1. Two failures, one cause
A certificate is issued. The goods do not qualify.
The two come from the same place: the origin analysis was not done, or was done wrong.
2. The four common analysis errors
The wrong rule
The product-specific rule applied was for a different tariff line, or for a different agreement.
The wrong materials
Components treated as originating without a supplier declaration.
The wrong value
The value content calculated on the sale price rather than on the basis the rule specifies.
The wrong date
An analysis performed for a previous product configuration, carried forward without rechecking.
3. The price of a wrong analysis
The certificate is refused, and the preference is lost.
The importer declares at MFN, and the duty difference is recovered from the exporter under contract.
4. A scenario
An exporter calculated regional value content as the share of the selling price attributable to Chinese materials.
The rule specified the value of non-originating materials as a share of the FOB value, which is a different calculation.
The result was close to the threshold, and the difference pushed it below.
5. What a correct analysis looks like
The rule
Quoted, from the agreement’s schedule, for the exact tariff line.
The inputs
Each material, its code, its origin, and its value on the specified basis.
The calculation
Shown, not just the result.
The conclusion
Stated, with the date.
6. The verification test
Can a person with no knowledge of the product read the analysis and reach the same conclusion?
If not, the analysis is not complete.
7. What to do for the first product
Do it once, carefully, with the agreement text open.
Template the structure.
Apply the template to the rest.
8. Closing view
The origin analysis is the whole of the work.
The certificate is a printout of its conclusion.
*This article is based on the origin rules of RCEP and China’s free trade agreements.*