Certificate of origin for EU imports: when you need proof of origin, and when you do not

“Certificate of origin” covers several documents, and EU customs asks for only some of them. Origin does two jobs at the EU border. It decides which duty and which trade measures apply, and it decides whether a trade agreement lowers that duty (Commission, Rules of origin for goods). The first job needs no certificate. The second needs the proof the agreement names.

The Commission lists the proofs of preferential origin (Commission, Proof of origin):

• Movement certificate EUR.1 or EUR-MED. A government certificate, printed on a green guilloche-pattern background, required under the agreements that use it.
• Statement on origin, origin declaration or invoice declaration. The exporter’s own declaration on the invoice or another commercial document. Depending on the agreement, the exporter must be an approved exporter or registered in REX, or the consignment must stay under a value limit.
• Importer’s knowledge. Under the EU-Japan and EU-New Zealand agreements and the EU-UK agreement, the importer may claim the preference on the strength of what it knows about the goods.
• Supplier’s declaration. A supplier tells its customer the origin of what it supplies, so the customer can make out its own proof. It is not a proof at import.

The EU itself issues a document proving origin for export only where trade requires it, under the rules of the country of destination (UCC Art. 61(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 61, paragraph 3Click opens the article on EUR-Lex.). For most exports, the EU’s non-preferential rules do not apply at all, and the export declaration need not state the origin (Commission, Guidance on non-preferential rules of origin, section 3).

The evidence the Commission lists for a check of non-preferential origin: the producer’s name and address, the country and place of production, customs documents of the exporting country, commercial sales contracts, and, on the goods, the description, at least six digits of the commodity code, the ex-works price and the production process (Commission, Guidance on non-preferential rules of origin, section 2.3.1). A proof of preferential origin is in principle not accepted as proof of non-preferential origin, because the rules differ.

Rules of origin: where your goods come from

Non-preferential rules. Goods wholly obtained in one country originate there: minerals, crops, animals born and raised there, and goods made only from such products. Goods made in more than one country originate where they underwent their last substantial, economically justified processing, in a business equipped for it, that made a new product or an important stage of manufacture (UCC Art. 60(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 60, paragraph 1Click opens the article on EUR-Lex., Art. 60(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 60, paragraph 2Click opens the article on EUR-Lex., Delegated Reg. Art. 31Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 31Click opens the article on EUR-Lex.). For the goods listed in Annex 22-01 to the Delegated Regulation, product rules in that annex decide it (Delegated Reg. Art. 32Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 32Click opens the article on EUR-Lex.). These never confer origin: preserving goods, changing packing, simple packaging, putting goods up in sets, fixing labels or marks, simple assembly, and disassembly. For goods outside Annex 22-01, when only such operations happened in the last country, or the processing there was done to avoid a duty or other trade measure, the origin is the country where most of the materials came from: by weight for goods of chapters 1 to 29 and 31 to 40, by value for chapters 30 and 41 to 97 (Delegated Reg. Art. 33Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 33Click opens the article on EUR-Lex., Art. 34Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 34Click opens the article on EUR-Lex.). Packing classified with the goods is left out (Delegated Reg. Art. 36(2)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 36, paragraph 2Click opens the article on EUR-Lex.).

Preferential rules. Each agreement sets its own (UCC Art. 64(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 64, paragraph 2Click opens the article on EUR-Lex.). A product originates if it is wholly obtained in the partner country, or if its non-originating materials were worked enough to meet the product-specific rule for its code. The common rule types are a maximum value of non-originating materials, a change of tariff classification, and a specific process, such as spinning fibres into yarn (Commission, Preferential rules of origin). A general tolerance allows non-originating materials that the product rule would exclude, up to a set share, typically 10% of the ex-works price or of the product’s weight. Under many agreements, the goods must travel directly or stay under customs supervision in transit. Newer agreements, the EU-UK one included, use a non-alteration rule instead, which allows operations such as adding labels or splitting consignments in a third country (Access2Markets, Quick guide). Under the EU-UK agreement, goods may be stored or split in a third country while under customs supervision there, and marks or labels may be added (TCA Art. 52). The rules are listed by Harmonised System code, so the commodity code comes first.

