4. Outbound - Preferential origin

Introduction

Preferential origin of an outbound product becomes relevant where the customer requests a proof of preferential origin for an outbound shipment,shipment. soWith thatsuch a proof, the importerproduct incan be imported into the country of destination canat claima preferentiallower tariff(often treatment.0%) import duty rate under a trade agreement between the EU and that country.

Before performing an assessment, CS identifies:

• the product and quantity concerned;
• the country of destination; and
• the preferentialtrade arrangementagreement under which originatingthe statuspreferential origin is to be assessed.

Whether VTTI can facilitate a proof of preferential origin depends on the destination and the trade agreement concerned. Requests are assessed case by case by the customs specialist at the terminal, who checks which proof of origin is required under the relevant trade agreement.

This section only applies where the customer requests VTTI to make out or obtain a proof of preferential origin for an outbound shipment. Where the customer makes out a proof of preferential origin itself, this falls outside the scope of this procedure. In that case, VTTI has no role in the origin assessment or the proof of origin, bears no responsibility for it and performs no checks.

EvidenceRequired ofinformation originatingand status of inbound productdocumentation

WhereIt productis deliveredthe responsibility of the customer to provide the terminal maywith bethe shippedsupporting underinformation and documentation to substantiate a preferential arrangement,origin claim. If insufficient information is provided, VTTI will not issue or request any proof of origin. VTTI keeps a record of all supporting evidence provided by the customer provides evidence of its originating status with the inbound nomination. customer.

For product from productionoriginating in the EU, thisthe supporting documentation is a supplier's declaration (SD) or a long-term supplier's declaration within(LTSD). In this signed declaration, the meaningsupplier of Articlesthe 61product confirms that the goods originate in the EU under the rules of origin of the relevant trade agreement. An LTSD covers all shipments of the product during a specified period of up to 6624 ofmonths. ImplementingThe Regulationofficial (EU)template 2015/2447for (Annexesthe 22-15relevant andtrade 22-16).agreement must be used.

BeforeUpon relyingreceipt onof aan supplier'sSD declaration,or LTSD, CS checks that:checks:

• whether the country of origin is mentioned for each parcel;
• whether all combinations of CN code and product description that may be shippeddispatched under the arrangementtrade agreement are covered;covered by a valid SD or LTSD. If not, CS requests the missing declaration from the customer as soon as possible;
• the declaration refers towhether the arrangementSD relevantor toLTSD theis destinationstill and, where applicable, contains the required statement on cumulation;valid;
• awhether long-termthe supplier'scorrect declaration is validwording for the daterelevant trade agreement is used. This is checked upon receipt of theeach inboundnew deliveryor (maximumrenewed validity 24 months);declaration;
• whether the declaration bearsis signed. The declaration must bear a handwritten signature,signature. or,However, where both the declaration and the invoice are drawn up electronically, isthe declaration may be electronically authenticatedauthenticated, or coveredthe bysupplier may give a written undertaking of the supplier accepting full responsibility;responsibility and
for
• renewedeach declarationsdeclaration arethat requestedidentifies beforeit expiry.as if it had been signed by hand.

MaterialsCS originatingstores inthe aSD partneror country may count as originatingLTSD in the EUDocument throughManagement cumulationSystem where(part of VTTI's ERP) with a reference to the applicablerespective arrangementparcel(s), providesand forrecords this.the Anrelevant exampledocument is UK-originating materials used in productiondata in the EUCargo underDocuments themodule TCA.in ERP. The evidencelatest version of theireach originating statusdeclaration is thealways proofkept ofon origin recorded under section 2.

CS stores and registers the evidence in the same manner as proofs of origin under section 2.file.

Goods leaving the terminal unchanged

Where the goods leave the terminal unchanged, VTTI relies on the evidenceSD ofor originating statusLTSD recorded for the relevant inbound parcel(s). CS verifies that the outbound goods can be traced to thosethe parcelsrelevant inbound parcel(s) and are covered by the available documentation.

WhereA originatingload andis non-originatingonly producteligible hasfor beena storedproof of preferential origin if all parcels included in the sameload tank,are of preferential origin under the outboundrelevant producttrade cannotagreement. For shipments to the UK under the TCA, this means that only parcels of EU or UK origin can be identifiedincluded. physically.If Ita mayparcel onlyof any other origin is included in the load, for example Norway, no proof of preferential origin can be treatedissued, aseven originatingif wheresupporting alldocumentation for that parcel is available.

In case of thedoubt, followingCS apply:

reaches
• theout applicable arrangement permits accounting segregation for the product concerned (the TCA does so for fungible products of Chapter 27);
• where required, prior authorisation ofto the customs authorities has been obtained;
• the method applied ensures thatspecialist at no time more product receives originating status than would be the case with physical segregation; and
• the method is applied in accordance with generally accepted accounting principles and supported by the ERP inventory records.

Where these conditions are not met, product drawn from a tank that contains any non-originating product cannot be treated as originating. These cases are always referred to the terminal's customs specialist.terminal.

