Establishing the Validity Period for a Blanket Certificate of Origin Upon Resale: Independence from Producer's Original Dates Released

Understanding the Blanket Certificate of Origin

The Blanket Certificate of Origin (also known as a Comprehensive Certificate of Origin) is a critical document within the domestic supply chain. It certifies that the goods supplied meet the Rules of Origin criteria stipulated by specific Free Trade Agreements (FTAs). This document is typically issued when raw materials or finished goods are supplied continuously or repeatedly to the same producer or exporter.

According to the Act on Special Cases of the Customs Act (FTA Special Act), a Blanket Certificate of Origin can be issued with a validity period not exceeding 12 months from the date of the supply of goods.

Determining the Validity Period for Resale

Regarding your inquiry about re-supplying goods initially covered by a certificate valid from June 1, 2018, to December 31, 2018: Your new certificate's validity period is not legally restricted by the specific dates of the original producer's certificate.

The key factor is the "12 months from the date of supply" rule. The validity period of the certificate you issue must be set based on the date you supply the goods to the subsequent buyer, not the date you originally purchased them.

For example, if you supply the goods to a new company on October 26, 2024, you may set the validity period of your Blanket Certificate of Origin from October 26, 2024, up to October 25, 2025. The producer's original period (June–December 2018) does not dictate the start or end date of the certificate you issue for the resale.

Key Compliance Considerations

While the dates are independent, you must adhere to the following compliance obligations:

• Verification of Origin Status: Do not simply issue a certificate based solely on the existence of the previous document. You must ensure the goods still meet the FTA origin criteria. If a significant amount of time has passed or regulations have changed, you may need to request updated data from the domestic producer to confirm valid origin status.
• Record Retention: Businesses issuing a Certificate of Origin are required by law to retain relevant supporting documents for 5 years. This is mandatory to prepare for potential origin verification audits by customs authorities.
• Accurate Data Entry: The certificate must accurately reflect the goods' details, including HS Code, specifications, and model names, to ensure the buyer can correctly apply for FTA preferential tariff rates.

Conclusion

In summary, the validity period of your Blanket Certificate of Origin should be calculated starting from the date you supply the goods to your customer, not exceeding 12 months. It is not limited by the expiration date of the original certificate you received. However, ensuring the continued validity of the origin criteria and maintaining proper records is essential.