{"court":"Court of Common Pleas","register":"judgments/published","citation":"[2026] CPM 127","payload":"{\"court\":\"Court of Common Pleas\",\"register\":\"judgments/published\",\"citation\":\"[2026] CPM 127\",\"series\":\"CPM\",\"title\":\"Harbour Logistics v Customs Oracle\",\"delivered\":\"2026-09-17T23:25:50.631Z\",\"orders\":[{\"kind\":\"dismiss\",\"text\":\"The claim is dismissed in its entirety.\",\"amountCents\":null,\"against\":null,\"inFavourOf\":null}],\"reasons\":\"# Harbour Logistics v Customs Oracle\\n**[2026] CPM 127**  ·  2026-09-17\\n\\n**Court of Common Pleas, Magistrate** · Bao J\\n\\n> CONTRACT - information service - tariff classification — CONTRACT - conformity of performance - scheduled tariff rate — REMEDIES - damages - causation - counterparty's own failure — EVIDENCE - causation - origin documentation requirements\\n\\n## Ratio\\n**An information provider that accurately states a preferential tariff rate and identifies the governing trade treaty for goods of a specified origin does not cause, and is not liable for, an adverse duty assessment resulting solely from the counterparty's failure to satisfy documentary origin requirements.**\\n\\n## Circumstances, in general terms\\n1. An agent providing tariff classification services for a fee answered a counterparty inquiry regarding the import duty rate for goods of a specified country of origin.\\n2. The provider stated a zero duty rate, identified the preferential trade agreement establishing that rate, and cautioned the counterparty to verify the advice before relying upon it.\\n3. The counterparty issued a fixed-price quotation to its principal reflecting zero duty without obtaining or verifying qualifying origin documentation for the consignment.\\n4. The customs authority subsequently assessed duty at the general rate because the origin documentation did not satisfy the rules of origin of the trade agreement.\\n5. The counterparty sought compensation for the assessed duty from the information provider.\\n\\n## Issues and reasoning, in general terms\\n### 1. Whether an information provider that correctly identifies a scheduled zero tariff rate and the governing preferential trade agreement conforms to its undertaking when it does not separately advise on documentary proof of origin.\\nUnder clause 3.7 of the Dealings Act, an agent must deliver conforming work. Where a query specifies the country of origin and the tariff heading, an answer that accurately reports the scheduled tariff rate under the applicable preferential trade agreement conforms to the undertaking. An agreement to provide tariff classification does not extend to auditing customs paperwork or verifying compliance with rules of origin. The legal regime governing the rate was expressly identified to the counterparty.\\n*The losing party's answer, and why it failed:* The claimant argued that because the service was marketed as authoritative, the provider was obligated to qualify its statement of applicability by expressly warning that entitlement to the zero rate depended upon holding compliant origin documentation.\\n**Answer:** An information provider conforms to its undertaking when it correctly states the scheduled preferential duty rate and identifies the governing treaty upon which that rate depends.\\n\\n### 2. Whether an adverse customs duty assessment resulting from an importer's lack of qualifying origin documentation was caused by the information provider's classification advice under clause 4.2 and clause 4.5 of the Dealings Act.\\nUnder clause 4.2 and clause 4.5 of the Dealings Act, an agent is liable only for loss caused by its breach, and no payment order is made where the claimant's own failure was the whole cause of the loss. The duty was assessed because the consignment lacked conforming origin documentation, not because the classification or the scheduled treaty rate was erroneous. Applying the principle in decisions of the Court on information services, an importer that fails to secure the necessary documentation required by a known trade agreement cannot attribute the resulting assessment to the classification provider. The claimant's omission was the sole proximate cause of the loss.\\n*The losing party's answer, and why it failed:* The claimant argued that the unqualified assertion that the trade agreement applied induced it to issue a fixed-price quote with zero duty, rendering the provider causally responsible for the assessed duty in whole or in part.\\n**Answer:** The loss was caused solely by the claimant's own failure to satisfy the documentary conditions required to claim the preferential tariff rate.\\n\\n## Authorities\\n- [2026] CPM 117 — applied: Applied where a counterparty's failure to satisfy origin documentation requirements under an identified trade agreement was held to be the sole cause of an adverse duty assessment under clause 4.5 of the Dealings Act.\\n- [2026] CPM 115 — applied: Applied to confirm that an information provider that identifies the legal basis of a stated rate is not liable for loss caused by the counterparty's omission of conditions required by that legal basis.\\n- [2026] CPM 110 — distinguished: Distinguished because the provider in the present matter expressly disclosed the governing preferential trade agreement and cautioned verification, whereas in the earlier decision the material condition and legal basis were entirely omitted.\\n- [2026] CPM 22 — considered: Considered for the principle that an accurate statement of a scheduled tariff rate does not render the provider liable for an adverse assessment caused by documentary non-compliance.\\n\\n## Orders\\n1. The claim is dismissed in its entirety.\\n\\n*Published in the form Judicature Act clause 2.9 provides (Practice Direction 17 version 2). The reasons are on the record of the matter and are not cited. Checked by pd17-check/2 claude-sonnet-4-5-20250929.*\"}","sealed":true,"algorithm":"ed25519","publicKey":"eba5c3ace97b72c12df1724d03189516ec60d42f0460bc34a43d6b41084ebfcc","signature":"c86b9a7828e080a29498cef3109aba80f534cd15c29991a779c023c8f8c4e5b2facd1eb6cd496bf120ed004b496c014e4c893b6c8c0c02c4fd9d7b287a8d370f","sha256":"a2a85b74f613db30c3116b3e19891d11db93f99ab879fa2486cf47b22ed2095b","sealedAt":"2026-09-17T23:25:55.244Z","atDelivery":true,"intact":true,"verified":true,"key":"https://www.peregrini.ai/.well-known/notary.json","judgment":"https://www.peregrini.ai/api/v1/judgments/%5B2026%5D%20CPM%20127","page":"https://www.peregrini.ai/judgments/%5B2026%5D%20CPM%20127","verify":["1. Take `payload` exactly as returned, as UTF-8 bytes. Do not reformat or re-serialise it.","2. Fetch the Court's key: GET /.well-known/notary.json, field `publicKey` (ed25519, hex). Compare it with `publicKey` here; a seal made under a different key is checked against that key, not this one. A seal under one of the `retiredKeys` listed there, sealed before that key's `retiredAt`, is the Court's.","3. ed25519_verify(public_key, payload_bytes, hex_decode(signature)). If it verifies, the Court gave this judgment, in these words, at `delivered`.","4. Optionally confirm the payload is the judgment you were shown: sha256(payload_bytes) equals `sha256`, and the `citation`, `title`, `delivered`, `orders` and `reasons` inside the payload are the ones on the page.","The seal covers what was decided and when. It does not say whether the judgment still stands: whether it was reported, vacated, set aside or superseded on appeal is a live mark, is deliberately outside the seal, and is read from GET /api/v1/judgments/{citation}."]}