Binding origin information (BOI). Customs in an EU country can decide the origin of your goods on application. The decision binds every EU customs authority as against you for three years, if the goods and the way they acquired origin match it in every respect (UCC Art. 33(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 33, paragraph 1Click opens the article on EUR-Lex., Art. 33(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 33, paragraph 2Click opens the article on EUR-Lex., Art. 33(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 33, paragraph 3Click opens the article on EUR-Lex., Art. 33(4)Regulation (EU) No 952/2013, Union Customs CodeArticle 33, paragraph 4Click opens the article on EUR-Lex.). A BOI does not replace the proof of origin: a holder still presents it to get a preferential rate (Commission, BOI).

The importer may instead claim on its own knowledge that the goods originate, from information that shows it. If the exporter treats that information as confidential, it can give a statement on origin instead (TCA Art. 54(2), Art. 58). Minor errors or discrepancies in the statement do not sink the claim, and neither does an invoice issued in a third country (TCA Art. 57).

Customs may check a claim by asking the importer, before or after release. With a statement on origin, the importer sends the statement and may say it cannot give the production details; customs can then ask the UK authorities within two years. Customs may deny the preference if, within three months of its request, the importer does not reply or does not provide the statement (TCA Art. 61, Art. 62(2), Art. 63(1)). If the exporter cannot show that the goods originate in the UK, HMRC states that the EU customer pays the full rate of customs duty (HMRC, Proving originating status).

The agreement waives the proof for small packages, but only from private persons to private persons, not imported by way of trade, up to EUR 500 for the EU (TCA Art. 60). A sale to a customer is trade, so the waiver does not cover it.

Goods made in the US: the 2026 duty cuts need more than a certificate

From 1 July 2026 until 31 December 2029, goods originating in the United States enter at 0% on the codes in Annex I of Regulation (EU) 2026/1455. The ad valorem duty is dropped on the codes in Annex II, and Annex III opens tariff quotas (Art. 1, Art. 2, Art. 8). US origin is decided by the non-preferential rules (Art. 6). The Commission may suspend these cuts (Art. 3).

The proof must include evidence that the goods travelled directly from the US to the EU, or stayed under customs supervision in transit. If they were stored or split in another country, as in a UK warehouse, the evidence must show they were not altered there, except to keep them in good condition or to add marks, labels, seals or documents (Implementing Reg. Art. 59aImplementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 59aClick opens the article on EUR-Lex.). The Commission’s Q&A on that article sets out what counts (Commission, Q&A on Article 59a):

• There is no standard certificate or statement. A “made in US” mark, an origin statement on an invoice or a certificate of origin is “in themselves not sufficient” (Q2).
• The EU importer must hold evidence of US origin and of direct transport when it lodges the declaration (Q2, Q3). Transport documents such as a bill of lading or air waybill, sales and transport contracts and packing lists count (Q4).
• If the US exporter cannot supply the evidence, the adjusted duties cannot be claimed (Q2).
• Goods routed through another country need documents for that leg, such as customs transit documents or a non-manipulation certificate from that country’s authorities (Q5).
• The claim uses preference code 300, or 320 for goods under the Annex III quotas, and document code U190 in the declaration (Q6).

So if your EU customer claims these rates, it needs production and shipping evidence from you, not only a certificate.

Goods from developing countries: REX and the GSP

The GSP lowers EU duty on goods originating in the beneficiary countries listed in Regulation (EU) No 978/2012 (Delegated Reg. Art. 37Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 37Click opens the article on EUR-Lex., Art. 41Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 41Click opens the article on EUR-Lex.). The proof is a statement on origin by the exporter. Above EUR 6,000 of originating goods per consignment, the exporter must be registered in REX; up to that value, any exporter may make it out (Implementing Reg. Art. 78(1)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 78, paragraph 1Click opens the article on EUR-Lex.).

