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Work instruction (commercial incentive)

In practice, there are two types of documents that refer to non-preferential origin:

  1. An official Certificate of Origin (CoO), which exporters can obtain by applying to the competent Chamber of Commerce or the relevant customs authorities; and

  2. A commercial document declaring the non-preferential origin (Terminal Origin Declaration).

Upon request, our terminal can assist with the application for the relevant certificate or document via a broker authorised to apply for an official CoO (digital connection required). When applying with the Chamber of Commerce the burden of proof is greater than when issuing a Terminal Origin Declaration, because the latter is not an official document and it is the discretion of the Terminal to conclude on origin and the proof that is provided. For example, when documentation is provided that the Product comes from a refinery in Italy the Terminal may be inclined to accept this as sufficient proof, where the Chamber of Commerce is likely to require a Suppliers declaration for non-Preferential origin. Apart from whether or not the proof of origin for the components is sufficient or not, the procedure in determining the origin should be the same with the terminal itself and the Chamber.


Our Customer Service team determines the non-preferential origin in accordance with the following criteria:



Below some concrete examples on applying the procedure for establishing the non-preferential origin.

1. Products added to the “base” product may enhance or improve it, but do not alter its essential nature. Such activities are considered minimal operations and do not confer origin.

As this involves blending rather than mere storage, the major portion rule applies, provided that customers inform us of the origin and substantiate it with appropriate documentation. This requirement applies at least to the parcel representing the major portion based on weight. The origin of the remaining parcels may be unknown without affecting this assessment. 

Components




TankProductCommodity codeStatusOriginKilogramLiters 15
T xGasoline RON 952710 1245 90T2 - Excise controlledNorway35.096.53045.579.910
T xAdditive3811 1900 90T2 - Excise controlledUnknown244.894349.849







Blended product




T xGasoline RON 952710 1245 90T2 - Excise controlledNorway35.341.42445.929.758


2. Various components blended into a specific product (which itself is also used as a component) may be regarded as deliberate and proportionate blending and therefore origin-conferring.

The processed product results from the combination of several significant components. The fact that one of these components shares the same Commodity code as the final product does not alter this assessment. In quantitative terms, it is not considered a “base” product to which only minimal operations are applied. Accordingly, a new product is deemed to have been created. The majority of the product is not RON 95. The process here is to get the RON 91 to a RON 95 making it a process to obtain a Product by deliberate and proportionate blending.

Components






Tank

Product

Commodity code

Status

Origin

Kilogram

Liters 15

T x

Gasoline RON 91

2710 1241 90

T1 - Bonded

Norway

28.077.224

36.463.928

T x

Naphta

2710 1225 90

T1 - Bonded

Unknown

5.565.992

7.951.417

T x

Alkylate

2710 1290 90

T2 - Excise controlled

Unknown

4.634.938

6.019.400

T x

Gasoline RON 95

2710 1245 90

T2 - Excise controlled

Unknown

17.670.712

22.948.977

T x

Additive

3811 1900 90

T2 - Excise controlled

Unknown

244.894

349.849








Blended product






T x

Gasoline RON 95

2710 1245 90

T1 - Bonded

EU/Netherlands

56.193.763

73.733.571


3. Various components (classified under the same Commodity code but possessing different technical characteristics) blended into a specific product may be regarded as deliberate and proportionate blending, thereby conferring origin, provided that the resulting product acquires new technical specifications or attributes that it did not possess prior to blending. The fact that all components share the same Commodity code as the final product is not relevant.

Components




TankProductCommodity codeStatusOriginKilogramLiters 15
T xRMK 5002710196800T2 - Excise controlledUnknown
427.486429.112
T xRMK 5002710196800T2 - Excise controlledUnknown
243.967244.894
T xHSFO2710196800T2 - Excise controlledUnknown4.634.9384.617.392
T xIMFO2710196800T2 - Excise controlledUnknown5.565.9925.587.141
T xCutterstock2710196800T1 - BondedMalaysia43.870.66344.037.332







Blended product




T xHSFO2710196800T1 - BondedEU/Netherlands54.743.04654.915.871

4. Same example as last, but now also the Commercial name is the same. Here it is merely storage and each Lot keeps its origin.

Components




TankProductCommodity codeStatusOriginKilogramLiters 15
T xHSFO2710196800T2 - Excise controlledUnknown
427.486429.112
T xHSFO2710196800T2 - Excise controlledUnknown
243.967244.894
T xHSFO2710196800T2 - Excise controlledUnknown4.634.9384.617.392
T xHSFO2710196800T2 - Excise controlledUnknown5.565.9925.587.141
T xHSFO2710196800T1 - BondedMalaysia43.870.66344.037.332







Blended product




T xHSFO2710196800T2 - Excise controlled
Unknown
427.486429.112
T x
HSFO
2710196800
T2 - Excise controlled
Unknown
243.967
244.894
T x
HSFO
2710196800
T2 - Excise controlled
Unknown
4.634.938
4.617.392
T x
HSFO
2710196800
T2 - Excise controlled
Unknown
4.634.938
5.587.141
T x
HSFO
2710196800
T1 - Bonded
Malaysia
43.870.663
44.037.332




        










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