Rules of origin for preferential trade

The UK has signed 40 trade agreements with 74 countries plus the EU, allowing tariff-free or reduced-duty trade. To access these preferential rates, you must prove your goods 'originate' in the UK under the relevant agreement's rules. Getting origin right is a competitive advantage — if your customer faces unexpected tariffs because you did not provide proper origin proof, they will buy from a competitor who does.

How origin is determined

Goods qualify as originating if they are:

• wholly obtained in the UK, meaning entirely produced here without materials from any other country (for example, minerals extracted, crops harvested, or livestock born and raised here)
• sufficiently worked or processed, meaning goods that contain non-originating materials have been transformed in the UK to the degree the product-specific rules require

Simply shipping goods through or from the UK does not confer origin. Operations such as packaging, labelling, simple mixing, simple assembly, or preserving for transport count as insufficient production and cannot on their own make goods originating.

Product-specific rules

Each trade agreement sets out product-specific rules (PSRs) for each product type, identified by Harmonised System (HS) commodity code. PSRs typically take one of three forms:

1. A change of tariff classification (CTC) rule means the finished product must fall under a different HS heading from all its non-originating materials.
2. A maximum value of non-originating materials (MaxNOM) rule means non-originating content must not exceed a set percentage of the ex-works price, for example MaxNOM 40%.
3. A specific processing rule means certain manufacturing operations must be carried out. This is common for textiles, which often must be made from the yarn or fabric stage.

Use the UK Trade Tariff tool to look up the PSR for your product under the relevant agreement.

UK-EU Trade and Cooperation Agreement

The UK-EU TCA provides zero tariffs and zero quotas on all goods meeting its rules of origin.

• EU-origin materials used in UK production count as UK-originating, and the other way round (bilateral cumulation).
• Processing carried out in the EU on non-originating materials can also count towards meeting UK origin rules (full bilateral cumulation). You need a supplier's declaration from your EU supplier to use this.
• For most manufactured products, up to 10% by value of non-originating materials may be used even if they do not meet the PSR (the tolerance rule). For agri-food products the limit is 15% by weight.

The TCA does not provide diagonal cumulation with third countries. You cannot count content from Turkey, Switzerland, or other non-EU countries towards meeting UK-EU origin rules.

CPTPP

The UK's accession to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership entered into force on 15 December 2024. You can trade under it with all 11 other members: Australia, Brunei, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore and Vietnam.

CPTPP allows cumulation between member parties — originating materials from one CPTPP member can count as originating when exporting to any other CPTPP member where UK accession is in force.

Proving origin

Different agreements require different proof types:

• Under the UK-EU TCA, you can make a statement on origin: a self-certified declaration on your commercial invoice in prescribed wording, with your EORI number. Any exporter can make one without approved exporter status, and one statement can cover multiple shipments of identical goods for up to 12 months.
• Also under the TCA, the importer can claim preference on the basis of their own knowledge and evidence, without a statement from you.
• Some agreements (including those with Switzerland, Norway and South Korea) require an EUR.1 certificate endorsed by HMRC, using form C1299.
• Some agreements require approved exporter status for origin declarations on consignments over £5,400. Apply using form C1454.

Record keeping and verification

You must keep records supporting your origin claims for 4 years from the date the statement on origin was made. Records should include supplier invoices, production records, bills of materials, and any supplier's declarations used for cumulation.

Customs authorities in the importing country can request verification of your origin claim. If you cannot provide supporting evidence, the preferential tariff rate may be denied and your customer will owe the full duty plus interest.

Penalties

Making a false origin claim is a serious offence. Under the Customs (Preferential Trade Arrangements: Error in Evidence of Origin) Regulations 2024, HMRC can impose civil penalties for errors in evidence of origin. More serious fraud under the Customs and Excise Management Act 1979 can result in criminal prosecution with unlimited fines.

You can apply to HMRC for an Advance Origin Ruling if you are uncertain whether your goods qualify. The ruling is legally binding in the UK for 3 years and provides certainty.