods, loose cargo, or items shipped without packaging (like vehicles or machinery), the packing list should describe the goods as they are. Use “unit” or “piece” as the package type, and show the dimensions and weight of each individual item. For example: “1 unit — industrial printing press, gross weight 2,500 kg, dimensions 400 × 200 × 250 cm.” The key is to provide enough detail for customs to verify the shipment.
How long must I keep packing lists?
HMRC requires you to keep packing lists and all supporting export documentation for 4 years from the date of export. This is a legal requirement under the Customs and Excise Management Act 1979. The clock starts from the export date, not the date you created the document. Digital copies are acceptable, provided they’re legible and retrievable.
Does HMRC have a standard packing list template?
No, HMRC doesn’t provide or require a specific packing list template. The document just needs to contain the required information: exporter/consignee details, invoice reference, package count and type, weights, dimensions, marks and numbers, goods description, and country of origin. Many freight forwarders provide templates to their customers, or you can create your own in-house template that meets the requirements.