Using Manual Commercial Documents for Korea-UK FTA Origin Certification During System Outages Released

Structure of Korea-UK FTA Origin Declarations and Recognition of Commercial Documents

The Korea-UK FTA follows the implementation framework of the previous Korea-EU FTA. It utilizes a self-certification system where the exporter provides an origin declaration on commercial documents rather than using a standardized Certificate of Origin (C/O) form. According to the agreement, an origin declaration is made by typing, stamping, or printing the prescribed text onto an invoice, delivery note, or any other commercial document that describes the products in sufficient detail to enable identification.

Crucially, there is no restriction requiring documents to be generated specifically from an automated computer system. Therefore, even if your headquarters' ERP or invoicing system is undergoing updates, you may manually prepare an invoice or packing list (using Word, Excel, etc.) that clearly states the product description, quantity, and price. Such documents are legally valid for origin declaration purposes.

Exporter Certification Requirements and Value Thresholds

The authority to issue an origin declaration depends on the total value of the UK-made engines. Under the Korea-UK FTA, if the total value of the shipment exceeds 6,000 EUR, the origin declaration must be issued by an Approved Exporter authorized by the UK customs authorities. For shipments valued at 6,000 EUR or less, any exporter can issue the declaration. Given the high value of engine units, it is highly likely you will exceed this threshold; therefore, you must ensure the Customs Authorization Number of the headquarters is accurately included.

Even for manually prepared documents, the following requirements must be met to apply for preferential tariff rates:

• Standard Origin Declaration Text: The mandatory English phrase must be used exactly: "The exporter of the products covered by this document (customs authorisation No ...) declares that, except where otherwise clearly indicated, these products are of UK preferential origin."
• Customs Authorization Number: For shipments exceeding 6,000 EUR, the authorization number must be inserted into the parentheses within the declaration text.
• Exporter’s Signature: While signatures may be waived for certain Approved Exporters, it is highly recommended to obtain a document with a physical signature and company stamp to prevent potential correction requests during customs clearance.

Post-Clearance Management and Compliance Precautions

Manual documents prepared during a system outage must maintain originality at the time of the import declaration. If there are discrepancies in dates or document numbers between the manual invoice and a system-generated invoice issued after the system is restored, the credibility of the origin evidence may be questioned during a post-clearance audit. You must ensure consistency between the manual documents, the restored system data, and the Bill of Lading (B/L).

Furthermore, commercial documents used for origin declarations must be retained for five years from the date of import acceptance. High-value items like engines are frequent targets for customs origin verifications. To mitigate risks during a future Origin Verification, it is safest to store copies of the manual documents alongside internal evidence of the system failure, such as official notices or email correspondence from headquarters.