1. The requirement
The exporter must hold the evidence before it declares that the goods qualify.
Not after the customer asks. Not after the verification request arrives.
2. What verification examines
The bill of materials
With HS codes for each component.
Supplier declarations
For each imported material.
The product-specific rule
Identified, and the correct one for the product and the agreement.
The test
Performed, with its inputs and its result.
The dates
When the test was performed, and which version of the data it used.
3. What exporters usually have
A certificate of origin.
An invoice.
A feeling that the product qualifies.
4. The gap
The certificate records a claim. The file is what makes the claim defensible.
5. The scenario
An exporter had shipped under RCEP certificates for four product lines over two years.
A verification request arrived covering the whole period.
The exporter could produce the certificates and the invoices. It could not produce the origin test for one of the four lines, because the person who had performed it had left and had kept the analysis in a personal file.
The preference was withdrawn for that line across the full period, and the importer recovered the duty.
6. What would have prevented it
The analysis being filed against the product, not against the individual.
A template that requires the rule, the inputs, the result and the date.
7. What to build
A product origin file
One per product. The rule, the data, the test, the result.
The update trigger
Any change to materials, suppliers or process.
The annual review
Because the tariff schedules change.
8. The cost of the file
An hour per product, once.
The cost of not having it is the duty on everything shipped under the withdrawn line.
9. Closing view
Origin work performed at the time is documentary.
Origin work reconstructed afterwards is usually impossible.
*This article is based on the origin verification provisions of RCEP and China’s free trade agreements.*