Understanding Audit Defensibility
When we talk about "audit-defensible" origin claims, we mean documentation and processes that can withstand detailed customs examination. This isn't about optimistic interpretations or assumptions. It's about building a foundation of evidence.
What Customs Authorities Look For
During an origin audit, authorities typically examine:
- Bill of Materials and Sourcing Documentation: Where do your components actually come from? Can you prove it?
- Value-Add Evidence: What transformation or substantial work occurs in the claimed country of origin?
- Cost Narratives: How does value accumulate through your supply chain? Can you document this clearly?
- Process Documentation: What exactly happens at each step? Is it documented consistently?
Building Defensible Claims
The key is working backwards from the audit scenario. Ask yourself: "If a customs officer requested documentation for this origin claim tomorrow, could I provide it?"
If the answer is anything other than a confident "yes," you have work to do.
Common Weaknesses We See
- Relying on supplier declarations without verification
- Incomplete or inconsistent process documentation
- Unclear value-add justifications
- Missing cost allocation records
- Assumptions about "minor" vs "substantial" processing
Our Approach
We assess your current origin claims against audit standards, identify gaps and risks, and build documentation frameworks that stand up to scrutiny. When claims aren't defensible, we say so, protecting you from future exposure.
