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A Verification Request Arrives Two Years Later

1. How verification starts

A request from the importing authority to the exporting authority, or a direct request to the importer for supporting documents.

Both can happen for the same consignment.

2. The time frame

Verification requests commonly arrive one to three years after the shipment.

By then, the people who prepared the documents may have moved on, and the data may have changed.

3. The timeline

The importing authority asks.

The exporting authority collects from the exporter.

The exporter assembles the file.

The response goes back.

The importing authority decides.

4. The decision

Accepted: the preference stands.

Rejected: the preference is withdrawn, and duty is recovered from the importer, who recovers from the exporter under the contract.

5. The failure modes

No origin analysis exists

The exporter shipped on the assumption that the goods qualified.

The analysis exists but is not traceable

Kept in a spreadsheet with no reference to the specific rule, or performed by an individual.

The data changed

The supplier changed, the product changed, and the analysis was not updated.

The analysis used the wrong rule

Performed against a bilateral rule but claimed under RCEP, or against the wrong product-specific rule.

6. What distinguishes a file that survives verification

It names the rule applied.

It shows the material codes and origins.

It records the calculation, where a value test applies.

It is dated.

It is consistent with the certificate that was issued.

7. A scenario

An exporter maintained origin files as a set of one-page documents per product, each naming the RCEP rule, the components with their codes and origins, the test, the result and the date.

A verification request covering two product lines was answered in a week with no adjustment to the preference.

8. The lesson

The file that survives verification is the one that was written when the claim was made.

9. Closing view

Verification is a documentary exercise.

The authority is not testing whether the goods qualify. It is testing whether the claim can be supported.

*This article is based on the origin verification provisions of RCEP and Chinese customs practice.*

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