Rules of Origin in the Japan-EU Economic Partnership Agreement
Interlink編集部What Are the Rules of Origin under the Japan-EU EPA?
The rules of origin under the Japan-EU Economic Partnership Agreement (EPA) define the criteria used to determine whether goods qualify as originating products eligible for preferential tariff rates.
Even if goods are exported or imported between Japan and the EU, the preferential EPA rates cannot be applied unless the goods meet the EPA’s rules of origin and the required certificate of origin procedures are completed.
The Japan-EU EPA primarily uses a self-declaration system, where exporters declare the origin of goods themselves, rather than relying on the traditional third-party certification system.
In practice, key elements include the origin declaration statement, the EU exporter’s REX number, the Japanese exporter’s corporate number, the HS code, product-specific rules of origin, shipment criteria, and proper retention of supporting documents.
Especially when importing goods from the EU into Japan, it is essential to verify the presence of the origin declaration statement and REX number on the invoice or other documents, check the declared country of origin and applicable goods, confirm the content of the declaration, and organize evidence in preparation for possible post-clearance verification by customs.
Scope Covered in This Article
This article addresses the practical aspects of rules of origin and certification procedures when using the Japan-EU EPA.
| Item | Contents Covered in This Article | Details Covered in Other Articles |
|---|---|---|
| Basics of the Japan-EU EPA Rules of Origin | Organizes the rules of origin and certification methods necessary to apply preferential tariff rates under the Japan-EU EPA | The overall system structure of rules of origin is covered in “Practical Guide to Rules of Origin Compliance” |
| Self-Certification System | Explains the importance of the self-certification system centered on origin declaration statements, rather than a third-party certification system, under the Japan-EU EPA | Details of the self-certification system are covered in “What Is the Self-Certification System?” |
| Exports from the EU to Japan and from Japan to the EU | Clarifies differences between the EU exporter’s REX number and the Japanese exporter’s corporate number | The overall classification of origin certification methods is covered in “Types of Certificates of Origin” |
| REX Number and the 6,000 Euro Threshold | Organizes the approach to confirming whether the REX number is required in origin declaration statements by EU exporters | Registration and verification under the REX system itself are covered in “What Is the REX System?” |
| Origin Declaration Statement | Addresses key points in verifying origin declaration statements included in invoices and other commercial documents | Example wording and formats for origin declaration statements are covered in specific articles |
| Knowledge of the Importer | Summarizes precautions when explaining origin based on information held by the importer | Details of importer self-declaration and the self-certification system are addressed in related specialist articles |
| HS Codes and Product-Specific Rules of Origin (PSR) | Clarifies the relationship between HS codes, product-specific rules of origin, CTC, RVC, and processing criteria | Detailed treatments of PSR, CTC, RVC, and processing criteria are covered in dedicated articles |
| Shipment Criteria | Discusses the approach to confirming that originating status is maintained during transit via third countries | Through B/L, bonded storage documents, non-processing proof, and related topics are covered in “What Are Shipment Criteria?” |
| Scope of Freight Forwarders’ Involvement | Organizes the scope of freight forwarders’ support for document consistency, number verification, transport document preparation, and the limits of origin determination | Freight forwarders’ responsibilities, customs document checks, and details of B/L and Sea Waybill practices are covered in related practical articles |
Purpose and Background of the System
The purpose of the Rules of Origin under the Japan-EU EPA is to grant preferential tariff rates exclusively for products originating under the agreement between Japan and the EU.
EPA rates cannot simply be applied based on cargo being exported from the EU or from Japan. It is essential to demonstrate that the cargo qualifies as originating under the Japan-EU EPA by meeting rules of origin, product-specific rules, certification methods, shipment criteria, and record-keeping requirements.
The Japan-EU EPA adopts a self-declaration system that relies on exporter origin declaration statements or importer knowledge declarations, rather than a traditional third-party certification model.
This approach facilitates smoother procedures without depending on pre-issued certification by issuing authorities; however, it places significant responsibility on exporters, importers, and producers to organize supporting documentation substantiating origin and to be prepared for customs verification.
In particular, the Japan-EU EPA often raises issues regarding REX numbers for EU-to-Japan exports and corporate registration numbers for Japan-to-EU exports. Different identification numbers need to be verified depending on the export direction. Understanding this direction-dependent structure is an important starting point for practical handling of Japan-EU EPA matters.
