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Who Performs the Origin Analysis, and Who Carries the Risk

1. The principle

The rate is claimed at the destination. The origin test is performed in China.

The two are in different countries, with different authorities, and the link between them is the certificate.

2. The three areas where things go wrong

The origin analysis

Performed in China, usually by the exporter, often informally.

An incorrect conclusion becomes an incorrect claim.

The certificate issuance

The issuing authority checks consistency, not the underlying facts.

The destination presentation

The importer claims the rate. The importer relies on the exporter entirely.

3. The asymmetry

The importer receives the benefit and bears the risk of the verification.

The exporter produces the analysis and the certificate.

The risk allocation is therefore usually written into the contract, which is where exporters discover that they agreed to indemnify the importer.

4. The evidence file

Supplier declarations for imported materials.

Cost breakdown.

Production records.

Bill of materials with HS codes.

Transport documents for direct shipment.

5. What makes the file credible

It was created contemporaneously, not reconstructed after a verification request.

It includes negative evidence, such as the imported materials identified as non-originating.

It is consistent between the agreement claimed and the analysis recorded.

6. The scenario

An exporter prepared origin analyses each year before renewing a customer contract.

The analysis was a paragraph in a spreadsheet.

When the destination authority requested verification two years later, the exporter could not reconstruct the reasoning for one product, and the preference was withdrawn for that line.

7. What to change

Make the analysis a short written test per product, applying the rule and recording the material codes and the conclusion.

It takes an hour per product. It is what a verification request asks for.

8. Closing view

The rate is claimed at the destination. The defence is prepared in China.

The exporter who prepares the defence at the time of the claim never has to reconstruct it.

*This article is based on the origin rules and verification provisions of China’s free trade agreements.*

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