1. The gap between the rules and the practice
The origin rules are published. The practice of applying them is not, and exporters who follow the rules without the practice often fail verification.
2. The area with the most divergence
Pouch and fibre content
Textiles, where the composition determines the rule and the declared composition is checked against test reports.
Simple mixing and assembly
Where the product-specific rule requires more than the processing performed.
The cost basis
CIF or FOB, and what is included on each side.
3. What to ask for
Supplier declarations, in the form the agreement requires.
Cost breakdown, itemised consistently.
Production records.
Test reports where composition matters.
4. The frequency of review
Review the origin conclusion when the product changes, when the supplier changes, when the agreement changes, and annually regardless.
5. A scenario
An exporter relied on a supplier declaration that said “material of Chinese origin.”
The materials were imported and merely reprocessed.
The declaration was inaccurate and the origin claim failed.
6. The lesson
Supplier declarations are not accepted at face value by a verification authority.
They are tested against the supplier’s own records.
7. What to build
A supplier declaration dossier, reviewed for plausibility, with the bill of materials where possible.
8. Closing view
The origin rules are public. The evidence that satisfies them is not.
That is where the work is.
*This article is based on the origin rules and verification provisions of China’s free trade agreements.*