Verification of Supplier's Declaration - Non-Preferential Origin

Purpose

To ensure that supplier declarations claiming non-preferential origin are accurate, legally compliant, and auditable for EU customs purposes.

Step 1: Collect the Supplier Declaration

• Obtain a completed supplier declaration for all goods, including:

  • Product description and Commodity code.

  • Country of origin.

  • Basis of origin (wholly obtained or substantially transformed).

  • Signature, company details, and date.

• Ensure the declaration is dated, legible, and signed by an authorized representative. 

Step 2: Verify Supplier Credentials

• Confirm the supplier is legitimate and traceable.

• Check:

  • Legal registration of the supplier.

  • Manufacturing locations.

  • Historical compliance with customs documentation.

Step 3: Check Completeness of the Declaration

• Ensure all required fields are completed:

  • Product description matches your purchase.

  • Commodity code matches the EU customs classification.

  • Country of origin is stated.

  • Basis of origin (wholly obtained/substantial transformation) is clear.

  • Declaration is signed and dated.

Step 4: Validate Basis of Origin

• For wholly obtained goods:

  • Confirm that all production, extraction, or harvest occurred in the stated country.

  • Request supporting documentation if necessary (e.g., harvest records, production logs).

• For substantially transformed goods:

  • Confirm that processing in the stated country was economically justified and resulted in a substantial transformation:

    • Check change in tariff classification (Commodity code).

    • Check change in physical/chemical properties or composition.

    • Ensure processing was more than minimal operations (not just cleaning, packaging, sorting).

Step 5: Check Supporting Evidence

• Review:

  • Invoices for raw materials.

  • Production or processing logs.

  • Bills of lading.

  • Quality certificates or process descriptions.

• Ensure consistency between documentation and the declaration.

Step 6: Cross-Check Against Legal Requirements

• Verify compliance with:

  • UCC Articles 148-152 (non-preferential origin rules).

  • Delegated / Implementing Acts (Annex 22-01, list of primary rules, minimal operations).

• Ensure the declared origin aligns with EU customs rules and relevant CJEU case law (e.g., C-86/24 CS STEEL).

Step 7: Approve or Request Clarification

• If all criteria are satisfied:

  • Approve the declaration for use in customs procedures.

• If inconsistencies are found:

  • Contact supplier to provide additional information or correct the declaration.

• Keep all correspondence for audit purposes.

Step 8: Record Retention

• Retain the supplier declaration and all supporting documents for at least 3-5 years (EU standard for customs audits).

• Store in a retrievable format (electronic or paper) linked to the relevant shipment.

Step 9: Periodic Review

• Review supplier declarations periodically (at least annually) to:

  • Confirm consistency with current supply chains.

  • Ensure compliance with updates to UCC or Delegated Regulations.

  • Flag changes in production location or processing steps that may affect origin.

This procedure ensures that your non-preferential origin declarations are reliable, auditable, and legally defensible in case of customs verification or post-clearance checks.