1. Purpose
This policy sets out Murzo Group's approach to customs import and export compliance, trade documentation, customs declarations, commodity classification, origin, valuation, licences, permits, broker management, and customs records.
The purpose is to reduce customs, tax, sanctions, product safety, food safety, cultural property, security, and reputational risk when goods, samples, documents, prototypes, materials, equipment, food, fashion items, cultural objects, or other assets move across borders.
2. Scope
This policy applies to Murzo Group, its group companies, workers, contractors, suppliers, freight forwarders, customs agents, couriers, brokers, distributors, clients, and partners involved in import, export, re-export, temporary admission, returns, repair, samples, exhibitions, or cross-border movement.
It applies to physical goods, documents, prototypes, fashion items, textiles, food and feed, farming inputs, biological materials, chemicals, cultural objects, antiques, artworks, design materials, security-sensitive items, technology, and records.
3. Customs Principles
Murzo Group will take a documented, evidence-led, and risk-based approach to customs compliance.
- Goods must not be imported, exported, re-exported, shipped, returned, or transferred where required customs checks are incomplete
- Customs declarations must be accurate, complete, and supported by evidence
- Commodity codes, origin, valuation, quantity, description, and licence status must be reviewed before shipment where risk requires
- High-risk goods must be escalated before movement, including controlled goods, cultural objects, CITES materials, food, chemicals, dual-use items, arms-related goods, and high-value goods
- Murzo Group may stop, delay, reroute, reject, quarantine, or return goods where customs or legal status is unclear
4. EORI, Registration & Authorisations
Murzo Group will consider whether relevant EORI numbers, customs registrations, tax registrations, licences, permits, or customs authorisations are required before cross-border movement.
Where customs simplifications, temporary admission, inward or outward processing, duty relief, bonded storage, special procedures, or other authorisations are used, responsibilities and records must be controlled.
5. Commodity Codes, Origin & Valuation
Goods must be described and classified carefully. Commodity codes are used to determine customs duty, import VAT, licences, restrictions, preferential treatment, and other trade measures.
Origin and valuation must be supported by suitable evidence, such as supplier declarations, manufacturing records, invoices, purchase orders, bills of materials, contracts, transport documents, and professional advice where needed.
- Do not rely blindly on supplier commodity codes, overseas codes, or historic classifications
- Record the reason for classification decisions where the item is complex, high-value, restricted, or unusual
- Check rules of origin before claiming preference under a trade agreement
- Ensure invoices and shipping documents reflect the real transaction, value, currency, Incoterms, and party responsibilities
- Escalate uncertainty before shipment, not after goods reach the border
6. Licences, Permits & Restricted Goods
Some goods may require specific licences, certificates, health documents, export licences, import permits, cultural object licences, CITES permits, phytosanitary certificates, food or feed controls, strategic export controls, sanctions checks, or authority notifications.
Murzo Group must not move restricted goods unless required licences and checks are in place, valid for the goods, parties, route, value, destination, end use, and shipment date.
7. Customs Agents, Brokers & Freight Forwarders
Murzo Group may appoint customs agents, freight forwarders, couriers, express operators, or brokers to support customs clearance, but appointment of a third party does not remove Murzo Group's responsibility for due diligence on its own declarations and instructions.
Written instructions should define whether representation is direct or indirect, what information the agent may use, what documents are required, how errors are handled, and who must approve changes.
8. Documentation & Shipment Controls
Shipment files should contain sufficient information to evidence lawful movement and future audit.
- Commercial invoice, packing list, transport documents, tracking, and proof of delivery
- Commodity code, origin, value, currency, quantity, weight, Incoterms, and party details
- Licences, permits, certificates, customs declarations, duty and VAT evidence, and broker instructions
- Product specifications, safety data sheets, food or feed documents, CITES evidence, cultural object evidence, or technical files where relevant
- Records of holds, inspections, queries, delays, corrections, seizures, returns, or voluntary disclosures
9. Errors, Holds & Voluntary Disclosure
Where Murzo Group identifies a customs error, undeclared licence requirement, incorrect classification, incorrect valuation, missing permit, sanctions risk, or other irregularity, the matter must be escalated promptly.
Corrective action may include shipment hold, amendment, broker instruction, authority notification, voluntary disclosure, payment correction, customer communication, supplier review, or legal advice.
10. Records, Review & Responsibilities
Murzo Group will keep customs and trade records for a suitable retention period in line with legal, tax, audit, and operational requirements.
Procurement leads, logistics contacts, sales contacts, finance contacts, product owners, compliance leads, and authorised representatives are responsible for applying this policy. This policy will be reviewed periodically and when trade rules, product categories, markets, brokers, or customs arrangements change.
