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  4. How to Verify a Chinese Pencil Factory is Real — 5-Step Due Diligence Before You Order

How to Verify a Chinese Pencil Factory is Real — 5-Step Due Diligence Before You Order

Before you wire a deposit to a Chinese pencil supplier, verify their legal identity. Business license cross-check, certification traceability, factory address verification — the 5 checks that separate real manufacturers from brand shells.

Buyer GuideBy David Wu, CEO22 May 20269 min read

A Factory Name on a Website is Not a Factory

A supplier website can look professional and still hide who owns production. Before you pay a deposit, verify the legal company, factory address, FSC holder, BSCI audit entity, and invoice name all point to the same manufacturer.

The single most important due diligence question: Does the company name on the website match the company name on the business license? Does the business license name match the certification holder name? If these three names are not identical, you are not dealing with a transparent manufacturer — you are dealing with a brand shell. Every major European retailer's compliance team will catch this during supplier onboarding, and your order will be blocked at the documentation stage.

Why Factory Identity Matters for Your Order

When a retailer like Auchan, Lidl, or HEMA onboards a new supplier, their compliance team runs a legal entity check. They verify that the company named on the FSC certificate, the BSCI audit report, and the invoice are the same legal entity. If the website says "ABC Global Pencil Group" but the business license says "XYZ Local Stationery Shop," your supplier fails compliance — after you have already invested months in sampling and negotiation.

This is not a hypothetical scenario. Many Chinese manufacturers operate under a brand name that differs from their registered legal name. A brand name is marketing. A legal name is traceable, auditable, and enforceable in a contract. For your order to clear customs and retail compliance, you need the legal name — and it must match across all documents.

Step 1: Get the Business License (营业执照) — Not a Logo, the Document

Every legally registered company in China has a 统一社会信用代码 (Unified Social Credit Code) — an 18-digit identifier that is unique, permanent, and publicly searchable. Ask your supplier for this number. If they hesitate, that is your first red flag.

The official registry is China's National Enterprise Credit Information Publicity System (国家企业信用信息公示系统, gsxt.gov.cn). Note: this government site and commercial services like Tianyancha (天眼查) are often inaccessible from overseas IP addresses. For buyers outside China, the most practical approach is:

  • Ask the supplier for a screenshot of their business license and their gsxt.gov.cn listing page — they can access it from within China. A legitimate manufacturer should treat this as a normal due diligence request, not a sensitive secret.
  • Cross-reference on Made-in-China.com (made-in-china.com) — search the company name. Verified suppliers on this platform have their business license validated by the platform's own audit team, viewable globally in English. Look for the "Verified Supplier" or "Audited Supplier" badge.
  • Check Google Maps — the factory address on the business license should be visible on satellite view as an industrial building, not a residential compound or virtual office. For pencil factories specifically, look for the distinctive long, narrow factory building shape and loading docks in Qingyuan County, Zhejiang.

Once you have the code and business license image, confirm:

  • Company name — does it match the name on the website?
  • Legal representative — who is personally liable for the company?
  • Registration date — was the company founded in 1998 as claimed, or 2014?
  • Registered capital — is this a ¥5M small enterprise or a ¥50M manufacturer?
  • Business scope (经营范围) — does it include "制造" (manufacturing) or only "销售" (sales/trading)?

Step 2: Match Three Names — Website, Business License, and Certifications

Write down three names:

  1. The company name on the supplier's website footer and About page
  2. The company name on the business license (营业执照)
  3. The certificate holder name on their FSC certificate (searchable at search.fsc.org)

All three must be identical. Not "similar." Not "same group." Identical. A real manufacturer has one legal identity that flows through every document. A trading operation has a brand name on the website, a different entity on the business license, and sometimes a third entity on the certifications — because the certificates are borrowed from the actual factory they source from.

Real example from pencilschina.com — the three-name match in practice: Our website footer and About page display: Qingyuan County Hongyun Penindustry Co., Ltd. Our business license (Unified Social Credit Code 913311267613355427) registers the same company name. Our FSC chain-of-custody certificate (ESTS-COC-251233, verifiable at search.fsc.org) is issued to the same legal entity. Our BSCI Grade C, ISO 9001, and ICS documentation pack uses that same entity name. One legal name across the business license, certificate records, and contract paperwork is the benchmark you should demand from every shortlisted supplier.

