Supplier management and origin data collection
What the exam tests
This domain tests how to obtain reliable origin data from suppliers and convert it into a defensible claim. The focus is supplier declarations, bills of materials, HS mapping, validity periods, change management, and traceability.
Core controls
Collect supplier declarations at material level, not just a made-in label. A blanket declaration should identify the material, HS code, origin criterion, validity period, and authorized signatory. Link each declaration to the BOM and to the finished good's PSR. Refresh declarations before expiry and after any process, sourcing, or HS change. Treat unconfirmed materials as non-originating and test the PSR; never assume origin from a supplier's marketing statement.
Worked example
A BOM lists an imported motor that represents 12% of FOB. The supplier's declaration expired before shipment. The motor must be treated as non-originating. If the PSR is CTH and the motor's heading differs from the finished machine, the shift may still be met. If the motor shares the finished good's heading and de minimis is 10%, the 12% share causes failure until a valid declaration is obtained.
Traps
Relying on certificates rather than material-level declarations; not mapping supplier HS codes to the BOM; missing expiry dates; failing to update data after engineering changes; storing declarations without access controls.