This article analyses, first, the principal features of Spain's commercial policies towards Spanish America in 1797–1820, and, second, the value, nature and distribution of the trade that survived in this period, despite prolonged international warfare, the admission of neutral shipping, and internal strife from 1808 in both Spain and America. Like the author's earlier studies of ‘free trade’ in the period 1778–96, its principal sources are shipping registers and associated inter-ministerial correspondence in the Archivo General de Indias of Sevilla. Its main conclusions are that: (1) despite ambivalence and uncertainty in Spain about commercial policy, trade with Spanish America was more buoyant in 1797–1820 than previously realised; (2) nevertheless, by the first decade of the nineteenth century most parts of Spanish America were enjoying de facto, if not de jure, free trade with foreigners; (3) consequently, commercial discontent was not a key factor in the process of emancipation from Spain, particularly in the viceroyalties of New Spain and Peru which received some 70% of exports from Spain in this period.