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Certificates of Origin for Processed Goods

1. What the requirement covers

The invoice and the certificate of origin, in most cases.

The packing list in some.

The contract where the tender requires it.

2. What the certificate certifies

Origin, and therefore eligibility for the preferential rate where one exists.

3. The combination that matters

A processor buys imported materials, works them, and exports.

The question is whether the processing is enough to change origin.

4. The tests

Change in tariff classification

The materials must move to a different heading or subheading from the finished good.

Value added

A minimum share of the good’s value must originate in the processing country.

Specific processes

Some products qualify by undergoing defined operations.

5. The typical processing business

Assembly, mixing, packing, cutting, coating.

Which of these changes origin depends entirely on the product-specific rule.

6. The trap

Assuming that processing means origin.

In many product-specific rules, simple assembly does not change the tariff classification, and therefore does not confer origin.

7. A scenario

A company importing components and assembling finished units in China, exporting to an ASEAN market.

The parts and the finished unit fell within the same subheading. The classification change test failed.

The company had to demonstrate regional value content instead, and needed the cost breakdown to do it.

8. The working preparation

For each export product, keep the bill of materials, the HS codes of the components, and the cost breakdown.

For imported materials, keep supplier declarations on origin.

9. Closing view

The certificate is a declaration of origin. Having the cost and code records is what allows you to make that declaration and to defend it later.

*This article is based on the origin rules of China’s free trade agreements. Exporters should confirm requirements with China Customs and the agreement text.*

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