Outbound - Non-preferential origin

Blending or processing at the terminal may affect the non-preferential origin of the product concerned. Where an operation results in a new parcel, the non-preferential origin of that parcel must therefore be assessed separately. This assessment determines whether the operation confers origin or whether the origin must be determined by reference to the input materials.

Pending this assessment, the country of origin of the resulting parcel is registered in VTTI’s ERP system as “QU”, meaning “countries and territories not specified”. The use of “QU” in this context reflects that no specific country of non-preferential origin has yet been established for the resulting parcel. It does not constitute an origin determination and must not be used as the country of origin in a customs declaration, origin document or other external communication.

Before the non-preferential origin is required for the placement of the parcel under a subsequent customs procedure or for another customs or compliance purpose, the terminal’s customs specialist performs and documents the origin determination.

The determination is made by applying the relevant non-preferential origin rules to the product resulting from the operation. The assessment is based on the customs classification of the resulting product, the origin and customs classification of the input materials, the nature of the operations performed and the relevant operational and inventory data recorded in VTTI’s systems. Any supporting information or documentation provided by the customer is also taken into account where relevant.

Once the determination has been completed, CS replaces “QU” with the determined country of non-preferential origin in the ERP system. The outcome and basis of the determination, together with the relevant supporting information and documentation, are retained as part of the origin audit trail.

A work instruction for non-preferential origin determination at the terminal is included here.

Where the customer requests VTTI to provide or facilitate non-preferential origin documentation for an outbound shipment, CS first verifies whether the non-preferential origin has been established properly.

Any document prepared or facilitated by VTTI must be consistent with the origin information recorded in the ERP system and must relate to the relevant outbound product and quantity. Where an application must be submitted to a Chamber of Commerce or another competent body, VTTI provides the information and supporting documentation required for that application in accordance with the applicable process.

VTTI will not provide, facilitate or support an origin document where the non-preferential origin has not been established or material concerns regarding the determination remain unresolved.

A copy of the completed document, the underlying origin determination and the relevant supporting documentation must be stored in the Document Management System and linked to the outbound parcel or shipment. The relevant document data must also be recorded in the Cargo Documents module in ERP.

Any doubt concerning the origin of the input materials, the customs classification of the relevant products, the nature of the operations performed or the applicable non-preferential origin rule must be resolved before the origin is used for customs or compliance purposes.

The terminal’s customs specialist requests any clarification or additional information required from CS, the relevant operational personnel or the customer. Where the matter involves complex or unclear origin rules, a material financial or compliance impact, possible exposure to trade measures or engagement with a competent authority, the terminal’s customs specialist may request support from CGT.

VTTI will not use or communicate a country of non-preferential origin while material concerns regarding the determination remain unresolved.