Step 3: Verify Certifications Are Issued to the Manufacturer — Not a Trading Company

FSC chain-of-custody certification can be verified in 60 seconds at search.fsc.org. Enter the certificate code. Confirm:

  • The certificate is active — FSC chain-of-custody certificates are valid for 5 years and must be renewed through annual surveillance audits (not expired or suspended)
  • The certificate holder name matches the factory's legal name
  • The product group includes pencils/stationery (not just timber trading)

BSCI audits are verifiable through the amfori Sustainability Platform (sso.amfori.org). A valid BSCI report shows the audit date, the grade (A through E), and the audited entity name. If your supplier sends a BSCI report where the audited entity name does not match their business license, the certificate belongs to a different factory.

ISO 9001 certificates can be verified through the issuing body's database (e.g., SGS, TÜV, Bureau Veritas). The certificate number and the certified organization name must match.

Step 4: Verify the Factory Address — Not Just the Sales Office

Many B2B websites list a prestigious address — a Shanghai free-trade zone office, a Hefei tech park suite. That is the sales office, not the production floor. The factory address is on the business license. If the supplier cannot provide a factory address that matches their business license registration, they are not showing you their own factory. Real pencil manufacturers operate from industrial-zoned land with production equipment, loading access, and QC records; the business license address should match a factory building visible on satellite view, not a residential apartment or virtual office suite.

For pencils specifically, Qingyuan County, Lishui, Zhejiang is a major production cluster with roughly 40 pencil manufacturers and around 30% of global pencil output. A pencil factory claiming to manufacture in Qingyuan should have a Qingyuan legal or factory address. If the business license is registered in a provincial capital 500 km away with no manufacturing scope, that company is a trading office — regardless of what factory photos their website displays.

Step 5: Check for Legal and Trade History

Chinese business registries like Tianyancha (天眼查) and Qichacha (企查查) aggregate litigation records, administrative penalties, and ownership structure — but they are often geo-blocked for overseas visitors. Instead, ask the supplier to provide a Tianyancha screenshot of their company profile page from within China. A transparent supplier should be able to provide it for due diligence. Look for:

  • 司法案件 (litigation records) — lawsuits, contract disputes, IP infringement
  • 行政处罚 (administrative penalties) — environmental, tax, or safety violations
  • 经营异常 (business anomalies) — failure to file annual reports, unreachable registered address
  • 股权结构 (ownership structure) — is the factory owner also the legal representative, or is there a hidden parent company?

Supplement this with a check on the supplier's B2B platform profiles. Made-in-China.com and Alibaba.com display years of membership, transaction history (if enabled), and any platform-issued warnings. A supplier with 5+ years of continuous platform membership and no visible recent platform warnings is a positive signal. A supplier with no B2B platform presence at all is not automatically a red flag — but it removes one verification channel.

The 5-Minute Due Diligence Checklist

Before you send a deposit, verify these five items in under five minutes:

  1. Business License → Request the Unified Social Credit Code + a screenshot from the supplier. Cross-reference on Made-in-China.com for platform-verified suppliers. Confirm manufacturing scope in business scope field.
  2. Three-Name Match → Website name = Business license name = Certification holder name. All three must be identical.
  3. FSC Certificate → search.fsc.org (works globally) → active, correct holder, correct product group. 60 seconds.
  4. Factory Address → Verify on Google Maps satellite view. Business license address must match actual production location. For pencils: Qingyuan County, Zhejiang.
  5. Legal Record → Request Tianyancha screenshot from supplier + check B2B platform membership history and dispute records.

Five checks. Five minutes. This is the difference between wiring a deposit to a manufacturer and wiring it to a marketing website.

Step 6: When You Visit — The Production Floor Audit Checklist

Steps 1–5 cover what you can verify from your desk. But for first orders exceeding $10,000, or when your retail buyer requires supplier qualification, an on-site visit reveals what remote verification cannot. Walk the floor yourself — do not let the sales manager keep you in the meeting room. Each item below includes what to look for, where to look, and the red flag that tells you to walk away.

Production Floor Checks

Slat moisture content — check the meter, not the spec sheet. Basswood slats must be dried to 8-10% moisture content before production. Above 12%, pencil barrels will warp after painting — sometimes after they have reached the destination country. Ask to see the moisture meter reading from slats currently in production, not the calibration certificate for the meter. Red flag: the meter display is off, the operator does not know where the meter is, or you are told "it is in another building."

