A Certificate of Conformity (CoC) is not owned by the customs broker who submits it — it is the legal responsibility of the Importer of Record (IOR). Under national customs frameworks including Section 101 of the South African Customs and Excise Act, the EU Customs Code (UCC), and US 19 CFR Part 141, the Importer of Record carries 100% of the legal liability for the accuracy, retention, and validity of all trade documentation for a minimum of 15 years. The customs broker is a transaction agent: they submit the declaration on behalf of the importer, but the importer bears criminal fraud liability if a document is fake, altered, or non-compliant. This distinction matters enormously in practice. When an importer changes brokers — which happens frequently due to pricing or route changes — their compliance archive does not transfer. Most importers have no system for this: they forward PDFs by email, store files in shared drives, and rely on their broker to handle it. When the document is wr...