Customs Documentation Checklist for Frozen Food Exports

Most documentation problems are not missing documents. They are documents that exist but disagree with each other, or that were issued after the moment they were needed as an input.

This checklist is organised the way the work actually happens: by who issues the document and when it has to exist.

Issued by the seller, before loading

**Proforma or commercial invoice.** Must state the Incoterms 2020 rule and the named place, the currency, the commodity description matching the customs classification, the net and gross weights and the total value. The description on the invoice is the description the declaration will use, so an internal product name that means nothing to a tariff is a problem.

**Packing list.** Produced from the actual load, not from the order. Lot numbers, carton counts per lot, cartons per pallet, pallet count, net and gross weights. If a pallet was rebuilt during loading, the packing list has to reflect the rebuild.

**Certificate of analysis per lot.** Issued against the lot codes on the cartons in the packing list. A certificate that names a lot which is not on the truck is worse than no certificate, because it invites the question of what else does not match.

**Specification sheet.** The agreed technical specification for the product as shipped. Keep the version number on it. A dispute about grade is resolved against a version, not against a memory.

**Declaration of compliance for food contact packaging.** Available on request under Regulation (EC) No 1935/2004, and for plastics under Regulation (EU) No 10/2011. Buyers ask for this more often than exporters expect.

Issued by the seller or the carrier, at loading

**CMR consignment note.** The contract of carriage. Check that the consignee, the place of delivery and the goods description match the invoice, and that the temperature instruction is written on it. A reefer instruction that exists only in an email is an instruction that did not exist.

**Temperature logger placement record.** Which loggers, which serial numbers, where in the load. Two loggers in known positions are worth more than four in unknown ones.

**Pre-cooling and loading temperature record.** The product temperature at loading and the trailer temperature before loading. This is the document that separates a supplier problem from a carriage problem later.

Issued by third parties, before shipment

**Certificate of origin.** Issued by the competent chamber or authority, where a preferential rate or a buyer requirement calls for it. Check the exporter name matches the invoice exactly.

**Phytosanitary certificate.** Required for certain plant products under Regulation (EU) 2016/2031. Whether a frozen product needs one depends on the commodity and the processing, so confirm with the competent authority rather than assuming that freezing removes the requirement.

**Certificate of inspection for organic goods.** Issued in TRACES NT by the control body, and it must exist before the consignment is presented at entry. Check the consignment description on the certificate against the invoice and the declaration, because a mismatch here is not a paperwork issue, it is a loss of organic status for the lot.

**Certification scheme certificate.** BRCGS, IFS Food, FSSC 22000 or equivalent, valid on the shipment date, with a scope annex that covers the exact product category and process. Buyers read the annex. Send it.

Issued by the importer or their agent, at entry

**Customs declaration.** Lodged by or on behalf of the importer, using the confirmed commodity code.

**EORI number.** The importer must hold one. This is a prerequisite, not a document you produce at the border.

**Common health entry document and pre-notification** where the commodity, origin and current control frequencies require it under Regulation (EU) 2017/625 and Regulation (EU) 2019/1793. Confirm the current position for the commodity before each season.

What the importer needs from you, and when

The importer is preparing a declaration against a deadline they do not control. Working backwards from that deadline gives a simple rule: everything the declaration depends on has to be in their hands before the truck reaches the frontier.

• At order confirmation: the commodity description you intend to invoice, so the code can be confirmed; the certification certificate and its scope annex; the organic certificate where relevant.
• One week before loading: the draft invoice and the expected pallet and weight figures, so nothing at the border is a surprise.
• At loading, same day: the final invoice, the packing list generated from the actual load, the certificates of analysis for the lots loaded, the CMR and the loading temperature record.
• On the road: the certificate of inspection reference for organic goods, if it was not already issued.

An importer who receives a complete file at loading will clear on arrival. An importer who receives it on arrival will clear a day later, and the reefer runs through that day.

Retention: how long to keep what

Retention periods come from different places and it is easier to apply one internal rule than to track them separately.

• Food law traceability records under Article 18 of Regulation (EC) No 178/2002: keep for the shelf life of the product plus a margin, and in practice for several years.
• Temperature records for quick-frozen foodstuffs under Commission Regulation (EC) No 37/2005: keep for at least the period the regulation sets, and longer where a buyer contract requires it.
• Customs and origin records: long, and driven by the possibility of post-clearance verification. Follow the importer’s requirement, which is normally the longer one.
• Certification scheme records: as required by the scheme, checked at each audit.

The practical rule most exporters settle on is a single retention period covering all of them, applied per consignment folder, with the folder named for the CMR number. It costs nothing and it removes an entire category of argument.

A one-page pre-departure check

Run this on the morning of loading. If any line fails, the truck does not leave.

1. Certificate valid on the shipping date, scope annex covers the product and process.
2. Commodity code confirmed in writing by the agent for this shipment.
3. Packing list generated from the actual load, weights reconciled with the invoice and the CMR.
4. Certificates of analysis issued for every lot on the packing list, and no lot on a certificate that is not on the truck.
5. Loggers placed and recorded, trailer pre-cooled, product temperature recorded at loading.
6. CMR carries the temperature instruction and the correct consignee and delivery place.
7. Organic certificate of inspection issued, or a confirmed issue time before arrival.
8. Full document set sent to the importer and the buyer.

The five errors that cause most of the trouble

1. **Weights that do not reconcile.** Invoice, packing list and CMR showing three different gross weights. Fix the process, not the document: generate all three from the same loading record.
2. **A lot on the certificate of analysis that is not on the truck.** Usually caused by issuing certificates from the production plan rather than from the load.
3. **A commodity description that no tariff recognises.** Internal names, marketing names and abbreviations belong in the specification, not on the invoice.
4. **A certificate whose scope does not cover the product.** The site is certified, the product category is not. Read the annex before shipping, not after the buyer does.
5. **Documents sent after the truck.** The importer needs the file to prepare the declaration. Sending it on arrival means the file becomes the delay.

A practical filing rule

Keep one folder per consignment, named for the CMR number, containing every document listed above plus the temperature download after delivery. When a buyer asks a question eight months later, the answer is in one place, and the ability to answer it in an hour is itself a commercial asset.