Guidelines on Issuing Separate Export Declarations for Different Manufacturers Under a Single B/L for Duty Drawback Released

In international trade, it is common practice to consolidate multiple Purchase Orders (POs) into a single shipment at the request of an overseas importer. However, when the purpose is specifically for duty drawback (refund of customs duties), meticulous attention to documentation and declaration methods is required. If the manufacturers of the goods are different, please follow this practical guide to satisfy customs administration and drawback requirements.

1. Necessity of Issuing Separate Export Declarations for Different Manufacturers

According to the Notification on the Handling of Export Customs Clearance Procedures by the Korea Customs Service, the 'Manufacturer' field on an export declaration must accurately reflect the entity that actually produced the goods. To claim a duty drawback, the manufacturer's information must be explicitly stated on the export declaration to prove their eligibility for the refund.

Since the current export declaration system does not allow for multiple manufacturers to be listed under a single declaration number, separate declarations must be filed for each manufacturer for the following reasons:

• Eligibility for Duty Drawback: For a manufacturer to receive a refund directly or via an agent, their name must be uniquely identified in the 'Manufacturer' field. If goods from two different manufacturers are combined into one declaration, one manufacturer will be omitted, making them ineligible for a drawback.
• Rules of Origin and Post-Management: Different manufacturers may have different criteria for determining the country of origin and different supporting documentation. Separate declarations prevent administrative errors and ensure accurate statistical reporting.
• Administrative Costs: Please be advised that since a unique export declaration number is generated for each manufacturer, customs brokerage fees will be charged per declaration (e.g., two sets of fees for two manufacturers).

2. Practical Procedures for Consolidating Multiple Declarations into a Single B/L

Even if export declarations are filed separately, the goods can be consolidated into a single Master B/L (or House B/L) for logistical efficiency. This involves matching multiple Export Declarations (EDs) to a single Bill of Lading (B/L). The following steps should be followed:

When requesting export clearance from your customs broker, you must provide a Commercial Invoice and Packing List separated by manufacturer. The quantity, weight, and value of the goods in each declaration must exactly match the manufacturer’s PO to avoid issues during the drawback process.

Once the declarations are issued, provide the two export declaration certificates to your freight forwarder and request consolidation into a single B/L. The forwarder will then transmit the manifest to customs, matching both export declaration numbers to the single B/L. This step is critical to ensure that the confirmation of export loading is processed for each declaration, enabling the duty drawback.

3. Documentation Strategy for the Importer (Consignee)

It is crucial to distinguish between 'documents for domestic customs clearance' and 'documents for the overseas importer.' While documents are separated by manufacturer for domestic purposes, the Shipping Advice sent to the importer should focus on their convenience and consistency with the B/L.

• Preparation of a Consolidated Invoice: Since the importer receives the goods under one B/L, they will likely require a single, consolidated Commercial Invoice and Packing List. Prepare these integrated documents separately for the importer’s use.
• Ensuring Data Consistency: The total quantity, total weight, and total amount on the consolidated documents must match 100% with the sum of the two separate export declarations. Any discrepancy can cause significant issues during customs clearance in the importing country.
• Post-Clearance Management: Maintain internal records of both the consolidated documents and the manufacturer-specific declarations. This will be essential for future customs audits or verification requests from the Korea Customs Service regarding the drawback.

In conclusion, to ensure a smooth duty drawback for domestic manufacturers, export declarations must be issued separately by manufacturer, while logistics should be consolidated into one B/L via the forwarder. Regarding the additional customs fees incurred, it is standard practice to discuss cost-sharing with the manufacturers who benefit from the drawback.