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Statements on Origin vs. Certificates of Origin in EU Trade

Trade Documents 9 min read
Statements on Origin vs. Certificates of Origin in EU Trade

Quick answer

In EU trade, a certificate of origin is an official document issued by competent governmental authorities confirming the origin of goods, while a statement on origin is a declaration made by the exporter on commercial documents. Both serve to prove the origin of goods for preferential tariff treatment but differ in issuance, format, and procedural requirements [1][2].

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Key takeaways

  • A statement on origin is made by the exporter on commercial documents, typically at export or within two years after export, and is valid for up to 12 months or longer depending on the importing party [1:1][3].
  • A certificate of origin Form A is issued by governmental authorities upon written application and may be issued retrospectively under strict conditions [2:1].
  • Statements on origin may be used for cumulation purposes and must contain specific indications depending on the type of cumulation applied [4].
  • Certificates of origin require documentary evidence and verification by authorities before issuance [2:2].
  • EU importers and exporters must understand the procedural and documentary differences to ensure compliance and benefit from preferential tariffs [1:2][2:3].

Distinguishing Certificates of Origin and Statements on Origin

A certificate of origin is a formal document issued by the competent governmental authorities of the exporting country. It certifies that the goods comply with the applicable rules of origin under preferential trade agreements. The certificate is issued on written application by the exporter or their authorised representative and is supported by appropriate evidence proving the origin of the products. It is typically issued at or after exportation and bears official signatures and endorsements [2:4].

In contrast, a statement on origin is a declaration made by the exporter on commercial documents such as invoices or delivery notes. It confirms that the goods originate in the exporting country or beneficiary country and complies with the relevant rules of origin. The statement can be made at the time of export or retrospectively within two years of importation. It must include specific particulars and be made in one of the prescribed languages. Unlike certificates, statements on origin do not require issuance by governmental authorities but rely on the exporter’s responsibility for accuracy [1:3][4:1].

In practice, certificates of origin are often required for customs clearance in third countries or under specific trade agreements, while statements on origin facilitate simpler proof of origin within the EU or under certain preferential arrangements. Understanding the distinction is essential for EU businesses to ensure correct documentation and avoid delays or refusals of preferential treatment.

Who Issues Statements on Origin and When?

Statements on origin are made out by the exporter in the beneficiary country of export or, in some cases, the beneficiary country of origin. The exporter is responsible for the correctness of the statement and the information provided. The statement is typically made at the time of exportation to the EU or when exportation is ensured. However, it may also be issued retrospectively, provided it is presented to the customs authority in the Member State where the customs declaration for release for free circulation is lodged no later than two years after importation [1:4].

The retrospective issuance allows exporters to regularise missing statements on origin after exportation, which can be critical in cases where the statement was omitted or delayed. This flexibility applies mutatis mutandis when consignments are split across different beneficiary countries or when cumulation rules apply.

Statements on origin must be provided by the exporter to their customer in the European Union, ensuring that importers have the necessary documentation to claim preferential tariff treatment. The statement may be made on any commercial document that allows identification of the exporter and the goods concerned [1:5][4:2].

Content and Format of Statements on Origin

The statement on origin must contain specific particulars as prescribed in the relevant annexes of EU implementing regulations. It must include sufficient detail to identify both the exporter and the goods involved. The statement is to be made out in English, French, or Spanish, or in the language versions specified under bilateral agreements such as the EU-UK Trade and Cooperation Agreement [1:6][3:1].

A typical statement on origin includes:

  • Identification of the exporter
  • Description of the originating goods
  • Declaration that the goods originate in the beneficiary country
  • Any necessary references to cumulation (e.g., “EU cumulation,” “regional cumulation,” or “Norway cumulation”) where applicable [4:3].

The statement may be included on invoices, delivery notes, or any other commercial documents that sufficiently describe the goods. The exporting party is responsible for providing enough detail to enable customs authorities and importers to identify the products correctly [3:2].

Retrospective Issuance and Validity Periods

Both statements on origin and certificates of origin may be issued retrospectively under certain conditions. For statements on origin, retrospective issuance is admissible if presented within two years after the importation date to the customs authorities in the Member State where the customs declaration is lodged. This provision accommodates situations where the statement was not made at the time of export or was omitted inadvertently [1:7][4:4].

Similarly, certificates of origin Form A may be issued retrospectively if they were not issued at export due to errors, omissions, or special circumstances, or if the original certificate was not accepted at importation for technical reasons. The competent authorities verify the exporter’s application against export records before issuing a retrospective certificate, which must be endorsed accordingly [2:5].

Regarding validity, a statement on origin is generally valid for 12 months from the date it was made out. The importing party may allow a longer validity period up to a maximum of 24 months. The statement may cover a single shipment or multiple shipments of identical products imported within the specified period. For unassembled or disassembled products imported by instalments, a single statement on origin may be used in accordance with the importing customs authority’s requirements [3:3].

Statements on Origin for Cumulation Purposes

Cumulation allows materials originating in one country to be considered as originating in another country when used in the manufacture of a product, facilitating preferential tariff treatment under trade agreements.