Lacquer line — count the stations. Standard pencil finishing requires minimum four coating stations: base coat, colour coat, imprint, top coat. Fewer stations mean thinner coverage, which means the paint chips faster in use. Look at the line while it is running — not during a lunch break. Red flag: fewer than four stations running, or visible paint overspray on the floor suggesting rush production.

Core centering — pull a random sample and crack it open. Pick ten pencils off the line yourself — do not accept a pre-selected handful from the QC desk. Split each one lengthwise with a blade and measure core centering. A core offset by more than 0.3 mm from centre means the pencil sharpens unevenly and the tip breaks more frequently. If three or more of your ten are off-centre, the production run has a centering problem. Red flag: the factory refuses to let you pull random samples or insists their QC samples are representative.

Batch traceability — ask to see the last three production batch records. A functioning ISO 9001 system produces batch records showing raw material lot numbers, production date, machine settings, and QC results for each production run. If the factory cannot produce these within ten minutes, their quality system exists on paper only. Red flag: blank stares, or batch records that are pre-signed with no measurements filled in.

Documentation & Compliance

EN71-3 test reports — per SKU, not per factory. EU toy safety standard EN71-3 covers migration of heavy metals from pencil coatings. A factory-level test report is not sufficient — each paint colour, each lacquer formulation, and each new batch of raw materials requires testing. Ask for the EN71-3 report covering the specific SKU you are ordering. Red flag: a single test report from 2023 that the factory claims "covers all our products."

REACH compliance — confirm the SVHC declaration. REACH applies to every substance in a pencil that reaches the EU market. The factory should provide a Substances of Very High Concern (SVHC) declaration confirming that no SVHC exceeds the 0.1% weight threshold in any component — wood, lacquer, graphite, ferrule, eraser. Red flag: the factory has never heard of REACH or says "we have never had a problem with REACH before."

Shipping documentation — check what your freight forwarder actually receives. FSC chain-of-custody documentation must accompany the shipment. Confirm the factory issues an FSC invoice with the correct certificate code and product description for each order. Without this, your freight forwarder cannot demonstrate FSC status at customs — and your buyer cannot claim FSC on the retail shelf. Red flag: the factory says "we send the FSC documents separately" without explaining the process.

Post-audit commitment — get a written corrective action plan before you leave. Every audit finds something. A professional factory responds with a written corrective action plan listing each finding, the root cause, the corrective action, the responsible person, and a completion date — within 48 hours of the audit closing meeting. A factory that says "yes, we will fix everything" without a written plan has no intention of fixing anything before your order runs. The corrective action plan is the single strongest signal of whether a factory operates a genuine continuous-improvement system or merely passes audits by memorising the right answers. A factory that can show you corrective action plans from previous audits — with actual completion dates and evidence of closure — is a factory where quality problems get solved before they reach your container. A factory that has never written one is a factory where every problem becomes your problem, discovered at the destination port.

