Certificates of origin
Preferential and non-preferential proof of origin, who issues each, and how a self-declaration works under USMCA, the EU-UK TCA and EUR.1 deals.
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You need a certificate of origin when the importing country, a bank, or a trade agreement asks for one. Many shipments don't need any, and under several trade deals the certificate has been replaced by a statement you write yourself. Before you pay a chamber for one, find out which kind is really being asked for.
The two families
| What it says | The goods come from this country | The goods qualify under this agreement |
|---|---|---|
| What it's used for | Import rules, trade remedies, letters of credit | Reduced duty |
| Who issues it | Chamber of commerce, usually | Customs, or the exporter by self-declaration |
| Saves duty? | No | Yes, if accepted |
A chamber certificate doesn't get you a preferential rate. That's the most common mix-up. A buyer asking for a "COO" to reduce duty needs the agreement's own form.
ICC runs a voluntary accreditation chain for chambers, and publishes international guidelines for them. Chambers generally ask for evidence of origin, so a supplier's or a manufacturer's statement should be ready before you apply.
Preferential proof, by agreement
| USMCA | Certification of origin in any format | Importer, exporter or producer | Nine minimum data elements in Annex 5-A |
|---|---|---|---|
| EU-UK TCA | Statement on origin, or importer's knowledge | Exporter, or the importer's own evidence | EU exporters above EUR 6,000 per consignment need a REX number. UK exporters use a GB EORI. A EUR.1 can't be used |
| Deals using EUR.1 or EUR-MED | Movement certificate | Customs in the exporting country | Exporter declares and holds the evidence |
| EU GSP and several EU agreements | Statement on origin under REX | Registered exporter, on the invoice or another commercial document | Registration number needed above EUR 6,000 |
The wording of a self-declaration is set by each agreement, down to the words. Copy it from the agreement or the customs authority's guidance. Don't reuse the one on your last invoice for another agreement, because it may not work.
A worked saving, and what it depends on
This is our own illustration. A UK seller ships EUR 9,000 of leather bags to a German customer, under a rule the bags meet. Assume a 3% EU general rate, which you'd check against the real tariff:
- Without preference: EUR 9,000 x 3% = EUR 270 in duty.
- With a correct statement on origin: EUR 0, so EUR 270 saved.
Above EUR 6,000, an EU exporter would need a REX number for the same shipment going the other way. A UK exporter puts its GB EORI in the statement. The saving also relies on the goods really meeting the rule. If the leather was tanned outside the UK and EU and only stitched there, check the product rule before you make the claim. If the claim fails on verification, your customer becomes liable for the full duty, and interest may follow. HMRC's guidance says an importer keeps the statement on origin or its evidence, and the exporter keeps its records, for 4 years.
Things that cause trouble
- Issuing a certificate for the wrong origin concept. "Made in the UK" for marking purposes doesn't mean originating under a deal.
- Blanket statements. Each deal has rules on how long a statement can cover multiple shipments. Under the EU-UK deal, it's identical products under the same contract, for up to 12 months.
- Wrong edition of the code. Product-specific rules are written against a specific HS edition. HS 2028 will open that up again.
- Missing legalisation. Some markets also want a chamber or embassy stamp on the invoice. Check before dispatch, since it can take days and can't be done at the border.
- Missing supplier evidence. Whoever signs the statement needs records showing the goods qualify. Get your suppliers to declare before you need it.
Frequently asked questions
Do I need one to ship to the US?
Can I get a certificate after shipping?
Sometimes. For EUR.1 deals, there's a route for certificates issued retrospectively, and self-declarations can often be added later if the agreement allows. Under the EU-UK deal, a claim can be made within 3 years of importation. Check the time limit for yours, as your customer's refund claim depends on it.
Sources
- ICC: Certificates of origin guidelines, checked 5 November 2026
- ICC: Certificates of origin, chamber services, checked 5 November 2026
- HMRC: How to complete the EUR1 movement certificate, checked 5 November 2026
- European Commission: Application of provisions on movement certificates, checked 5 November 2026
- European Commission: Guidance on the Registered Exporter System, May 2022, checked 5 November 2026
- European Commission: EU-UK Trade and Cooperation Agreement, rules of origin Q&A, 5 March 2021, checked 5 November 2026
- HMRC: Proving originating status for trade between the UK and EU, checked 5 November 2026
- CBP: USMCA, checked 5 November 2026
- Department for Business and Trade: How to create a commercial invoice for export, checked 5 November 2026