Preferential origin - Specific EU - UK TCA Procedures

Here various procedures are listed describing the rules of origin as specified in the specific Preferential trade agreements between the exporting and importing countries, providing the basis for preferential tariff treatment.

Assessment of Change of Tariff Heading (CTH) Rule for HS Heading 2710
Statement on Origin
SOP - Decision flow Preferential origin EU - UK TCA tariff Heading 2710
Decision flow Preferential origin EU - UK TCA tariff Heading 2710
Template preferential origin (long term) supplier declaration

Assessment of Change of Tariff Heading (CTH) Rule for HS Heading 2710

1. Purpose

The purpose of the Change of Tariff Heading (CTH) rule is to ensure that non-originating materials undergo sufficient processing or transformation before a product obtains preferential origin under the EU–UK Trade and Cooperation Agreement (TCA).

The CTH rule prevents preferential origin from being granted where a product is merely assembled or blended from non-originating materials without a substantial change in tariff classification.

The relevant legal framework is:

EU–UK Trade and Cooperation Agreement (TCA), Chapter 2 – Rules of Origin;
Annex ORIG-1 – Definitions;
Annex ORIG-2 – Product-Specific Rules of Origin.

2. Assessment principle

The CTH assessment is performed only on non-originating materials.

Originating materials are excluded from the CTH assessment because they already have preferential origin status.

The assessment logic is:

editor_310_5_9bcd4811-7408-4b72-9deb-32091e7b1c90_rte_image_276.png

3. Practical example – Blended product classified under HS heading 2710

Final product

Product	HS heading
Blended petroleum product	2710

The production process uses ten input components.

Input material assessment

Component	HS heading	Origin status	Evidence	CTH assessment
Component 1	2707	Non-originating	No preferential origin evidence	CTH fulfilled (2707 → 2710)
Component 2	2707	Non-originating	No preferential origin evidence	CTH fulfilled (2707 → 2710)
Component 3	2707	Non-originating	No preferential origin evidence	CTH fulfilled (2707 → 2710)
Component 4	2710	EU originating	Supplier declaration	Excluded from CTH test
Component 5	2710	EU originating	Supplier declaration	Excluded from CTH test
Component 6	2710	EU originating	Supplier declaration	Excluded from CTH test
Component 7	2710	EU originating	Supplier declaration	Excluded from CTH test
Component 8	2710	EU originating	Supplier declaration	Excluded from CTH test
Component 9	2710	UK originating	Statement on Origin	Treated as originating material under EU–UK bilateral cumulation
Component 10	2710	Non-originating	No preferential origin evidence	Assess under applicable tolerance/value rule

4. Key interpretation points

4.1 Non-originating materials from another HS heading

Example:

Input material:
HS 2707

Final product:
HS 2710

Result:
2707 ≠ 2710

→ CTH requirement fulfilled

The material does not prevent the final product from obtaining preferential origin.

4.2 Originating materials with the same HS heading as the final product

Example:

Input material:
HS 2710

Origin:
UK

Evidence:
Valid Statement on Origin

Result:
Material is originating under EU–UK TCA

→ CTH assessment not required

The fact that the material has the same HS heading as the final product is irrelevant because the CTH rule applies only to non-originating materials.

4.3 Non-originating materials with the same HS heading as the final product

Example:

Input material:
HS 2710

Origin:
Non-originating

Result:
Same heading as final product

→ Additional assessment required

The material must be assessed against any specific tolerance or maximum value rule included in the applicable product-specific rule.

5. Decision tree for HS heading 2710

editor_310_5_0363e4c0-e755-426b-92f5-9b4e63f3721e_rte_image_286.png

6. Final conclusion

For a blended product classified under HS heading 2710:

The CTH rule is applied only to non-originating materials.
Materials classified under HS heading 2707 can satisfy the CTH requirement because they undergo a change from heading 2707 to heading 2710.
Materials classified under HS heading 2710 do not automatically prevent preferential origin.
If a 2710 material has EU or UK preferential origin supported by valid documentation, it is treated as originating and is excluded from the CTH assessment.
Only non-originating 2710 materials require further review against the applicable tolerance/value provisions.

This approach ensures that preferential origin is granted where sufficient processing has occurred while allowing originating materials from the EU and UK to be used within the bilateral cumulation framework.

Statement on Origin

To be printed on an invoice or commercial document containing information on the goods concerned

(Period: from ___________ to ___________ (1))

The exporter of the products covered by this document (Exporter Reference No ...(2)) declares that, except where otherwise clearly indicated, these products are of Union preferential origin.

.......................................................