Situations Where the Japan-EU EPA Applies
| Situation | Reason the Japan-EU EPA is Relevant | Main Parties Responsible for Verification | Practical Considerations |
|---|---|---|---|
| When importing from the EU to Japan | Because Japanese importers may be able to apply preferential EPA tariff rates for EU-origin goods | Japanese importers, EU exporters, customs brokers | Verify origin declaration statement, REX number, EUR 6,000 threshold, and supporting documents for PSR |
| When exporting from Japan to the EU | Because EU importers may be able to apply preferential EPA tariff rates for Japan-origin goods | Japanese exporters, EU importers, customs brokers | Confirm that the exporter reference number is a corporate number, not a REX number |
| When the exporter prepares the origin declaration statement | Because preferential tariff rates are declared based on the statement on commercial documents | Exporters, importers, customs brokers | Confirm consistency among the declaration statement, the goods concerned, country of origin, reference number, and supporting origin documentation |
| When relying on the importer’s knowledge | Because the importer must hold evidence to explain origin | Importers, exporters, producers | Check whether the importer can explain materials lists, process sheets, RVC calculation documents, etc. |
| When routing via a third country | Because it is necessary to confirm that the goods maintain originating status during transport | Importers, exporters, freight forwarders | Verify transport documents meeting shipment criteria before loading |
| When customs conducts post-import verification | Because origin evidence may be requested after importation | Importers, exporters, producers | Retain not only the origin declaration statement but also PSR, material lists, processes, cost data, and transport documents |
Common Misconceptions
Several common misunderstandings arise regarding the Japan-EU EPA:
| Misconception | Actual Understanding | Possible Issues |
|---|---|---|
| If the product is made in the EU, the EPA tariff rate can be applied. | Even if made or shipped from the EU, it must be confirmed that the product qualifies as originating under the Japan-EU EPA. | Without origin declaration statements or supporting evidence, the EPA tariff rate cannot be applied. |
| Having a REX number proves the product’s origin. | The REX number identifies the EU exporter; it is not evidence itself confirming the origin criteria are met. | Only verifying the number and neglecting to check PSR compliance or material documents. |
| Declarations based on the importer’s knowledge can be used anytime. | To rely on the importer’s knowledge, the importer must have documentation that explains the product’s origin. | Unable to present material lists or process documentation at customs verification. |
| No declaration is needed if the value is under 6,000 euros. | While the REX number may not need to be stated under 6,000 euros, the origin declaration statement itself is still required. | Declaring the EPA tariff rate without any declaration statement. |
| Japanese exporters also obtain a REX number. | The REX number is part of the EU registered exporter system; Japanese exporters typically use their corporate number as the exporter reference number. | Mishandling the number when exporting from Japan to the EU. |
| Having an origin declaration statement means no supporting evidence is necessary. | The declaration statement is a means of proof; HS codes, PSR, materials, processes, and cost data are required supporting evidence. | Unable to explain origin during customs post-clearance verification. |
| Goods routed through a third country cannot use the EPA tariff rate. | The mere transit through a third country is not automatically disqualifying; it is critical to demonstrate compliance with the shipment criteria. | Failing to prepare necessary transport documents, hindering the confirmation of preferential tariff eligibility. |
| The freight forwarder will determine origin under the Japan-EU EPA. | Freight forwarders can assist with document alignment and transportation record keeping but are not responsible for origin determination. | Ambiguity over responsibility leads to declarations with insufficient supporting evidence. |
Differences Between EU-to-Japan and Japan-to-EU Shipments
Under the Japan-EU EPA, the reference numbers to be checked and practical considerations vary depending on the direction of export.
| Item | From EU to Japan | From Japan to EU | Practical Notes |
|---|---|---|---|
| Main Exporter Reference Number | REX number of the EU exporter | Corporate number of the Japanese exporter | The reference number to verify differs depending on export direction |
| Documents to Check | Origin declaration statements, REX number, and country of origin markings on the invoice or other commercial documents | Origin declaration statements, corporate number, and country of origin markings on the invoice or other commercial documents | Confirm which cargo the declaration statements correspond to |
| Notes on Number Verification | For originating goods valued over €6,000, confirm whether inclusion of the REX number is required | The corporate number is generally used as the exporter reference number instead of the REX number | Do not treat the REX number and corporate number as equivalent |
| Declarant | EU exporter or Japanese importer based on their knowledge | Japanese exporter or EU importer based on their knowledge | Confirm who is responsible for explaining the origin status |
| Importer’s Verification Responsibilities | Japanese importer verifies the declaration statements and supporting documents necessary for EPA preferential tariff declaration | EU importer confirms the information and documents required for customs clearance in the EU | Check in advance the documentation required by the importing country |
| Practical Points | Do not judge origin solely by EU markings or the REX number | Verify the presence of the Japanese corporate number, origin declaration statements, and their matching with the relevant cargo | Check export direction, reference number, declaration statements, and supporting documentation as an integrated set |
In the Japan-EU EPA, the focus is on the REX number for EU exporters and the corporate number for Japanese exporters. Since the significance of these numbers differs by export direction, it is necessary to treat shipments from the EU to Japan and from Japan to the EU separately for clarity.