• The statement goes on any commercial document that identifies the exporter and the goods, in English, French or Spanish, and needs no signature (Implementing Reg. Art. 92(3)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 92, paragraph 3Click opens the article on EUR-Lex.).
• One statement per consignment, valid for 12 months (Implementing Reg. Art. 99(1)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 99, paragraph 1Click opens the article on EUR-Lex., Art. 99(2)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 99, paragraph 2Click opens the article on EUR-Lex.).
• The declarant gives the statement’s date in the declaration, and the REX number above EUR 6,000. Before declaring, it checks the exporter’s REX registration on the public website (Implementing Reg. Art. 102(1)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 102, paragraph 1Click opens the article on EUR-Lex., Art. 102(3)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 102, paragraph 3Click opens the article on EUR-Lex.): the Commission’s Validate REX numbers page shows whether a number is registered.
• Customs refuses the preference, with no further check, where a required statement is missing, the goods differ from it, or the exporter is not registered (Implementing Reg. Art. 107(1)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 107, paragraph 1Click opens the article on EUR-Lex.).

REX is also the EU exporter’s number under the EU’s agreements with Canada, Japan, Vietnam, Singapore, the UK and others (Commission, REX).

• At import. Under the GSP, customs refuses the preference when a required statement on origin is missing (Implementing Reg. Art. 107(1)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 107, paragraph 1Click opens the article on EUR-Lex.). Under the EU-UK agreement, customs may deny a claim when the importer does not answer its request, or does not send the statement on origin, within three months (TCA Art. 63(1)).
• After release. If the goods turn out not to qualify, the preference is refused and the unpaid duty may be recovered (Commission, Preferential rules of origin). Customs has three years from the debt to notify it, five to ten years under national law where the act could lead to criminal proceedings (UCC Art. 103(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 103, paragraph 1Click opens the article on EUR-Lex., Art. 103(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 103, paragraph 2Click opens the article on EUR-Lex.).
• A wrong non-preferential origin. Customs sets the origin for the duty from the declarant’s evidence or, if that is not enough, from any information it has (Implementing Reg. Art. 243(4)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 243, paragraph 4Click opens the article on EUR-Lex.). Penalties for a wrong declaration are each EU country’s; see commodity code.
• Proof that comes late. A preference can be applied retrospectively within the time limits of the measure (UCC Art. 56(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 56, paragraph 3Click opens the article on EUR-Lex.): three years under the EU-UK agreement (TCA Art. 55(2)), two years for a GSP statement made out after export (Implementing Reg. Art. 92(2)Implementing Regulation (EU) 2015/2447, implementing the Union Customs CodeArticle 92, paragraph 2Click opens the article on EUR-Lex.).

Importing into Great Britain

The UK applies the same agreement to goods from the EU. UK customs grants the preference on the importer’s claim, based on a statement on origin or the importer’s knowledge (TCA Art. 54). HMRC sets out how its side differs (HMRC, Proving originating status):

• A statement on origin is valid for 2 years for imports into the UK.
• Goods worth under GBP 1,000 in total need no formal proof, for commercial imports too, if they are declared as meeting the origin rules. Above that, only goods with proof get the preference.
• A claim made after import, within 3 years, is a repayment claim on form C285.

For the UK’s other agreements, the proof may be a EUR1 or EUR-MED movement certificate, an origin declaration or the importer’s knowledge; the UK Trade Tariff shows which. Paper EUR1 certificates come from chambers of commerce, which may charge a fee (HMRC, Get proof of origin). For the UK too, origin is where goods were grown, produced or manufactured, which may not be where they were shipped or bought from (HMRC, Check your goods meet the rules of origin).

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