In today’s highly globalised climate, the location goods are shipped from is often insufficient to meet proof of origin requirements.
With increasing trade barriers, geopolitical tensions, and preferential trade agreements, proving the true origin of your goods is more important than ever. Failing to do so can lead to customs delays, the wrong duty rate being applied, and even financial penalties.
Therefore, customs officials and buyers may insist on more proof your goods meet rules of origin.
For businesses with an international supply chain, there are several relatively straightforward ways to obtain proof of origin. However, which method works best generally depends on 3 factors:
- The nature of your business operations.
- The composition of your products.
- The terms of any trade deal in place.
Failure to apply the rules of origin correctly can result in goods being stuck at the border and subject to the incorrect duty rate.
Most common ways to provide proof of origin
1. Supplier declaration
An official declaration from UK suppliers can demonstrate to customs officials that your products are from the UK by confirming the materials' origin. These can be made on any invoice or commercial document from the supplier.
If it’s a regular supplier, some trade agreements permit a long-term declaration that includes the validity dates.
Raw materials extracted from the country or products from animals born in the country are examples of locally sourced goods.
For more information, including the correct wording for the supplier, see the official UK government website pages here.
2. Certificate of origin from a Chamber of Commerce
Each region in the UK has their own Chamber of Commerce, which can assist in providing an official certificate of origin.
This document is most effectively used when trading on non-preferential terms, i.e., when no trade deal is in place and the exporter is only seeking to avoid tariffs that have been applied to other countries.
These can generally be applied for online with your local Chamber of Commerce. If you have never previously engaged with your local Chamber, there will likely be some formal undertaking requirements before they can issue the certificate of origin.
3. Official manufacturer declaration
An official declaration from a manufacturer can be a simple way to show customs officials the origin of goods. The declaration must be an official company document with an address and contact information.
This technique is generally only used when no existing trade deal exists. Where there are trade deals, businesses need to follow the rules for proving origin outlined in the agreement.
It needs to include similar wording to the following:
“We, [Company Name], hereby declare that the goods described below have been manufactured in the United Kingdom and qualify as UK-origin goods under non-preferential rules of origin.”
The letter should also include the following details:
- Product name, description and HS codes.
- Quantity of goods.
- Branch number.
- Highlight supporting documentation that is available on request.
- Signed by a senior staff member on behalf of the company.
- Contact details for verification or further information.
How to prove origin if challenged by customs officials
Show production or manufacturing records
If you are a manufacturer sourcing goods from different countries, then production or manufacturing records demonstrating sufficient processing may be required to prove compliance with rules of origin. You must show the materials in your product, which are not from the UK, have been ‘sufficiently worked or processed’ in the UK.
Specific trade agreements between the UK and other nations will specify how goods must comply with the ‘sufficiently worked or processed’ rule.
Where no trade deal exists, you must follow non-preferential rules of origin. This means proving that the goods are wholly obtained in the origin country, the tariff code has changed, or a minimum of 40-50% of its value is created in the country you claim as origin. Although this varies by jurisdiction, as outlined below, labour, energy and other costs can be factored into this calculation.
To justify manufacturing and processing, it must be more than simple actions. For example, it requires specialist skills, machines, or equipment to be completed.
Examples of documents which can prove sufficient manufacturing or processing has taken place in the UK:
- Commercial documentation and invoices
- Demonstrating the tariff codes of imported goods and the different tariff codes of the exported product.
- Demonstrating the tariff codes of imported goods and the different tariff codes of the exported product.
- Production flowchart or factory report.
- A detailed step-by-step outline of how raw materials or semi-finished components are transformed into the final product.
- A detailed step-by-step outline of how raw materials or semi-finished components are transformed into the final product.
- Manufacturing work orders, job cards & batch numbers.
- These documents show when and where the product was processed, proving that UK facilities carried out substantial transformation.
- Batch number changes between raw materials and the final product demonstrate changing items.
- Machine operation records & quality control reports.
- Demonstrating UK manufacturing equipment was used in the production.
- Inspection and quality control reports showing compliance with UK production standards.
- Payroll and production staff records.
- Shift logs recording the hours worked on UK-based production lines.
- Training records for UK-based manufacturing processes.
- Energy consumption and factory location proof.
- Evidence that UK-based facilities were used to process goods rather than just shipping imported components through the UK.
- Electricity and water bills from UK manufacturing sites.
- Lease agreements or property ownership documentation for factories.
- Waste and scrap records.
- Often, waste, offcuts, or scrap materials are involved in production. These records can verify that production genuinely took place.
If customs officials are unsatisfied with the documentation provided, they may ask manufacturers to calculate the UK-added value of the products.
This could be done to ensure the value-added is sufficient in the UK to be considered of UK origin. Costs associated with manufacturing or processing, such as labour, energy, and water, can be added to this calculation. If most materials are sourced from overseas.
The calculation required would be similar to the following:
(UK-origin materials + UK processing costs) ÷ total product cost x 100 = % UK origin content
The % UK origin content required will vary depending on the trade deal in place.
"The criteria for proving rules of origin are highly dependent on any trade deals in place between nations, or lack thereof. It's vital to understand the requirements as outlined in any trade deal. For example, between the UK and EU, proving compliance with rules of origin is even simpler than with other external partners."
Liam Launders, Head of Sales, WTA
Rules of origin requirements on goods moving between the UK and EU
When moving goods between the UK and EU, businesses must abide by the rules of origin as laid out in the Trade and Cooperation Agreement between the UK and EU.
There are two key factors explaining the requirements for duty-free trade between the UK and the EU:
- Your product is wholly obtained from the UK or EU.
- Enough of your product has been sufficiently worked or processed in the UK or EU.
If your product meets those requirements, then shippers must simply include the following wording on the invoice or other commercial document when moving the goods into the UK from the EU:
"The exporter of the products covered by this document declares that, except where otherwise clearly indicated, these products are of UK preferential origin."
If the shipment is over €6,000, the shipper must include their EORI number.
Now, customs officials may require further evidence to confirm that your goods should have favourable origin duty rates applied.
This can happen at any time, so we advise making the documentation listed earlier in this article available on request to avoid major delays at the border.
Rules of origin requirements for goods moving between the UK and USA
The UK and USA do not have a trade deal in place, meaning there is no specific wording on applying rules of origin. But UK businesses might be anxious to prove UK origin, with President Donald Trump’s aggressive approach to tariffs on international partners.
Therefore, the most popular methods include a statement from the local Chamber of Commerce or a Manufacturer Declaration, as listed earlier. However, remember that customs officials may require more information, such as manufacturing records.
Proving the origin of your goods is more important than ever in today's tense geopolitical climate. Whether you rely on a Supplier’s Declaration, a Certificate of Origin, or a Manufacturer's Declaration, having the correct documentation ensures smoother customs clearance and access to preferential tariffs.
Following the steps above, UK exporters can avoid unnecessary delays, stay compliant, and take advantage of duty savings where applicable. If you need further guidance, contact WTA’s expert customs team.