Comparison between the Japan-EU EPA and Other Systems
The method of origin certification under the Japan-EU EPA differs from other EPAs, FTAs, and GSP schemes. In particular, the REX number, corporate number, importer’s knowledge, and the 6,000 euro threshold need to be specifically understood as unique verification points for the Japan-EU EPA.
| System / Agreement | Main Certification Method | Number / Registration Characteristics | Importer’s Verification Burden | Differences from Japan-EU EPA |
|---|---|---|---|---|
| Japan-EU EPA | Origin declaration statement and importer’s knowledge | REX number applies to EU exporters; corporate number is relevant for Japanese exporters | The declaration statement, applicable numbers, supporting documents for PSR compliance, and shipment criteria documents must be verified | Handling of numbers depends on shipment direction—REX for EU exports, corporate number for Japan exports |
| CPTPP | Self-certification system | Verification focuses on mandatory information required by the agreement | Documents to verify vary depending on whether the declarant is exporter, producer, or importer | REX numbers and the 6,000 euro threshold generally do not arise |
| RCEP | Third-party certification, certification by authorized exporters, or self-certification, etc. | May involve authorized exporter numbers or similar identifiers depending on countries and timing | Verification of the certification method varies by country and period | No direct correspondence like Japan-EU EPA’s EU REX number and Japan corporate number distinction |
| GSP | Origin certification under the GSP scheme | Certification methods vary depending on beneficiary countries and systems | Confirm beneficiary countries, applicable products, direct shipment requirements, and necessary certificates | Handled separately as a preferential scheme distinct from EPAs and FTAs |
| Third-Party Certification EPA Type | Specific certificate of origin issued by certifying authorities | Involves application to issuing bodies and determination of originating products | Consistency between the certificate and supporting documentation must be verified | Differs from the Japan-EU EPA, where exporters include origin declaration statements in commercial documents |
Methods of Certifying Origin
Under the Japan-EU EPA, origin is mainly certified through the following two methods:
- Origin declaration statement by the exporter
- Importer’s knowledge
In practice, the exporter typically includes an origin declaration statement on the invoice or other commercial documents, and the importer declares the EPA preferential tariff rate based on that declaration statement.
Use of the importer’s knowledge for declaration should generally be considered only when the importer has sufficient documentation to adequately explain the origin.
Differences Between Exporter’s Origin Declaration Statement and Importer’s Knowledge
| Item | Exporter’s Origin Declaration Statement | Importer’s Knowledge | Practical Considerations |
|---|---|---|---|
| Basic Concept | The exporter prepares the origin declaration statement, and the importer declares the EPA tariff rate based on it | The importer explains that the cargo qualifies as originating based on information they possess | Documentation to support the claim is needed in either approach |
| Suitable Situations | When the exporter can verify origin and include the declaration statement in commercial documents | When the importer can adequately obtain and manage manufacturing, material, and cost data | If the importer lacks documentation, avoid relying lightly on importer’s knowledge |
| Required Documents | Invoice or other commercial documents containing the origin declaration statement | Origin supporting documents held by the importer | Relying solely on either the declaration statement or documents may not be sufficient |
| Documents to Verify | Origin declaration statement, exporter reference number, country of origin, applicable goods, PSR supporting documents | HS code, PSR, materials lists, process sheets, RVC calculation data, supplier documents, etc. | Ensure these can be submitted and explained during customs verification |
| Points of Caution | Even with a declaration statement, lack of supporting documents may raise issues in customs checks | If importer lacks documentation, providing explanations becomes difficult | Agree on the scope of document provision at the start of the trade |
REX System and Handling of Japanese Exporters
The REX system stands for Registered Exporter System, referring to the EU's registered exporter program.
When an EU exporter prepares an origin declaration statement under the Japan-EU EPA, inclusion of the REX number is required for shipments exceeding a certain value.
Specifically, for origin declaration statements by EU exporters, the REX number must be noted on the origin declaration statement when the value of originating goods exceeds EUR 6,000 as a general rule.
