Which form for which trade
A certificate of origin (CO) is two different things depending on context. Preferential CO unlocks reduced duty under an FTA — wrong form, no benefit. Non-preferential CO is for compliance (anti-dumping, marking, country-of-origin labeling) and grants no tariff break.
| Form | Trade lane | Issuer | Notes |
|---|---|---|---|
| FORM A | GSP-eligible LDCs → EU/UK/Japan/Norway/etc. | Exporting country chamber or designated authority | US graduated all GSP partners (program lapsed 2020); EU/UK/Japan/Norway still accept FORM A from select LDCs. |
| USMCA Certificate of Origin | US ↔ Mexico ↔ Canada | Self-certified by exporter, producer or importer | Annex 5-A data elements; no specific form required, but 9 data elements must appear. Valid for blanket period up to 12 months. |
| EUR.1 / EUR-MED | EU ↔ FTA partners (Korea, Japan, Singapore, Vietnam, Switzerland, etc.) | EU customs authority on application | EUR.1 for bilateral; EUR-MED extends to pan-Euro-Med diagonal cumulation. Some lanes also accept REX self-certification. |
| RCEP Certificate of Origin | Asia-Pacific RCEP members (CN, JP, KR, AU, NZ, ASEAN-10) | Authorized chamber/authority OR approved exporter self-certification | Allows back-to-back CO for re-export within RCEP. Self-certification phase-in by member. |
| Form E (China-ASEAN / ACFTA) | China ↔ ASEAN-10 | China CCPIT / ASEAN equivalent | Required for ACFTA preferential rate. Issued for individual shipments. |
| Form B (Generic / Non-preferential CO) | Any → any | Chamber of commerce | No tariff benefit. Used for AD/CVD scope, government procurement, country-of-origin marking, letters of credit. |
| CAFTA-DR Certificate | Central America + DR ↔ US | Self-certified by exporter or producer | Free format with required data elements. Valid for shipments up to 12 months. |
Origin determination rules
How origin is determined
- Wholly obtained — agricultural and mineral products fully sourced in one country (fish caught in territorial waters, iron ore mined and smelted locally).
- Substantial transformation / Change in tariff classification (CTC) — the input HS code shifts to a different output HS heading. Often expressed as CTH (4-digit shift) or CTSH (6-digit shift).
- Regional Value Content (RVC) — a percentage of the ex-works or transaction value must come from inputs originating in the FTA region. Common thresholds: 35–60% by transaction-value method, lower by net-cost method.
- Specific Process Rule (SPR) — certain manufacturing steps must occur in the country (e.g., textile dyeing-and-finishing, automotive engine machining). Process rules override CTC/RVC for listed HS codes.
Common mistakes
What gets you denied at the border
- Choosing non-preferential CO when an FTA CO would apply — overpaying duty for years, no refund unless caught quickly.
- Wrong issuing authority — EUR.1 issued by chamber instead of EU customs is rejected.
- Origin claim not backed by underlying records (cost breakdowns, supplier declarations) when customs requests verification.
- Form chosen for wrong jurisdiction — using ACFTA form for an EU shipment.
- Self-certified CO (USMCA, RCEP) signed by someone without verifiable authority at the company.
- Origin marked at HS level but supporting calculation is at the product variant — failure during post-entry audit.
- Validity period expired — typical FTA COs are valid for the listed shipment or a blanket period; reuse beyond that is rejection-on-claim.
Working notes
Pre-classify before you ship: name the FTA, name the rule (CTC, RVC, SPR), keep the supporting calculation. Customs verification can come months later — files that exist on day one save audits years later.