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Long Term Supplier Declarations

EUR1 – H M Revenue and Customs Notice 827

Before issuing a preference document, the exporter must hold evidence to show that the exported goods meet the relevant rules of origin. The fact that an item is in free circulation or has been bought from an EU supplier does not in itself prove originating status.

“Originating” goods are either:

  • Wholly produced in the EU
  • Have been sufficiently processed in the EU to be classed as “originating”. This means work done elsewhere in the EU can help meet the origin rules.

The origin rules for goods of all Tariff headings are set out in notices:

These may vary according to the Tariff heading and the country to which the goods are exported.

If you are an Then you may
Exporter Need to obtain Suppliers’ Declarations to prove the originating status of materials used in the manufacture, or for finished products that you buy and re-export.
Supplier You may be asked to provide a Suppliers’ Declaration to your customer to prove the originating status of the goods.

There are occasions where manufacture is not enough in itself to meet the origin rules and suppliers’ declarations are required. For example if:

  • Any materials do not change tariff heading
  • The value of materials is over the specified limit. For example the origin rule may specify a percentage limit of 40% for non-originating materials, and the total value of materials used is 45% of the ex-works price. You will then need declaration(s) to cover the value of materials in excess of the limit, that is, 5% of the ex-works price
  • You manufacture using materials at a later stage of production than that specified, for example using bought-in fabric where the origin rule is manufacture from yarn
  • The only processing which you carry out on a product is among the minimal processes listed in Notices 828, 830 and 832
  • You buy and export goods in the same state.

There are occasions where manufacture is not enough in itself to meet the origin rules and suppliers’ declarations are required. For example if:

  • An origin rule may specify that all non-originating materials must change tariff heading. If, during manufacture, all materials change tariff heading then the rule is met without the need for any Suppliers’ Declarations
  • A percentage rule may specify a limit on the value of non-originating materials (30% or 40%). If the total value of all materials is within this limit, then the rule will be met
  • An origin rule may specify manufacture from materials at a certain stage of production, for example manufacture from yarn. If you manufacture using materials at or before the specified stage (for example yarn or pre-yarn) then the rule will be met automatically.

Certificates of Origin

The Certificate of Origin application form reflects this in that it establishes minimum requirements to be fulfilled in the case of:

  • goods wholly produced in the United Kingdom
  • goods of United Kingdom origin by virtue of processing undertaken in the United Kingdom
  • goods of foreign origin

The requirement is fulfilled by a signed declaration as to which category applies together with supporting documentary evidence.

Certificates of Origin

The Certificate of Origin application form reflects this in that it establishes minimum requirements to be fulfilled in the case of:

  • goods wholly produced in the United Kingdom
  • goods of United Kingdom origin by virtue of processing undertaken in the United Kingdom
  • goods of foreign origin

The requirement is fulfilled by a signed declaration as to which category applies together with supporting documentary evidence.

In any cases where doubt arises it is the duty of the Chamber to call for such additional evidence as may be necessary to prove the accuracy of the application, and to refuse certification until such evidence is provided.

In particular, difficulties may be encountered in the following areas and further clarification can be downloaded here.

  • Goods wholly obtained in a single country or territory

  • Operations not constituting an important stage of manufacture

  • Accessories, spare parts or tools

  • Product specific rules covering commodity codes in the following areas:

      • Live animals; animal products – 02 and 04
      • Vegetable products – 09,11 and 14
      • Prepared foodstuffs; beverages, spirits and vinegar; tobacco and manufactured tobacco substitutes – 17, 20, and 22
      • Products of the chemical or allied industries – 34 and 35
      • Raw hides and skins, leather, furskins and articles thereof; saddlery and harness; travel goods, handbags and similar containers; articles of animal gut (other than silk-worm gut) – 42
      • Pulp of wood or of other fibrous cellulosic material; recovered (waste and scrap) paper or paperboard; paper and paperboard and articles thereof – 49
      • Textiles and textile articles – 50 to 63
      • Footwear, headgear, umbrellas, sun umbrellas, walking-sticks, seat-sticks, whips, riding-crops and parts thereof; prepared feathers and articles made therewith; artificial flowers; articles of human hair – 64
      • Articles of stone, plaster, cement, asbestos, mica or similar materials; ceramic products; glass and glassware – 69
      • Natural or cultured pearls, precious or semi-precious stones, precious metals, metals clad with precious metal, and articles thereof; imitation jewellery; coin – 71
      • Base metals and articles of base metal – 72, 73 and 82
      • Machinery and mechanical appliances; electrical equipment; parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles – 84 and 85
      • Optical, photographic, cinematographic, measuring, checking, precision, medical or surgical instruments and apparatus; clocks and watches; musical instruments; parts and accessories thereof – 90 and 91
      • Miscellaneous manufactured articles – 94
  • Second hand goods – Evidence of origin may be difficult to obtain where second hand goods are concerned. Inspection of the goods may be helpful – machinery, for instance, may carry a manufacturer’s plate, a manufacturer’s serial number or some other indication of origin stamped or embossed on some part of the machinery. The production of a manufacturer’s catalogue or other literature on its own, while perhaps indicating that the goods shown on the certificate were made by the particular manufacturer, does not necessarily mean that the actual goods are of the same origin. Inspection of the goods to check that they correspond to the literature would be necessary in such a case unless other evidence such as the purchase invoice or other documentary evidence obtained at the time of purchase is available.

  • Reconditioned goods – The position regarding reconditioned goods is similar to that of second hand goods except that documentary evidence is somewhat more likely to be available. It should be noted that extensive re-conditioning of foreign-made goods which amounts to re-manufacturing might justify a claim to EC/UK origin for the goods.

  • Antiques – Establishing the country of origin of antiques for which a Certificate of Origin is sought is obviously difficult, as in most cases documentary evidence may not be available. Also, inspection of such items may not provide enough evidence on which to make a judgement. In such cases, a certificate given by a qualified antique dealer is probably the best evidence which can be obtained, even if such a certificate is in restricted terms indicating that, in the expert’s opinion, the item originated in a stated country. Exporters should obtain such a certificate from a qualified antiques expert at their own expense. Any certificate given must carry a statement as to membership of BADA.