Key Evidence

Why would a factory use a different brand name on their website: Some factories register a separate brand name for export marketing because their legal name is difficult for international buyers to pronounce or remember. This is not automatically a red flag — but the supplier should disclose both names transparently and the legal entity name should appear on all contractual documents, invoices, and certifications. If the brand name completely obscures the legal entity and the supplier is evasive about their business license, that is a red flag.
What if the supplier refuses to share their business license: Walk away. A legitimate manufacturer has no reason to hide their business license — it is a public document already listed on government databases. Refusal to share it means either the supplier is not a manufacturer, the business license contains information they do not want you to see (e.g., registration date much newer than claimed, no manufacturing scope), or they are operating without valid registration.
Can I verify a Chinese factory without visiting in person: Yes. The five checks above can all be completed from your desk. For a first order with meaningful financial or retail compliance exposure, supplement digital verification with a third-party inspection from firms such as SGS, Bureau Veritas, Intertek, QIMA, or V-Trust. Ask the audit firm to confirm that the factory address, production lines, management team, and document set match the business license information you verified digitally.
What is the difference between a manufacturer and a trading company on paper: On the business license, look at the 经营范围 (business scope). A manufacturer's scope includes "制造" (manufacturing), "生产" (production), or "加工" (processing). A trading company's scope only includes "销售" (sales), "批发" (wholesale), or "进出口" (import/export). Some companies have both, which is legitimate — but if the scope has no manufacturing terms, the company is legally a trading entity, not a factory. This distinction has direct commercial consequences: a trading company cannot hold FSC chain-of-custody certification for manufacturing (only for trading/distribution, product group W1), cannot be the audited entity on a BSCI production site audit, and cannot issue batch-level EN71-3 test reports under its own name — it must rely on the actual manufacturer for all three. When a European retail compliance team runs supplier qualification, the business scope field is one of the first items they check against the certification documents. A mismatch between claimed manufacturing capability and registered business scope triggers immediate rejection at the documentation stage, regardless of sample quality or price competitiveness.
Do I really need to visit the factory myself, or can a third-party audit suffice: A third-party audit covers the checklist items that a stranger with a clipboard can verify — certificates on file, fire safety equipment, wage records. It does not cover the four things that determine whether your specific order ships on spec: the moisture content of the slats currently in inventory, the centering of the cores on today's production line, the batch records for your product type, and the EN71-3 report for your specific colour formulation. A third-party audit is baseline due diligence. Add a factory visit if your order value exceeds $10,000, if this is a new supplier relationship, or if your retail buyer will delist you for a quality rejection. If you cannot visit, send a detailed technical questionnaire covering the production floor items above and require photographs of the specific production line, moisture meter readings, and batch records — dated within the week of your order confirmation.
How long should a proper pencil factory audit take: Half a day minimum — two hours on the production floor, one hour reviewing documents, one hour for the closing meeting and corrective action discussion. If the factory schedules your visit for 90 minutes and spends 60 of them in the meeting room with tea, you are being managed, not audited.
What if the factory refuses to let me take photos on the production floor: Some Chinese factories restrict photography, citing intellectual property concerns. This is sometimes legitimate — they may be running OEM production for a competitor — and sometimes evasion. Ask to photograph your specific product line only, offer to sign a limited NDA covering competitor products, and observe whether the restriction applies selectively. If you can photograph the meeting room but not the lacquer line, assume the lacquer line has something to hide.

Final Thoughts

Verify the legal entity before you compare price. Review our factory profile, then request samples or send your target market so we can map the documents before production.


Related Reading

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  • How to Order Custom Pencils from China: Specs, Lead Times, and MOQ
  • Top 8 Pencil Manufacturers in China: 2026 Factory Comparison Guide
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Article last reviewed 7 July 2026. Specifications and market conditions may change — verify current requirements with our team.

Detailed FAQs

How do I verify a Chinese pencil factory's business license before checking certifications?

Before verifying any certification (FSC, BSCI, ISO 9001), verify the factory's business license — because a certificate issued to a non-existent or different legal entity is worthless regardless of the certificate number. China's National Enterprise Credit Information Publicity System (NECIPS) at gsxt.gov.cn provides free public access to every registered company's business license information. The verification takes under three minutes.

Ask the supplier for their full Chinese company name (not the English trade name) and their Unified Social Credit Code (USCC) — an 18-digit alphanumeric identifier that every legally registered Chinese enterprise has since the 2015 business license reform. Enter the company name or USCC at gsxt.gov.cn. The system returns the company's registration status (active, cancelled, or revoked), legal representative name, registered capital, establishment date, and business scope. Three checks matter most: the registration status must be "active" (存续/在业), not "cancelled" (注销) or "revoked" (吊销); the business scope must include 生产 (production/manufacturing) — if it only lists 批发 (wholesale) or 零售 (retail), the entity is a trading company, not a factory; and the registered address should be in an industrial zone, not a residential address or virtual office.

For pencil factories specifically, the business scope should list 铅笔制造 (pencil manufacturing) or 文具制造 (stationery manufacturing). The USCC also enables cross-referencing with certification databases — the legal entity name on the business license must match the certificate holder name on the FSC, ISO 9001, or BSCI certificate. A mismatch between business license entity and certificate holder is the single most common indicator of certificate fraud in Chinese manufacturing. For factories located in Qingyuan County, Zhejiang — home to roughly 40 pencil manufacturers — the USCC prefix will typically be 91331127, corresponding to the Qingyuan administrative region code. A supplier claiming to operate a Qingyuan factory with a USCC registered in a different province should be questioned directly.

How do I verify a Chinese pencil factory's FSC certificate is real?

