MHA | 5 Key Questions on the Rules of Origin

5 Key Questions on the Rules of Origin

Posted on: February 28th 2022 · read

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We're working with many manufacturers who are finding Rules of Origin increasingly difficult to navigate.

Here are some of the most common queries we receive:

  1. What are the Rules of Origin and where can I find them?
  2. I purchase goods from a UK manufacturer.  Am I correct to assume that the goods can be exported to the EU as UK origin?
  3. What records do I need to have in place if HMRC check the origin of my goods?
  4. What is a Supplier’s Declaration and how do I know I need one?
  5. Can I follow one single approach for determining the origin of my goods if I export to various countries who have trade agreements with the UK?

If you have thought about any of the above, you will need our assistance to navigate the complex Rules of Origin regulations.  Our Indirect Tax Team are available to assist UK businesses to navigate the processes and produce the documents required to support any claim for “preferential origin” status.

Read on below for just one example on how Rules of Origin can impact businesses:

UK Export Case Study:

A UK business prints onto T-Shirts sourced from a UK supplier.  The printed T-shirts are exported to the EU as UK Preferential Origin.

This may be incorrect, but certain evidence is required to support the claim as the T-shirts would have to have been subject to certain processes within the UK to allow the preferential status to be gained.  If the T-shirts were imported into the UK then the addition of the printing would not change the original origin of the T-shirt.  It would therefore be important for the printing business to obtain a Supplier’s Declaration from its UK supplier.  The UK supplier would, in this instance, have to confirm the T-shirts are of non-UK origin.

The above shows that it is vitally important to not assume that UK purchases are UK origin.  Supplier’s Declarations are an important part of the evidence and can be subject to verification resulting in the supplier also being audited by HMRC.

Got a question? Get in touch for key advice

If you would like our team to contact you to discuss rules of origin compliance, please get in touch

Look out for more articles in this series of topics on international trade from our specialist Indirect Tax Team.

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