1. The change
Since 2023, several of China’s FTA partners have moved to exporter self-declaration for origin.
2. Existing arrangements
The RCEP origin declaration
An approved exporter, or any exporter above a threshold set by the importing party, can make an origin declaration on the invoice.
Bilateral agreements
Some permit exporter declarations under defined conditions.
Others
Require an authority-issued certificate.
3. The advantages of self-declaration
No certificate fee.
No waiting for issuance.
Flexibility in timing.
4. The obligations
The exporter must hold the origin evidence before making the declaration.
The exporter must be able to respond to a verification request.
The declaration must contain the prescribed wording.
5. The risk
The evidence burden moves to the exporter.
Under the certificate route, the issuing authority at least examined the application.
Under self-declaration, nobody does.
6. The scenario
An exporter used an origin declaration under RCEP without documenting the origin analysis.
A verification request arrived eighteen months later and the exporter could not reconstruct the basis.
The preference was withdrawn, and the importer recovered from the exporter.
7. What to build
A written origin analysis per product.
A file of supplier declarations.
The prescribed declaration wording, correctly used.
8. Closing view
Self-declaration removes a step and moves the responsibility.
Exporters who treat it as a simplification rather than a responsibility tend to discover the difference at verification.
*This article is based on RCEP and the origin rules of China’s free trade agreements.*