FSC certificate fraud is a real risk in low-cost stationery sourcing — a number of Chinese exporters display FSC logos on product photos or websites without holding a valid Chain of Custody certificate. Verification takes less than two minutes and should be done before sending any RFQ.

The official FSC public database is at search.fsc.org. It is free, does not require an account, and returns results in real time. Every legitimate FSC-certified supplier is listed there; if a factory is not in the database, the certificate is either expired, suspended, or was never valid.

Three ways to verify:

  1. By certificate code — Ask your supplier for their CoC code (format: XXXX-COC-XXXXXX). Enter it in the database search. pencilschina.com's code is ESTS-COC-251233 — paste it and you will see our active certificate record.
  2. By company name — Search the factory's registered business name in English or pinyin. A matching active record will appear with the scope, product types covered, and validity date.
  3. By scope — Confirm the certificate scope explicitly mentions pencils or relevant wood products. A supplier with FSC for paperboard packaging but not for pencil manufacturing is not authorised to sell FSC pencils to you.

Red flags: suppliers who resist providing a code, send only a cropped PDF, or list a code that returns "no matching certificate" in the database. In all three cases, request an audit trail or disqualify the supplier.

See our FSC certification page or read the full verification walkthrough.

What BSCI audit grade do European retailers require for pencil suppliers?

BSCI (Business Social Compliance Initiative, now amfori BSCI) audits social compliance in supplier factories — working hours, wages, health and safety, freedom of association. Auditors assign a grade from A (outstanding) through E (unacceptable). For major European retailers, grade C or better is the minimum gate; grade A or B is commonly required for full private-label approval.

Grade thresholds as applied to supplier qualification:

  • Grade A (Outstanding) — Very rare in practice. Typically only held by the largest, most systemically audited factories.
  • Grade B (Good) — Typical requirement for large European retail private-label programs (Auchan, Carrefour, Lidl, Kaufland private brand).
  • Grade C (Acceptable) — Minimum bar for most mid-tier importers and wholesale buyers. Factories at grade C must present a corrective action plan with a defined re-audit timeline.
  • Grade D / E — Disqualifying for almost all retail buyers. Some importers accept D on a one-time basis if a corrective action is already in execution, but this is high-risk for your supply chain.

pencilschina.com holds a current BSCI audit at grade C. Request the audit report directly with your RFQ — the report is confidential and shared only with qualified buyers under NDA, not posted publicly, because it contains factory-level operational data.

Important caveat: BSCI audits are valid for one to two years depending on the previous grade. Always confirm the audit date is within the valid window before placing an order. Expired BSCI documentation will not pass retail supplier-qualification software (Sedex, EcoVadis, SupplierIQ).

See our BSCI certification page or the full BSCI audit explainer.

Can I verify a pencil factory remotely if I cannot visit China?

Yes — a structured live video walkthrough, combined with the free database checks described above, provides roughly 70–80% of the verification value of an in-person visit at a fraction of the cost. The key is structure: an unstructured video call where the supplier points their phone at whatever they want to show you is marketing, not verification. A structured walkthrough follows a fixed checklist and is led by the buyer's questions, not the supplier's tour script.

The walkthrough should cover five zones in sequence, and the supplier should not know the exact route in advance. Zone 1 — Raw material warehouse: ask to see the wood slat inventory, check for FSC labels on pallets if the factory claims FSC certification, and ask what the current moisture meter reading is (point the camera at the meter display — a factory with proper kiln-drying will have a handheld meter within arm's reach). Zone 2 — Production floor: walk the full production line from slat grooving through core insertion, drying, shaping, lacquering, and printing; look for workers wearing PPE (masks in lacquering area, gloves where relevant), check whether the line is running or idle (an idle line with workers standing around during business hours suggests staged setup), and count the number of active production lines — this gives you a rough cross-check against claimed daily output. Zone 3 — QC laboratory: ask to see the breakage testing machine, the cross-hatch adhesion tester, and the most recent batch test log — a real QC lab has dated, signed logs within arm's reach, not filed away in an office. Zone 4 — Finished goods warehouse: check for branded packaging from other customers (this confirms the factory actually exports, though they should not show other customers' brand names close-up), look at pallet labelling for destination ports, and check whether the warehouse is temperature-controlled. Zone 5 — Certification wall: ask the supplier to walk to where physical certificates are displayed and hold each certificate close enough to read the certificate number, issue date, and expiry date — compare against what they sent you by email.

