Preferential origin: preparing for post-clearance verification of origin

Situations relevant to post-clearance verification of origin

• An exporter benefits from a preferential agreement with the EU or EFTA without a file of proofs organised by transaction.
• An importer identifies incomplete supplier’s declarations for goods imported under preference.
• A company faces a verification deadline and must first check its sample of transactions.
• A single product range falls under several agreements, including Agadir, the United States or the AfCFTA.
• No internal procedure yet ensures the retention of proofs of origin.

Process

1. Purchase and onboarding. The client first acquires the Preferential origin and post-clearance verification intake form (CV-04). ASKonsult then opens the secure exchange space.
2. Synchronous scoping. Session 1, a 90-minute videoconference, settles the sample of transactions to be examined. It also specifies the applicable rules of origin and the known verification deadlines.
3. Asynchronous collection. The client then completes the intake form and submits the bills of materials, supplier’s declarations, proofs of origin and invoices. Written questions flow in both directions.
4. Analysis and correction. The firm’s in-house engineering team then checks each product: classification, list rule, cumulation and tolerance. Session 2, a 60-minute videoconference, addresses the discrepancies identified.
5. Synchronous delivery. Finally, session 3, a 90-minute videoconference, is the occasion for handing over the compliance file. The regularisation plan and the internal procedure for retaining proofs accompany it.

Deliverable

The deliverable first comprises an origin matrix drawn up product by product. The file of proofs, organised by transaction, then gathers the documents for the sample examined. A discrepancy report sets out the non-compliant points, together with a regularisation plan. Finally, an internal origin management procedure organises the keeping of proofs with a view to a post-clearance verification of origin. ASKonsult hands over the whole set at session 3, after a final review.

Prerequisites

The package first requires the completed Preferential origin and post-clearance verification intake form (CV-04). The bills of materials and supplier’s declarations complete this foundation. In addition, the proofs of origin and customs declarations for the sample are among the expected documents. Time frames run from receipt of a complete file.

Frequently asked questions

How is the package quote established?

The quote rests on a qualification exchange prior to subscription. This exchange covers in particular the number of products examined, up to fifteen, and the number of agreements. The special conditions then set the scope, timetable, number of sessions, expected documents and deliverable. ASKonsult then creates the order from the accepted quote.

How are the sessions and asynchronous work distributed?

The package includes three videoconference sessions, 4 hours in total. Scoping and delivery each last 90 minutes; the session on discrepancies, 60 minutes. Between these sessions, collection takes place asynchronously, through the secure exchange space. Written questions flow there in both directions. In addition, the firm schedules the sessions in advance, in set time slots.

Which points does the product-by-product check examine?

The check first covers the classification of each product. It then compares manufacturing against the applicable list rule. Cumulation and tolerance are also among the points examined. The discrepancies identified then feed the discrepancy report and the regularisation plan. Finally, the origin matrix records the result of this check for each product.

Does the package cover relations with the customs administration?

No. The package prepares the company for post-clearance verification of origin, without representation before the customs administration. It also excludes customs clearance, as well as any settlement or negotiation on behalf of the client. These matters fall, where appropriate, to an authorised professional. Finally, the service carries no guarantee as to the outcome of a verification.

Do the documents submitted remain confidential?

The firm treats as confidential the bills of materials, supplier’s declarations, proofs of origin and invoices submitted. These documents circulate solely through the secure exchange space and serve only the purposes of the service. This obligation also survives the end of the relationship. Reciprocally, the client undertakes the same discretion with regard to non-public tools and deliverables.

Which tools and follow-ups relate to the package?

The supplier’s declaration template for EU preferential origin (O-03) completes the documentary chain. The customs settlement request template (O-04) relates, for its part, to another stage. The white paper “Preferential origin: documenting, verifying, securing” (LB-02) also explores the subject further. Finally, a need for recurring support falls under the Steering subscription (A-02).

Out of scope

The package excludes any representation before the customs administration, as well as customs clearance. Nor does it include any settlement or negotiation on behalf of the client. The issuing of proofs of origin also remains outside the service. Procedural acts, finally, fall to an authorised professional. No guarantee applies to the outcome of a verification.