Can a Single FTA Certificate of Origin be Used for Split Import Clearances from a Bonded Warehouse? Released

Inquiring whether a single FTA Certificate of Origin (CO), issued for the total weight of the initial shipment, can be used for multiple partial clearances after storing bulk raw materials in a bonded warehouse is a frequent and significant practical issue. To summarize, it is possible to file split import declarations using a single CO after storing the goods in a bonded warehouse. However, strict adherence to specific requirements and procedures is mandatory.

The fundamental prerequisite is that the identicality between the goods listed on the CO and the goods being partially imported must be verifiable. Customs authorities focus on confirming that the goods declared in each split shipment are identical to the originating goods specified in the initial FTA CO.

Key Considerations for Verifying Identicality

Customs authorities comprehensively review the following factors to verify identicality:

• Nature of Goods and HS Code: The item name, specifications, model, and HS code of the imported goods must match the details listed in the initial FTA CO.
• Transparency in Quantity Management: This is one of the most critical aspects. FTA preferential treatment applies only to the remaining balance after deducting previously cleared quantities from the total on the CO. For every clearance, the importer must clearly record (endorse) the cleared quantity, clearance date, import declaration number, and remaining balance on a copy of the FTA CO.
• Consistency of Related Documents: Documents submitted during import declaration (Commercial Invoice, Packing List, B/L) and bonded warehouse records must be consistent with the FTA CO. Specifically, the warehouse inventory system must clearly track entry dates, quantities, and storage locations to respond immediately to Customs verification requests.
• Appearance and Packaging: In some cases, physical inspections may be conducted to verify that the exterior and packaging of the goods are identical to those at the time of initial import.

Practical Precautions and Procedures

• Validity of the Certificate of Origin: Generally, an FTA CO is valid for 12 months from the date of issuance. Ensure the CO remains valid at the time of each split import declaration.
• Utilization of Originals and Copies: Typically, the original FTA CO is submitted during the first import declaration. For subsequent split clearances, a copy of the FTA CO containing the history of the initial clearance, the current cleared quantity, and the remaining balance must be submitted. The original should be safely archived as Customs may request its presentation.
• Role of the Bonded Warehouse: Bonded warehouses provide flexibility by allowing goods to be stored under foreign status. Entry and exit records from the warehouse serve as crucial evidence for proving identicality.
• Customs Requests for Vindication: Due to the nature of split clearances, Customs may request additional data or explanations to verify identicality. Importers must be prepared to promptly submit supporting documents (warehouse entry/exit slips, inventory ledgers, initial purchase contracts, etc.).
• Record Retention Obligation: Importers are legally required to retain all documents related to FTA-preferential imports for five years from the date the import declaration is accepted. This includes the original FTA CO, copies with split clearance history, commercial invoices, transport documents, and warehouse records.

This method of split clearance offers significant benefits for logistics and cash flow management by enhancing inventory flexibility and allowing duty benefits upon each partial entry. However, accurate document management and rigorous proof of identicality are essential. Negligence or insufficient documentation can lead to the denial of FTA preferences and the imposition of penalty taxes.

If you face complex situations or have questions, consulting with a customs broker or the competent customs office is the safest and most prudent approach to ensure compliance with all procedures and requirements.