Goods blended or processed at the terminal

Where the goods have undergone blending or processing at the terminal, the preferential origin of the resulting product must be assessed under the applicablerelevant arrangement.

Astrade withagreement. non-preferentialThis origin, blendingassessment is performedbased on the customer'sinformation instructionprovided andby assessedthe customer in close consultationcombination with the customer.information available in VTTI's systems. The customer indicates the arrangement concerned, the components and proportions used, the specification to which the blend is performed, and the basis on which the customer considers the resulting product to be originating. The terminal's customs specialist at the terminal performs athe reasonablenessassessment checkbased on this information, taking into account:on:

• the relevant product-specific rule;
origin
• rule included in the rules on insufficient working or processing;FTA;
• the originating status of the input materials; and
• the operations performed;performed andat the terminal.
• the information available in VTTI's systems.

Most arrangements treat simple mixing of products as insufficient working or processing. Whether controlled blending to a specification goes beyond "simple mixing" and satisfies the product-specific rule depends on the arrangement concerned. Some arrangements also specify for Chapter 27 that obtaining a sulphur content by mixing products with different sulphur contents does not confer origin.

A blend may therefore have EU non-preferential origin under section 3 without having EU preferential origin. In principle, a blend only qualifies as originating where all input materials are originating, including through cumulation, unless the applicable arrangement provides otherwise.

A work instruction for determining the preferential origin of outbound products is available here.

Proof of preferential origin

Where the originating status of an outbound product has been established, the terminal's customs specialist at the terminal determines which form of proof may be used under the applicablerelevant arrangementtrade agreement and in what capacitywhether VTTI may act.

• Standard route. The proof, such as a statement on origin, is madeentitled to issue, make out by the exporter (in principle the owner of the goods), under its own REX registration or approvedfacilitate exporterthat authorisation where required. VTTI facilitates this by providing the exporter with an overview of the parcels and quantities included in the shipment, the operations performed and the evidence of originating status on file.proof.
• VTTI as exporter. VTTI only makes out a proof itself where all of the following apply:This route is the exception.
  • VTTI qualifies as the exporter under the applicable arrangement;
  • VTTI holds the required REX registration or authorisation;
  • the customer has contractually undertaken to provide all supporting documentation upon a verification request; and
  • the customs specialist and CGT have approved this route for the arrangement and terminal concerned.
• Proofs issued by an authority. Where a proof must be issued or endorsed by a customs authority or another competent body, such as a movement certificate EUR.1 or EUR-MED, VTTI may apply for it on behalf of the exporter based on the completed origin assessment.

VTTI will only issue, make out or facilitate a proof of preferential origin where:

• the originating status of the product has been established and substantiated;
• the required form of proof is permitted under the applicablerelevant arrangement;trade agreement;
• the relevant formal requirements are met; and
• the proof can be linked to the relevant outbound product, quantity and shipment.

Where originatingVTTI statusmakes cannotout a statement on origin, it does so in its own name, stating VTTI's REX number (Registered Exporter number). In that case, the customer provides VTTI with all supporting documentation required to prove the origin of the product upon request, for example in the event of a verification by the customs authorities.

Where a proof must be established,issued or endorsed by a customs authority or another competent body, VTTI may facilitate the application based on the completed origin assessment and the available supporting documentation.

Where no proof of preferential origin can be issued, for example because not all parcels in the load are of preferential origin, the customer may request a Terminal Origin Declaration. A Terminal Origin Declaration under section 3. That document doesis not constitute a proof of preferential origin.origin and cannot be used to claim preferential tariff treatment.

Recording and retention

The origin assessment, its outcome and the supporting documentation, including the customer's blend instruction and information where applicable,documentation are retained as part of the origin audit trail. Any proof of origin issued, made out or facilitated for the outbound shipment is stored in the Document Management System and linked to the relevant parcel or shipment. CS records the relevant document data in the Cargo Documents module in ERP.

 Records are retained for at least the period required under the applicable arrangement (for example four years after making out a statement on origin under the TCA), and in any case for at least seven years.

Verification and correction

Where VTTI becomes aware that a proof it issued, made out or facilitated may be incorrect, CS informs the terminal's customs specialist immediately. The customer is informed without delay so that the importer can be notified where required.

Follow-up and escalation

• the applicablerelevant arrangement;trade agreement;
• the originating status of the input materials;
• the applicable origin rule;
• the application of accounting segregation; or
• the required proof.

WhereIn necessary,case of doubt, CS involvesreaches out to the terminal's customs specialist. The customs specialist may request support from CGT whereat the matter:

terminal.
• Where the matter is complex;
complex,
• has a potentially material financial or compliance impact;impact or
• requires engagement with a competent authority.authority, the customs specialist requests support from CGT.

VTTI will not issue, make out or facilitate a proof of preferential origin while material concerns regarding the originating status of the product or the supporting documentation remain unresolved.