| 1. Determine if the goods are “wholly obtained” in one country | Check if all materials, production, extraction, etc happen in a single country or territory. If yes → that country is the origin. | UCC Article 148(1). |
| 2. If not wholly obtained → identify the last country of production | When two or more countries intervene, identify the country where the last “substantial, economically justified processing or working” was undertaken. | UCC Article 148(2). |
| 3. Assess whether processing qualifies as “substantial, economically justified” | • Check that the processing is more than minimal operations (i.e., not just packaging, sorting, trivial finishing).
• Check that the processing is economically justified (not purely to circumvent duties or rules).
• Check that the result is a new product or important stage in manufacture (change of properties, composition, classification). |
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| 4. Determine applicable rule: list rule or residual rule | • If the good is listed in Annex 22-01 to UCC-DA (or equivalent) then apply the binding list rule for that HS heading.
• If not listed, use the residual rule: origin is the country where the major portion of materials originated (by value or weight) OR last substantial processing took place. |
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| 5. Verify tariff classification of the goods and materials | Tariff classification influences the list rule application and residual rule. Ensure correct HS/CN code of the finished good and inputs. |
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| 6. Compile and retain supporting documentation | Retain production records, material origin, processing steps, location of operations, invoices, customs classifications. The declarant is responsible. |
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| 7. Declare origin in customs release for free circulation | At import into the EU, the declarant must indicate the non-preferential origin. Customs authorities may request proof. |
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| 8. Be ready for post-clearance checks | Customs may challenge the declared origin if there is “reasonable doubt”. Be ready with evidence and audit trail. |
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| 9. Update internal processes and alerts | Monitor changes in list-rules, Annex updates, or new CJEU decisions (e.g., special rules for certain HS headings). Review supply-chain changes (new country, new process). |
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