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Certification, origin and grey-market imports

Certification, country of origin and parallel import become dispute issues where the documents do not support the legality of the supply chain from manufacturer to release.

01Documentwhat was received or submitted02Deadlinewhen it was received and the current deadline03Riskwhat risk arises from silence or an incorrect response04Next stepresponse, administrative appeal, claim letter or court application

Where the position usually weakens

A position weakens when the document, deadline and evidence do not fit together. Start with the facts, response period and evidence chain.

01certificates and declarations do not match the actual goods or stated origincertificates and declarations should match the actual goods and their origin
02the supply chain does not clearly show why the goods are lawfully sourced and traceablethe chain should show the lawful source of the goods
03trying to repair the issue only after import can turn it into a dispute about the entire shipmenta pre-import review identifies the applicable requirements before a dispute begins

What to check now

Start with the documents that explain the facts, deadline, money, goods and parties' actions rather than collecting the entire archive.

01

Compare product identification across the contract, invoice and technical records.

02

Check which goods and shipment the available conformity document actually relates to.

03

Compare stated origin with manufacturer, seller and shipment documents.

Related situations and materials

Customs dispute in a Russian commercial court

A customs decision has been issued or an administrative appeal rejected. A court challenge under Article 198 of the Russian Commercial Procedure Code requires close attention to the deadline, evidence and precise relief sought.

Post-release customs control

A post-release customs review under Article 332 of the EAEU Customs Code can revisit an earlier shipment. The key issue is whether the documents, payments and logistics form one coherent account.

Labelling and participant roles in imports

Import labelling depends on participant roles, the EAEU tariff code and the rules governing circulation of the goods. An error can lead to a review, document dispute or administrative-liability issue.

Import from the EAEU by road: DOPP, QR and labelling do not match

If transport data, the contract, invoice, universal transfer document, DOPP/QR data or labelling codes do not match, first identify where the discrepancy arose: shipment, electronic document, import tax documents or product data.

Audit of international trade and contract documents

The company has not yet received a request or entered an inspection, but already sees that the contract, transaction file or import model may not withstand a serious customs or tax query.

Customs relief and tariff preferences

The company claims preferential treatment, but customs refuses or later withdraws the preference. That can lead to recalculation of duties and, depending on the facts, administrative-liability issues.

Sanctions risk and parallel imports

Even an agreed shipment can be delayed by a bank, logistics provider or customs if the transaction raises unresolved sanctions-compliance issues.

Simple assembly does not necessarily change country of origin: EAEU rules and reclassification risk

When 'Made in…' affects the duty rate and the goods’ tax treatment. An examination of origin rules, Articles 28–29 of the EAEU Customs Code and common errors in reasoning about secondary assembly.

Questions and answers on documents and evidence in international trade

Questions on shipment files, evidence structure, correspondence, technical descriptions and preparing responses to customs requests.

Questions and answers on complex imports and project shipments

Questions on non-standard shipments, equipment, multiple contracts, project deadlines and cascading delays.

Materials on this issue

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