Origin is not where you ship from
Two ideas are constantly confused. Provenance is the country the goods leave from. Origin is the country where they were produced, under written rules. A product manufactured in China and shipped from Valencia has Spanish provenance and Chinese origin, and what counts for duty is the second.
And there are two kinds of origin. Non-preferential origin serves statistics, labelling and trade measures; it is evidenced by a certificate of origin issued by a chamber of commerce. Preferential origin is the one that reduces or removes duty where there is a trade agreement between the European Union and the destination country, and it is the one with money behind it.
The practical difference: the chamber’s certificate says where it comes from. Proof of preferential origin says, in addition, that it meets the rule that agreement requires — and that is something you assert.
The four steps
- Check whether there is an agreement with that destinationThe European Union has agreements with much of the world, each with its own scope. With no agreement there is no preference possible and the conversation ends here: your customer pays the general duty and there is nothing to issue.
- Find the origin rule for your headingThere is no single rule: each agreement has a list by tariff heading. Some require the product to be wholly obtained in the Union, others that non-originating materials change heading on processing, and others that the value of imported materials does not exceed a percentage of the ex-works price. You need the one for your heading in that specific agreement.
- Check you meet it, with numbersIf the rule is value-based, you have to do the calculation: how much of your ex-works price is non-originating materials. If it is change of heading, you also have to classify the raw materials and check the code changes. And you have to be able to redo that calculation four years from now.
- Issue the right documentDepending on the agreement and the amount it will be a statement on origin on the invoice, a EUR.1 endorsed by customs, or an A.TR if the transaction goes to Türkiye. The document does not create the origin: it only declares it.
Which document to issue
It depends on the agreement, the amount and whether you are registered. These are the three usual situations.
| Document | When | Who issues it |
|---|---|---|
| Statement on origin on the invoice | Modern agreements, consignments up to €6,000 with no prior registration | You, by writing the text on the invoice |
| Statement on origin with a REX number | The same agreements, above €6,000 | You, once registered as an exporter in the REX system |
| EUR.1 certificate | Agreements that still use it, or when the importer specifically asks for it | Customs, on your request and with justification |
| A.TR certificate | Türkiye, for products in free circulation in the customs union | Customs. It evidences free circulation, not origin |
| Chamber certificate of origin | Non-preferential origin: labelling, tenders, importer requirements | The chamber of commerce |
The €6,000 threshold is the usual one in European Union agreements, but it is worth confirming in the specific agreement: not all of them use the same figure.
Before signing a statement on origin
- I know the origin rule for my heading in that specific agreement
- I have done the calculation and I meet it, with the numbers on file
- I hold suppliers’ declarations on the origin of the raw materials
- If I exceed the threshold, I am registered in REX and I use my number
- The wording of the statement is the literal text from the agreement, unadapted
- I can redo this calculation four years from now with the papers I hold
What gets misread most
- Believing that manufacturing in the EU automatically gives EU originIt depends on the rule for your heading. A product assembled in the Union with most of its value in Asian components may not be originating, however local the assembly.
- Confusing the chamber certificate with preferential proofThey are different things and do not substitute for each other. The chamber’s one evidences non-preferential origin and gives no right to any tariff reduction.
- Issuing a statement on origin above the threshold without REXWithout a REX number the statement is not valid above the limit and customs at destination refuses the preference. Your customer pays full duty.
- Copying the statement wording from another exporterEach agreement has its own literal wording, and changing it invalidates the statement. You copy it from the agreement, not from a supplier.
- Throwing away the cost calculations the following yearThe review period exceeds four years in most agreements. Whatever you cannot demonstrate then counts as if you had not met it.