The import document set and six places it goes out of line
Files are rarely rejected because a document is missing. They are rejected because the documents say different things about the same shipment.
This article is not a list of documents, you can find that anywhere. It is about the places where documents in the same set contradict each other, because that is what creates real cost.
What the basic file contains
- The sale contract or an equivalent document.
- The commercial invoice issued by the seller.
- A packing list itemised by package.
- The transport document, which depending on the mode is a bill of lading, an air waybill, or a road transport document.
- The import customs declaration.
- The certificate of origin, where you want the special preferential rate under an agreement.
- Licences, specialised inspection results and quarantine certificates, depending on the goods.
The list of customs documents for imported goods is set out in Circular 38/2015/TT-BTC, as amended and supplemented by Circular 39/2018/TT-BTC. Before applying it to a specific shipment, check whether it is still in force and look for the latest amendments.
Six places things go out of line
Goods description
The invoice carries a shortened trade name, the declaration carries the name from the goods nomenclature, and the certificate of origin carries whatever the seller is used to writing. Three names for one thing. The result is a request for explanation, delayed clearance, and where preferential tariff treatment is involved, a possible refusal of that treatment.
Quantity and weight
The packing list and the bill of lading differ by a few kilograms because of how tare weight was counted. It sounds minor, but for goods dutiable by weight it is a difference in money, and for goods subject to physical inspection it is grounds for a report.
Unit price and total amount
The invoice shows a discount on a separate line and the contract says nothing about that discount. A price reduction with no basis in the contract is usually not accepted when the value is determined.
Delivery terms
The contract says one thing, the invoice says another, and the bill of lading shows freight paid in a third way. This leads straight to a query on value.
Dates
A certificate of origin issued before the invoice date, or a bill of lading showing a loading date before the contract was signed. An impossible sequence of dates is always the first sign that gets a file examined closely.
Names and addresses of the parties
The consignee on the bill of lading differs from the importer on the declaration, or the seller on the invoice differs from the exporter shown on the certificate of origin. Sometimes there is a legitimate commercial reason for this, but it has to be explained in writing.
A ten minute cross-check routine
Before a file goes off for declaration I use exactly one method: open every document side by side and read down the columns instead of reading document by document. Read the goods description on every document, then the quantity on every document, then the dates. Read document by document and your brain fills in the gaps. Read down the columns and the mismatch jumps out.
This is the situation most prone to mismatch on the China to Vietnam corridor. Each factory issues its own invoice, but there is only one bill of lading and one declaration. Agree on the goods description and the package numbering when the order is placed, not when the goods are already sitting at the consolidation warehouse.
Record keeping after clearance
Clearance does not mean the matter is closed. Customs records must be kept for the purposes of a post-clearance audit, and the audit window is counted in years, not months. The file you keep should include the commercial correspondence explaining anything unusual, because a few years later nobody will remember why that shipment carried that price.