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Cumulation Under RCEP: How It Changes the Arithmetic

1. The feature that changes the arithmetic

Cumulation: materials originating in any RCEP party count as originating when determining whether a finished good qualifies.

Fifteen parties, one pool.

2. Why it matters in practice

Most Chinese manufacturers of higher-value goods use imported components.

Under a bilateral agreement, those components are non-originating unless they come from the other party.

Under RCEP, they are originating if they come from any of the fourteen other parties.

For a product using Japanese panels, Korean semiconductors, or Australian raw materials, the difference is decisive.

3. What cumulation does not do

It does not make a good originating merely because it contains originating materials.

The product-specific rule still has to be satisfied.

Cumulation changes which materials count, not whether the rule applies.

4. The evidence cumulation requires

Supplier declarations

A declaration from the material’s supplier, establishing its originating status.

The chain

Where a supplier is itself relying on cumulation, the chain has to be traceable.

The documentation

The declaration has to identify the material and state its origin basis.

5. A scenario

A manufacturer of small appliances used motors from Japan and control boards from Korea.

Under the bilateral agreement with Australia, both were non-originating, and the value content test failed.

Under RCEP, both were originating. The value content test passed with a comfortable margin, and the goods qualified for the RCEP rate.

The change was not in the product or the factory. It was in which agreement was claimed.

6. The common error

Assuming that a supplier declaration for bilateral purposes is sufficient for RCEP purposes.

The wording and the basis differ. A declaration that says “Chinese origin” does not establish RCEP originating status.

7. What to ask suppliers for

The declaration in the form RCEP requires.

The material’s HS code.

The basis on which the supplier claims origin.

8. Closing view

Cumulation is the reason RCEP exists as a separate route rather than a consolidation of the bilateral agreements.

For products with East Asian supply chains, it is where the value is.

*This article is based on the Regional Comprehensive Economic Partnership agreement.*

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