On 31 March 2026, the Krefeld District Court in Germany convicted a Chinese national operating a German import company for evading EU anti-dumping duties on aluminium foil. The scheme involved falsely declaring Myanmar as the country of origin, despite the goods being manufactured in China. Minimal processing in Myanmar was used to disguise the true origin, and false Certificates of Origin (COOs) were submitted to EU customs authorities.
The penalties were significant: a suspended prison sentence of 1 year and 8 months, a €100,000 fine, and confiscation of over €321,000 in assets. The fraud resulted in approximately €610,000 in duties being evaded. This case underscores that false origin declarations are treated as serious customs fraud, with both criminal and financial consequences.
For compliance professionals, the key lesson is clear: ignorance is not a defence. Importers are legally responsible for the accuracy of origin declarations, even when relying on supplier-provided COOs. Authorities expect companies to exercise reasonable care and due diligence.
Practical Due Diligence Tips
- Verify supplier capacity: Assess whether the claimed country of origin has the industrial capability to produce the goods.
- Audit documentation: Request supporting production records, invoices, and shipping data.
- Watch for red flags: Minimal processing or sudden shifts in declared origin should trigger deeper review.
- Maintain records: Document all verification steps to demonstrate good faith compliance.
- Train staff: Ensure procurement, logistics, and compliance teams understand COO rules and risks.
Key Takeaway
This case is a reminder that COO misrepresentation can expose importers to severe penalties. Compliance professionals should reinforce due diligence practices and ensure that COO verification is embedded into daily operations.
Please refer to the following news release from the European Public Prosecution Office: