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Are suppliers' declarations sufficient for proving the origin of your export goods?

Updated: Nov 6, 2023


As an authorised issuing body of UK Certificates of Origin and EUR1s, amongst other documents, the Chamber’s role is also to provide timely guidance and advice to exporters to ensure they remain compliant.


In recent months, we have seen an increased number of exporters providing ‘suppliers’ declarations’ as their only evidence to prove the origin of non-UK goods. So, whilst the suppliers’ declaration is a valid evidence document, please note is not enough on its own, as the supplier may not be necessarily the manufacturer of the goods. Therefore, we as a Chamber will require additional evidence to be able to process and approve your applications.


So, let’s take a look at what documentary evidence is required for non-UK origin goods to be submitted with your UK Certificate of Origin request


If your goods are not of UK origin, the Chamber will need back up documentary evidence to identify the place of manufacture of a product to determine its origin. GM Chamber realises that this can sometimes be a difficult process for an exporter, so we have compiled the following guide to help you understand what documentation evidence we will need when you apply for the UK COO.


ACCEPTABLE PROOF OF ORIGIN

ONE OF THESE THREE OPTIONS

  • A copy of the manufacturers invoice that shows the factory address. If the address is not shown, or if you have any doubt that they do indeed manufacture the product that appears on the C/O, check the company online for clues that they manufacture the items in question. It is not unusual for applicants to provide supplier invoices which are obviously not what we need.

  • A certified Certificate of Origin signed by the issuing authority issued by an overseas body; this must show the same type of goods that appear on the C/O you are certifying. If the exporter does not know the name of the manufacturer, then they would enter ‘See attached overseas certificate of origin’ in the manufacturer’s box on the reverse of the application page.

  • A letter from the manufacturer on their company letterhead stating they manufacture the goods that appear on the C/O, or if this is not possible, then a list of items that they manufacture on their letterhead, including the country of manufacture and signed by the authorised representative of the company – the Chamber would need to cross reference items on the CO against the declaration to ensure all the items covered by the CO are accounted for. Letters from 3rd parties, suppliers, wholesalers etc. are not acceptable as they cannot make a declaration on behalf of the manufacturer.


IF YOU CANNOT PROVIDE ANY OF THE ABOVE, WE WILL NEED AT LEAST TWO OF THE FOLLOWING OPTIONS PER PRODUCT FOR US TO TAKE INTO CONSIDERATION

  • Information printed from the internet, this may be from the manufacturers website often found in the ‘About Us’ section, you are looking for a something that proves they produce the item/s that appear on the C/O. There must be a specific reference to the company manufacturing the goods on the webpage. Some companies are purely wholesalers and suppliers; hence, Chambers must be careful when considering evidence from company webpages.

  • Photographic evidence – This is really a last resort, a photograph of the product for example vacuum packed clearly showing ‘Made in ……….’ is acceptable with the manufacturers box reading ‘See attached photographic evidence’. You must be careful with food packaging as this will often show an address for consumers to deal with that is completely different to that where the product is manufactured. Photos of plain cardboard boxes that just show ‘Made in …………….’ are not acceptable.

  • Supplier invoice clearly showing origin for each item. If the manufacturer is unknown, then the reverse of the Application Form should state: “Proof of French, xxx, xxx origin, supplied by”

  • Email from the supplier. The email should list each item and its country of origin and manufacturer details. Company sending the email must not be involved in the shipment and name and contact details of the sender must be clearly visible. Emails where sender details are missing, or items are not clearly listed (hence preventing cross referencing to the CO) are not acceptable. Referencing a Purchase Order or Invoice no and just stating countries of origin is not acceptable, as this way we do not know origins for individual items in the shipment.

  • C88 (SAD) if provided by the exporter of the goods to UK.

EXAMPLES OF GOODS WHERE ORIGIN MAY BE DIFFICULT TO ESTABLISH

We understand there will be some difficulties when it comes to certain goods, the below provide some examples:

  • Movies – EU has specific criteria for determining origin of movies. The only way we can issue Certificates of Origin (for movies) would be against a written origin statement from the British Film Institute (http://www.bfi.org.uk) Alternatively, we can authenticate applicant’s declaration of origin (on their letterhead)

  • Works of art – determined by the birthplace of the artist

  • Antiques – Certificate of Antiquity from LAPADA (http://lapada.org/) or BADA (http://www.bada.org/)

  • Scrap metal – applicant must state that the metal was collected from various sites in the UK

  • Second-hand clothing and shoes – applicant must state that the items were collected from various sites in the UK

  • Machinery spare parts – if the spare part is classed as essential (i.e., the machine cannot work without it) then the part will have the same origin as the machine. Non-essential parts retain their own origin as per country of manufacture.

  • Cars – most manufacturers will provide origin information on their websites (origin is determined according to the VIN number) https://vindecoder.eu/

  • Medicines - http://www.medicines.org.uk/emc/browse-documents Once on the website you need to type in the exact drug and ensure you look at the mg ie 5mg as different weight drugs can be made in different countries. You will need to look at the PIL (patient information leaflet) and the manufacturer details are usually found on the last page. This leaflet is inserted into the boxes for all drugs sold.

Still unsure if your business complies with the right origin of goods evidence?

  • To ensure you are being compliant with your evidence, we offer an Origin Evidence Audit, where a member of our expert team can help you assess if the evidence you have in place meets the origin proof criteria and where there may be gaps which you may need to address. If interested in booking one, please email us at exportbritain@gmchamber.co.uk. Chamber Members access preferential rates.


  • We also offer a UK Certificate of Origin and EUR1 box-by-box workshop designed to help you understand common errors and the correct information that should be entered and will cover the differences between UK COO and EUR1s and what you need to know to successfully apply for both. For upcoming courses, click here.



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