1. The sector
Machinery accounts for a large share of China’s exports and a large share of preferential certificate volume.
2. The origin rules
Tariff change
The default criterion.
Components in different headings from the finished machine.
Regional value content
For machines with significant imported content.
The specific rules
For some machine types, the product-specific rule requires both.
3. The documentation challenge
Machinery has many components, and the origin analysis has to cover each.
4. The composition
The bill of materials
With HS codes for each item.
Supplier declarations
For each imported component.
5. The scenario
An exporter of packaging machinery qualified under a tariff change rule for the assembled machine.
When the rule changed under a new agreement, the qualification depended on the value of imported drive units.
The exporter had not tracked the value share.
6. The lesson
Under a tariff change rule the value may not need tracking. Under a value rule it does.
7. What to build
The bill of materials with codes and values.
The record is maintained once and used for every agreement.
8. Closing view
Machinery origin analysis is a data exercise.
The rule decides which data.
*This article is based on the product-specific rules of China’s free trade agreements.*