Inward Processing - conditions and requirements: identification of the imported goods in the processed products
A condition of IP is that the imported goods must be identifiable in the processed products. If it is not possible to do this by physical means the trader must be able to produce documentary evidence which shows that the imported goods were used to produce the products declared for free circulation.
The means of identification must be specified on the application and authorisation. The following are suggested methods of identification:
- serial or manufacturers numbers
- plumbs, seals, clip marks or other distinctive marks fixed to the IP goods
- the taking of samples, illustrations or technical descriptions
- stock records or other supporting documents (contracts, correspondence, and invoices) which show clearly that the processed products have been manufactured from the entered goods.
This list is not exhaustive and any method proposed by the authorisation holder which enables the import goods to be identified can be accepted. Commission Delegated Regulation (EU) 2016/341 of 17.12.15, Annex 12 lists the methods to be used.
The applicant must state how the goods stated in form SP3 Box 7 will be identified in the goods produced in Box 8. For more complex processing operations or where a number of different items are incorporated into a finished product, the goods stated in Box 7 may not be readily identifiable in the processed product. A bill of materials or recipe code may help to establish the quantity of goods contained in a processed product but samples or an analysis of goods will usually be required.
If use of equivalence (see SPE13315) has been applied for, the details in Boxes 18 of the SP3 must be sufficient for a comparison to be made between free circulation materials used and those materials that will be entered to IP.