1. Purpose
This policy defines how Murzo Group identifies importer of record, exporter of record, declarant, consignee, consignor, broker, freight forwarder, and fiscal or customs representative responsibilities before goods move across borders.
The purpose is to avoid accidental customs liability, blocked shipments, incorrect declarations, unauthorised broker instructions, unexpected duty or VAT exposure, and unclear authority responsibility.
2. Scope
This policy applies to imports, exports, re-exports, returns, repairs, samples, temporary movements, exhibitions, prototypes, spare parts, packaging, cultural objects, food, farming materials, fashion products, security-sensitive items, controlled goods, and goods moved through third-party platforms or fulfilment providers.
3. Role Clarity Before Movement
No cross-border shipment should be arranged until Murzo Group understands who is legally acting as importer of record, exporter of record, declarant, and party responsible for customs instructions.
Where Murzo Group is not the importer or exporter of record, the contract, purchase order, freight instruction, or commercial arrangement should make the position clear.
- Name and address of the party responsible for import clearance
- Name and address of the party responsible for export clearance
- EORI or local customs identification where required
- Broker or forwarder appointment and authority limits
- Commodity code, origin, valuation, licence, permit, and restriction responsibility
- Who pays duties, taxes, storage, inspection, penalties, and return costs
4. Customs Broker Appointment
Murzo Group may use customs brokers, freight forwarders, couriers, or logistics providers, but appointing a broker does not remove Murzo Group's responsibility where Murzo Group is the declarant, importer, exporter, or instructing party.
Brokers must be given accurate instructions. Murzo Group must not knowingly ask a broker to understate value, misdescribe goods, use an incorrect origin, avoid a licence, split a consignment improperly, or declare a party without authority.
5. EORI and Customs Identification
Where an EORI number or other customs identification is required, Murzo Group will use the correct number for the territory and transaction type. GB, XI, EU, or local identifiers must not be used interchangeably unless permitted by the applicable customs authority.
If Murzo Group is not established in the destination territory, specialist advice may be required before Murzo Group agrees to act as importer of record or appoints an indirect representative.
6. High-Risk Movements
The following movements require additional review before commitment because role errors can create serious customs, tax, safety, or criminal exposure.
- Controlled, dual-use, defence, security, firearms, weapons, explosive, or surveillance items
- Cultural property, antiquities, human remains, sacred objects, protected species, or CITES-sensitive goods
- Food, feed, animal products, plants, plant products, soil, water, biological material, or farming inputs
- Chemicals, cosmetics, textiles, electrical goods, batteries, WEEE, packaging, waste, or hazardous goods
- Goods involving sanctions, embargoes, high-risk destinations, unknown end users, or unusual payment routes
- Goods returned after rejection, repair, exhibition, testing, or temporary admission
7. Required Evidence Only
Customs, tax, shipping, and broker evidence should be limited to what is required by law, contract, insurance, authority request, dispute handling, or operational need. It should be accurate, accessible to authorised people, and not duplicated without reason.
8. Prohibited Conduct
- Using another party's customs number without authority
- Allowing a broker to submit a declaration based on guesses when key facts are missing
- Declaring samples as no value when they have a customs value
- Misdescribing goods to avoid controls, duty, VAT, inspection, or licence requirements
- Agreeing to be importer of record in a foreign country without understanding tax, product, and authority obligations
9. Review
This policy will be reviewed when Murzo Group changes logistics model, appoints a new broker, starts shipping to a new jurisdiction, or takes on importer or exporter responsibility in a new market.