(4) (Place and date)

{INCLUDE NAME EXPORTER}

(Name of the exporter)

(1) If the statement on origin is completed for multiple shipments of identical originating products within the meaning of point (b) of Article 56(4) of this Agreement, indicate the period for which the statement on origin is to apply. That period shall not exceed 12 months. All importations of the product must occur within the period indicated. If a period is not applicable, the field may be left blank.

(2) Indicate the reference number by which the exporter is identified. For the Union exporter, this will be the number assigned in accordance with the laws and regulations of the Union. For the United Kingdom exporter, this will be the number assigned in accordance with the laws and regulations applicable within the United Kingdom. Where the exporter has not been assigned a number, this field may be left blank.

(3) Indicate the origin of the product: the United Kingdom or the Union.

(4) Place and date may be omitted if the information is contained on the document itself.

SOP - Decision flow Preferential origin EU - UK TCA tariff Heading 2710

Please note that customs status as such has no role in determining origin!

Definitions

EU originating material: Materials having EU preferential origin under the Trade Agreement rules

Goodswholly obtained in the EU, or
Goods sufficiently worked or processed in the EU according to the applicable list rules

Non-originating material: Material that does not qualify as originating under the preferential rules of origin of the Trade Agreement

Materials imported from third countries that do not qualify as originating, or
Materials that have not undergone sufficient working or processing to acquire EU origin

T2 product can also be non-originating material. Customs clearance does not change the origin of the material

Change of Tariff Heading "CTH" means production from non-originating materials of any heading, except that of the final product; this means that any non-originating material used in the production of the final product must be classified under a heading (4-digit level of the Harmonised System) other than that of the final product (i.e. a change in heading).

Decision flow Preferential origin EU - UK TCA tariff Heading 2710

Template preferential origin (long term) supplier declaration

[TO BE PRINTED ON COMPANY LETTERHEAD]

SUPPLIER'S DECLARATION

I, the undersigned, declare that the goods listed on this document …………………………….……………….(1), originate in ……………………………….(2) and satisfy the rules of origin governing preferential trade with ……………………………………………(3).

I declare that (4):

editor_310_5_d5e519f3-a209-4ca6-a648-ec57e868cd0c_rte_image_272.png Cumulation applied with …………………………………(name country/countries)

editor_310_5_779ef7f7-bc0f-41bb-a476-33eafaf08dce_rte_image_276.png No cumulation applied

I undertake to make available to the customs authorities any further supporting documents they require.

……………………………………………………………………….…. (5)

………………………………………………………………………….. (6)

……………………………………………………………………..…… (7)

_________________________

Footnotes (can be removed after completion)

(1) If only some of the goods listed on the document are concerned, they shall be clearly indicated or marked and this marking entered in the declaration as follows:

“………………..…listed on this document and marked …………………..….originate in ………………….…

(2) The European Union, country, group of countries or territory, from which the goods originate

(3) Country, group of countries or territory concerned

(4) To be completed, where necessary, only for goods having preferential origin status in the context of preferential trade relations with one of the countries with which pan-Euro-Mediterranean cumulation of origin is applicable.

(5) Place and date of issue

(6) Name and position of the undersigned, name and address of company

(7) Signature

[TO BE PRINTED ON COMPANY LETTERHEAD]

LONG-TERM SUPPLIER'S DECLARATION

I, the undersigned, declare that the goods described below:

…………………………………………………………………….(1)

…………………………………………………………………….(2)

Which are regularly supplied to ………………………………….(3), originate in ……………………………….(4) and satisfy the rules of origin governing preferential trade with ……………………………………………(5).

I declare that (6):

editor_310_5_03dcdb43-1ce4-4077-89ef-9f4048632165_rte_image_282.png Cumulation applied with …………………………………(name country/countries)

editor_310_5_e5c6b2a4-db08-4e7b-b34d-a5de19884987_rte_image_290.png No cumulation applied

This declaration is valid for all shipments of these products dispatched from ......................................... to

...............................(7)

I undertake to inform ............................................(3) immediately if this declaration is no longer valid.

I undertake to make available to the customs authorities any further supporting documents they require.

……………………………………………………………………….…. (8)

………………………………………………………………………….. (9)

……………………………………………………………………..…… (10)

_________________________

Footnotes (can be removed after completion)

_________________________

Footnotes (can be removed after completion)

(1) Description

(2) Commercial designation as used on the invoices e.g. Model No

(3) Name of the company to which goods are supplied

(4) The European Union, country, group of countries or territory, from which the goods originate

(5) Country, group of countries or territory concerned

(6) To be completed, where necessary, only for goods having preferential origin status in the context of preferential trade relations with one of the countries with which pan-Euro-Mediterranean cumulation of origin is applicable.

(7) Give the start and end dates. The period shall not exceed 24 months.

(8) Place and date of issue

(9) Name and position of the undersigned, name and address of company

(10) Signature