Rules of origin for preferential trade

How origin is determined

Goods qualify as originating if they are:

• Wholly obtained in the UK — entirely produced here without incorporating materials from any other country (for example, minerals extracted, crops harvested, livestock born and raised)
• Sufficiently worked or processed — goods incorporating non-originating materials that have been transformed in the UK to the degree required by product-specific rules

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 are considered 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. Change of tariff classification (CTC): the finished product must fall under a different HS heading from all non-originating materials
2. Maximum value of non-originating materials (MaxNOM): non-originating content must not exceed a specified percentage of the ex-works price (for example, MaxNOM 40%)
3. Specific processing: certain manufacturing operations must be carried out (common for textiles, which often require manufacture from 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. Key features:

• Bilateral cumulation: EU-origin materials used in UK production count as UK-originating, and vice versa
• Full bilateral cumulation: not just EU materials but also processing carried out on non-originating materials in the EU can count towards meeting UK origin rules — you need a supplier's declaration from your EU supplier to use this
• Tolerance rule: for most manufactured products, up to 10% by value of non-originating materials may be used even if they do not meet the PSR. For agri-food products, the limit is 15% by weight

Note: 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. Initial trading partners under CPTPP are Japan, Singapore, Chile, New Zealand, Vietnam, Peru, and Malaysia. Other members (Australia, Brunei, Canada, Mexico) will follow once they complete ratification.

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:

• Statement on origin (UK-EU TCA): a self-certified declaration on your commercial invoice using prescribed text, plus your EORI number. Any exporter can make this — no approved exporter status needed. Can cover multiple shipments of identical goods for up to 12 months
• Importer's knowledge (UK-EU TCA): the importer claims preference based on their own evidence, without a statement from you
• EUR.1 certificate: an official certificate endorsed by HMRC, required for some agreements (Switzerland, Norway, South Korea, and others). Download form C1299 from GOV.UK
• Approved exporter status: required under some agreements 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.