How we work
Product that cannot be certified cannot be sold.
Every market has a gate, and the gate moves. A supplier who treats conformity as paperwork to be assembled at shipment discovers the problem at the destination port, where there is no remedy. We treat it as a design input at quotation stage.
01Economic operator
Who carries the obligation, and why we structure it that way.
Almost every conformity obligation in international trade attaches to the importer of record in the destination market, not to the seller. That choice is made through the Incoterm.
We sell CIP or DAP as standard. The buyer is the importer of record, and we supply the complete documentation set that allows them to discharge that role. We sell delivered duty paid only where a deliberate assessment has been made and a compliant local establishment exists.
This is not a way of pushing risk downstream. It is the structure that keeps the obligation with the party who can lawfully hold it, and it is why our documentation has to be complete rather than adequate.
02Regimes
Seven regulatory regimes, maintained continuously.
| Market | What is required | What we hold |
|---|---|---|
| European Union | CE marking under Regulation (EU) 2024/3110, which applies from 8 January 2026, with the Declaration of Performance and Conformity, the assessment and verification system appropriate to the product family, and notified body involvement where the system requires it | Manufacturer declarations, notified body certificates, initial type test reports, factory production control certification, and the technical documentation set, retained for ten years |
| United Kingdom | UKCA or CE, both of which remain acceptable for construction products placed on the market in Great Britain, plus third-party certification where the market expects it and Building Safety Act 2022 product obligations | Designated standard evidence, approved body certificates, and full product traceability against the retrospective liability created by section 149 of the Building Safety Act |
| United States | No single mark. Compliance is proven to the code official by test report to a code-referenced standard, by evaluation report from ICC-ES or IAPMO UES, or by listing with a nationally recognised testing laboratory such as UL or Intertek ETL. Plus NSF/ANSI 61 and 372 on anything wetted by drinking water, and state overlays including Florida Product Approval, Miami-Dade Notice of Acceptance, CARB and TSCA Title VI | Evaluation reports, listings, potable water certification, state approval numbers, and formaldehyde certification with lot labelling |
| Gulf Cooperation Council | Saudi Arabia requires a Product Certificate of Conformity on the SABER platform followed by a per-consignment Shipment Certificate of Conformity, obtained before arrival. The United Arab Emirates requires ECAS registration and, for fire products, cladding and insulation, separate Civil Defence listing per product and per manufacturer | Standing product certificates, per-shipment certificates issued in advance of sailing, Civil Defence listings, and G-Mark where required |
| Africa | Pre-shipment conformity under SONCAP in Nigeria, PVoC in Kenya, Tanzania and Uganda, CBCA in Zimbabwe, PECAE in Cameroon and equivalent schemes elsewhere. The certificate must be issued in the country of export before shipment. There is no cure at destination | Route B and Route C product registrations and licences at factory level for repeat lines, which removes per-shipment testing from the critical path |
| Australia and New Zealand | WaterMark certification, which is mandatory for scheduled plumbing products, plus separate statutory WELS registration, CodeMark where used, and AS/NZS standards | WaterMark certificates and database listings, WELS registrations, and product-specific evidence |
| India | Bureau of Indian Standards certification under the Foreign Manufacturers Certification Scheme, made mandatory across a widening list of construction products by Quality Control Orders | Licence numbers and scope, assessed product by product |
03Trade defence
The duty screen runs before the quotation, not before the shipment.
Anti-dumping and countervailing duty positions, safeguard quotas, tariff measures and carbon border adjustment obligations change continuously, and they can exceed the entire margin on a trade several times over.
Every quotation we issue runs a screen, per line item, per origin, per destination: current anti-dumping and countervailing orders, safeguard and quota position, tariff exposure, carbon border adjustment coverage, forced labour exposure, timber traceability requirement, and origin substantiation.
We also do something less common: where the right answer is that the product should not come from the origin the buyer assumed, we say so. Changing origin at quotation stage is a commercial conversation. Discovering the duty at customs is not.
04Origin
A Hong Kong invoice does not change origin.
Origin is determined by where goods were wholly obtained or last substantially transformed. A certificate of origin issued in Hong Kong certifies Hong Kong origin only where Hong Kong processing meets the origin criteria. It does not, and cannot, launder the origin of goods manufactured elsewhere.
We hold a written non-preferential origin determination for every line item, with the substantial transformation reasoning recorded. We require factory audit evidence of actual production capacity at the claimed origin.
We never accept an origin claim supported only by a certificate. Where the duty differential between two origins is large, we treat the transaction as high risk by default and require enhanced evidence.
Anyone who offers to route goods through a third country to change their origin should be removed from your supplier list. We remove them from ours.
05What is changing
The regulatory horizon we track.
| From | Change | Affects |
|---|---|---|
| 1 January 2026 | European Union Carbon Border Adjustment Mechanism definitive regime | Cement, iron and steel, aluminium, including downstream fasteners and aluminium structures |
| 8 January 2026 | Construction Products Regulation (EU) 2024/3110 applies, replacing 305/2011, with new harmonised technical specifications phased in product family by product family | All construction products placed on the European Union market |
| 1 July 2026 | European Union Steel Regulation replaces the steel safeguard, with a reduced duty-free quota, a higher out-of-quota rate and a melt-and-pour origin regime | Structural steel, reinforcement, sections, tube |
| 30 December 2026 | European Union Deforestation Regulation applies, requiring plot-level geolocation of timber harvest in a Due Diligence Statement | Plywood, panel products, wooden joinery, wood flooring, wooden furniture, prefabricated buildings |
| 1 January 2027 | United Kingdom Carbon Border Adjustment Mechanism | Aluminium, cement, iron and steel |
| 30 June 2027 | European Union Deforestation Regulation extends to micro and small operators | As above |
| 14 December 2027 | European Union Forced Labour Regulation applies | All product categories |
Position as at August 2026. Reviewed quarterly.
Not sure what your market requires?
Tell us the product and the destination. We will map the conformity route, name the certificates needed and tell you what it adds to the programme.
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