When cumulation applies, the exporter must rely on the statement on origin or proof of origin provided by their supplier. The exporter’s statement on origin must then contain specific indications reflecting the type of cumulation applied:

  • “EU cumulation” or “regional cumulation” for cumulation within the EU or regional partners
  • “Norway cumulation,” “Switzerland cumulation,” or “Turkey cumulation” when cumulation involves these countries
  • “Extended cumulation with country x” for extended cumulation under relevant free trade agreements [4:5].

These indications ensure transparency and compliance with the rules of origin and facilitate customs verification processes. The exporter must be diligent in obtaining and providing accurate statements or proofs of origin from suppliers when cumulation is involved.

Certificates of Origin Form A: Issuance and Requirements

Certificates of origin Form A are issued by the competent governmental authorities upon written application by the exporter or their authorised representative. The application must be supported by appropriate documents proving that the products qualify for preferential origin status under the relevant trade agreement or EU legislation [2:6].

The certificate is made available as soon as exportation has taken place or is ensured. In exceptional cases, a certificate of origin may be issued retrospectively if it was not issued at export due to errors or special circumstances or if the original certificate was rejected at importation for technical reasons. Retrospective certificates bear the endorsement “Issued retrospectively” or equivalent [2:7].

In cases of theft, loss, or destruction of the certificate, a duplicate may be issued based on export documents held by the authorities. The duplicate must be endorsed with “Duplicate” and reference the original certificate’s serial number and date [2:8].

Before issuing the certificate, authorities may require documentary evidence or conduct checks to verify compliance with the rules of origin. The certificate must include specific information such as the date of issue, the name of the issuing authority, and handwritten signatures of both the authority and the exporter’s authorised signatory [2:9].

Key Differences for EU Importers and Exporters

For EU businesses, understanding the operational differences between statements on origin and certificates of origin is crucial for compliance and efficient customs clearance.

  • Issuance: Statements on origin are issued by exporters themselves on commercial documents, whereas certificates of origin require application to and issuance by governmental authorities [1:8][2:10].
  • Timing: Both may be issued retrospectively within two years, but certificates of origin require official verification before issuance [1:9][2:11].
  • Format and Content: Statements on origin have a flexible format but must include prescribed particulars and may be in English, French, or Spanish. Certificates of origin follow a strict template (Form A) with official endorsements [1:10][2:12].
  • Use Cases: Certificates of origin are often necessary for customs clearance in third countries or under specific preferential agreements. Statements on origin are more common within the EU or under agreements allowing exporter self-declaration [1:11][3:4].
  • Cumulation: Statements on origin must indicate cumulation where applicable, while certificates of origin provide formal proof of origin status [4:6].

EU importers should ensure they receive the correct document type from their suppliers and verify that the documentation complies with the applicable rules of origin to claim preferential tariff treatment without delay or dispute.

Next steps

  1. Confirm whether your goods require a statement on origin or a certificate of origin based on the trade agreement and destination.
  2. Obtain or prepare the statement on origin with all required particulars in the prescribed language(s) for your commercial documents.
  3. If a certificate of origin Form A is required, submit a written application with supporting evidence to the competent governmental authority.
  4. Verify the validity period of your statement or certificate and ensure retrospective issuance deadlines are met if needed.
  5. Check for any cumulation indications required on statements on origin and obtain corresponding proofs from suppliers.

FAQ

What is in a Certificate of Origin?
A certificate of origin contains official confirmation from competent governmental authorities that the goods comply with the rules of origin. It includes exporter details, product description, date of issue, signatures, and endorsements verifying origin status [2:13].

How do I get a Certificate of Origin?
You must apply in writing to the competent governmental authority in the exporting country, providing supporting documents proving that your products meet the origin criteria. The certificate will be issued after verification [2:14].

What is a statement on origin?
A statement on origin is a declaration made by the exporter on commercial documents confirming that the goods originate in the beneficiary country. It is used to claim preferential tariff treatment and can be issued at or after export [1:12].

When is a statement on origin required?
It is required when exporting goods that qualify as originating under preferential trade agreements to prove their origin for customs purposes. It must be provided to the EU customer and presented to customs authorities upon import [1:13][4:7].

Can a statement on origin be issued retrospectively?
Yes, a statement on origin may be made out retrospectively if presented to the customs authorities no later than two years after importation [1:14][4:8].

What is the validity period for a statement on origin?
Statements on origin are generally valid for 12 months from the date of issue but may be accepted for up to 24 months by the importing party. They may cover single or multiple shipments within that period [3:5].

Sources


  1. Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 laying down detailed rules for implementing certain provisions of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union Customs Code, Article 92

  2. Commission Regulation (EU) No 1063/2010 of 18 November 2010 amending Regulation (EEC) No 2454/93 laying down provisions for the implementation of Council Regulation (EEC) No 2913/92 establishing the Community Customs Code, Article 97

  3. TRADE AND COOPERATION AGREEMENT BETWEEN THE EUROPEAN UNION AND THE EUROPEAN ATOMIC ENERGY COMMUNITY, OF THE ONE PART, AND THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND, OF THE OTHER PART

  4. Commission Regulation (EU) No 1063/2010 of 18 November 2010 amending Regulation (EEC) No 2454/93 laying down provisions for the implementation of Council Regulation (EEC) No 2913/92 establishing the Community Customs Code, Article 95

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