China imports: customs master data controls
Use a controlled product register that links each product revision to its approved commodity code, classification evidence, valuation treatment and importer identity. Give every broker the same approved instructions, reconcile declarations and route changes for review. Agree the factory evidence and shipment handover with Cambridge China Bridge.
Give the register an owner and approval controls
Appoint a customs data owner and named reviewers from procurement, finance and compliance. Let buying teams propose changes, but restrict approval and publication to authorised people. Mark records as draft, approved or withdrawn, with an effective date and a change history. These are recommended internal controls, rather than a prescribed register format.
Appointing a broker does not remove your responsibility for customs due diligence. Start by comparing current product records with declarations from every broker. Put conflicting codes, unexplained valuation treatments and uncertain importer identities into a review queue before treating any existing record as approved.
Record the product facts behind each decision
Key each record to your internal product identifier and specification revision. Map supplier references and broker descriptions to it. Avoid grouping variants solely because they share a commercial name. Use the commodity code guide for the classification decision and the importer identity guide for the importing arrangement.
Keep evidence alongside the approved fields so a reviewer can reconstruct the decision. Record who approved it and which products, entities and shipment arrangements it covers. The suggested register fields below connect product evidence to broker instructions.
| Record area | Approved fields | Supporting evidence |
|---|---|---|
| Product identity | Internal identifier, supplier reference, revision, materials and function | Specification, drawings, photographs and factory confirmation |
| Classification | Commodity code, rationale, scope and review date | Tariff wording, relevant notes and any applicable ruling |
| Valuation | Method, additions, exclusions and allocation approach | Contracts, tooling invoices and approved calculations |
| Importer and broker | Importing legal entity, EORI number, representation and authorised contacts | Entity records, written authority and instruction version |
| Control history | Status, approver, effective date and superseded version | Change request, review decision and broker acknowledgement |
Control valuation treatment separately from shipment costs
Store the approved valuation approach in the register, then calculate the shipment value from current invoices and costs. Record treatment of tooling, packing, freight, insurance and relevant royalties, including whether each amount is already in the goods price. Keep the allocation workings and track tooling allocations across shipments. The customs valuation guide explains which items belong in the value.
Give finance responsibility for identifying payments outside the goods invoice. Reconcile tooling allocations with their approved basis and review changes to expected production quantities. Keep invoice currency, the applicable HMRC customs exchange rate and the conversion calculation with the shipment record. Consistency means applying the same approved method to comparable transactions, rather than forcing every shipment to have the same value.
Issue the same approved instructions to every broker
A broker cannot act on your behalf without written instructions. Ask your customs broker to confirm how direct or indirect representation should be recorded. Check the broker representation authority guide, then link each broker's authority to the importing entity and approved instruction pack. Make the register extract part of that pack, alongside shipment documents and valuation workings.
Agree that brokers flag discrepancies before filing and refer proposed departures to your named reviewer. Ask them to acknowledge the instruction version and return the submitted declaration, reference and amendments. For UK customs and delivery, agree who supplies product evidence, who approves customs treatment and who gives filing instructions. Carry the same handover into container programmes.
Reconcile declarations and review changes
Match submitted declaration lines to the product revision, purchase order and shipment calculation. Compare commodity code, importer identity, currency, additions and customs value against the approved instructions. Use the broker declaration checking guide for entry checks. Log missing declarations and differences by product and broker, with an owner and a recorded resolution.
Route material, function, supplier, tooling, royalty, trading arrangement, importer and tariff changes for review. Retain the old version so historic entries remain traceable. If a review finds an error, identify affected declarations and agree the correction route with the broker and compliance lead; updating the register alone does not resolve earlier entries. Publish the approved change, obtain broker acknowledgement and check subsequent declarations.
Frequently asked questions
Can we use the same commodity code across all brokers?
Give every broker the approved code for the same product revision and import context, with supporting evidence. Refer disagreements to the customs data owner before filing.
Should we store a fixed customs value for each product?
Store the approved valuation method and treatment of additions. Calculate each shipment from its actual invoices and costs, retaining the workings and checking for amounts already included.
Who should approve customs master data changes?
Name a customs data owner. Procurement supplies product facts, finance checks valuation inputs and compliance reviews customs treatment. Restrict publication to authorised approvers.
What if a broker uses different customs data?
Compare the submitted entry with the approved instruction version. Record the reason, identify other affected shipments and agree any correction with the broker and compliance lead.