The most revealing moment in a video walkthrough is not what the supplier shows you — it is what happens when you ask to see something they did not plan to show. Ask to see the worker dormitory, the chemical storage area, or the subcontractor's production area if components like erasers are outsourced. Hesitation, excuses about camera battery, or claims that areas are "closed today" are information in themselves. A genuine factory with nothing to hide will accommodate these requests. Combine the video walkthrough with all free database checks before the call, so during the walkthrough you are verifying what you already know, not discovering it for the first time.

How much does it cost to audit or verify a pencil factory in China?

Factory verification costs range from zero to approximately USD 2,500, depending on the depth of verification required. Understanding this spectrum helps buyers allocate the right budget to the right risk level — spending USD 2,000 on a full audit for a USD 5,000 trial order is disproportionate, but relying on free database checks alone for a USD 200,000 annual programme leaves compliance gaps unaddressed.

Free verification methods cover the first layer of due diligence and should be exhausted before spending money. FSC certificate verification at info.fsc.org is free and takes under two minutes — enter the certificate code and confirm the holder name, scope, and validity date. ISO 9001 verification through IAF CertSearch (iaf.nu) is also free — confirm the certification body is IAF-accredited and the scope covers pencil manufacturing. China's NECIPS business license check at gsxt.gov.cn is free and confirms the factory legally exists. BSCI audit status verification through the amfori platform requires access from an amfori member retailer — if you are buying for one, this verification is free through their compliance team.

Paid verification starts at USD 250–400 for a basic third-party factory audit conducted by firms such as SGS, Bureau Veritas, QIMA, or V-Trust. This one-day audit confirms the factory physically exists at the claimed address, reviews business licenses, checks production equipment, and provides photographic evidence — suitable for first-time supplier qualification on orders up to roughly USD 30,000. A quality system audit — including production line inspection, QC process review, and equipment calibration verification — costs USD 500–900 and is appropriate for ongoing programmes where consistent product quality is critical. A full social compliance audit (BSCI or SMETA) conducted by an accredited firm costs the factory USD 1,500–2,500 — this cost is typically borne by the factory, not the buyer, as the audit result benefits all the factory's customers. Pre-shipment inspection for a single container runs USD 250–350 and is the highest-ROI spend in the paid verification category — it catches defects before goods leave China, when corrective action is still possible. For a buyer placing their first pencil order, the recommended sequence is: exhaust all free checks first, commission a basic factory audit (USD 300–400), and add pre-shipment inspection (USD 300) on the first production run.

Pre-shipment inspection for pencils: what to check and how to instruct your QC agent

A pre-shipment inspection (PSI) should be booked when at least 80% of the order quantity is finished and packed, typically 5–7 days before the container loading date. The inspection costs USD 200–300 through firms such as QIMA, Bureau Veritas, or SGS, and typically takes one working day on-site.

Instruct your QC agent with these six checkpoint categories:

  1. Quantity verification — Count cartons against packing list. Open 10% of cartons and count inner packs. Total count must match order quantity within ±2%.
  2. Product specification check — Grade (HB/2B), barrel shape (round/hexagonal), barrel colour, logo print position and colour, eraser colour. Compare against approved pre-production sample with photos.
  3. Workmanship AQL sampling — Use AQL 2.5 for critical defects (core break on first sharpening, ferrule detachment, severe barrel warping) and AQL 4.0 for major defects (paint peeling, logo misprint, off-centre core). Standard sample size for orders of 10,000–35,000 pcs is 200 units per AQL 2.5.
  4. Packaging integrity — Verify retail packaging matches approved artwork (barcode, country of origin, age warning if required by EN71, importer name if required). Check inner pack counts and master carton gross weight against packing list.
  5. Document collection — Request the inspector to photograph and collect: packing list, invoice, FSC transaction certificate (if FSC order), test report reference numbers. These are needed for customs clearance.
  6. Carton drop test — Ask the inspector to perform a corner-drop test on one master carton from 1 metre height. Pencils should not shift or break through packaging.

Fail/pass decision: If AQL 2.5 critical defects exceed the acceptance number, hold shipment and require 100% re-inspection by factory before re-booking. Do not release payment balance until a re-inspection pass certificate is issued.

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