For shipments valued at EUR 6,000 or less, an origin declaration statement may be prepared without a REX number.
The REX number is critical information identifying the EU exporter on the origin declaration statement. For imports into Japan from the EU, it is important to confirm whether the invoice’s origin declaration statement requires a REX number, whether the number provided is structurally valid, and whether it corresponds appropriately to the shipment value.
Conversely, when a Japanese exporter prepares an origin declaration statement for shipments to the EU, the exporter should indicate their Japanese corporate number as the exporter reference number, rather than an EU-side REX number.
Japanese exporters do not register for the REX system but instead organize their corporate number, origin declaration statement, relevant goods, and supporting documentation confirming compliance with origin criteria accordingly.
Key Points for the 6,000 Euro Threshold
When verifying whether the EU exporter’s REX number is required, special attention should be paid to how the 6,000 euro threshold is interpreted.
| Verification Item | Practical Interpretation | Common Issues | Practical Measures |
|---|---|---|---|
| Applicable Value | Confirm the value of the originating goods subject to the origin declaration statement | Deciding based only on the total invoice amount | If non-originating goods are mixed, clearly separate the items subject to the declaration statement |
| Invoice Unit or Item Unit | Confirm which originating goods on which commercial document the declaration statement refers to | Unclear which items among multiple products the declaration statement applies to | Match and verify the applicable items, quantities, values, and country of origin |
| When Below 6,000 Euros | The origin declaration statement may be prepared even if the EU exporter does not have a REX number | Misunderstanding that if the REX number is not required, the declaration statement is also unnecessary | Distinguish between the need for a REX number and the need for an origin declaration statement |
| When Above 6,000 Euros | Confirm whether the EU exporter’s REX number must be indicated | Proceed with import declaration without the REX number stated | Confirm with exporter, importer, and customs broker, and if necessary, correct before declaration |
| Currency Conversion and Price Adjustments | Clarify which value should be the basis when the transaction is in currency other than euro or there are discounts | Unclear treatment of discounted price, list price, and exchange rate conversion | If difficult to judge, confirm with importer, customs broker, and customs reference materials |
The 6,000 euro threshold is a critical point related to whether the REX number must be stated. However, even for values below 6,000 euros, it remains necessary to separately confirm the origin declaration statement and supporting evidence of origin.
Application Requirements and Common Exclusions
To utilize the Japan-EU EPA, it is necessary to comprehensively verify export direction, eligible cargo, origin criteria, certification method, transport routes, and record retention.
| Verification Item | Requirements for Application | Common Exclusions or Issues | Practical Measures |
|---|---|---|---|
| Eligible Transactions | Transactions under consideration for Japan-EU EPA application between Japan and the EU | Even if routed via the EU, the cargo does not qualify as originating goods under the Japan-EU EPA | Separately verify export country, origin country, transport route, and eligible cargo |
| Preferential Tariff Rate | Japan-EU EPA preferential tariff rate is set for the applicable HS code | No tariff difference even when using EPA rates, or the cargo is excluded | Compare MFN tariff rate and EPA tariff rate |
| HS Code | HS code of the cargo is reasonably confirmed | HS code judged only by product name | Check specifications, materials, usage, structure, and advance ruling materials |
| Product-Specific Rules of Origin (PSR) | Meets itemized product-specific rules of origin under Japan-EU EPA | Apply PSR from different agreements | Confirm Japan-EU EPA PSR and organize CTC, RVC, and processing criteria |
| Origin Declaration Statement | Required declaration statement is included in the invoice or other commercial documents | No declaration statement, unclear cargo, missing number or origin indication | Verify declaration statement, applicable cargo, origin country, and exporter reference number |
| REX Number | Provided by the EU exporter when required | REX number missing for cargo exceeding 6,000 euros | Confirm declared value and necessity of REX number |
| Corporate Number | For Japanese exporters declaring to the EU, the handling of the corporate number has been confirmed | Misunderstanding that Japanese exporters should use the REX number | Confirm corporate number as the exporter reference number for Japan-to-EU shipments |
| Importer’s Knowledge | Importer holds documentation able to explain origin status | Importer cannot obtain documents held only by exporter or producer | Confirm availability of material lists, process charts, and RVC documentation prior to import |
| Shipment Criteria | Can explain that cargo was not processed or altered when transiting third countries | Unable to explain bonded control or non-processing at transit locations | Verify Through B/L, transshipment records, bonded control documents, and non-processing certificates |
| Record Retention | Retain supporting documents to respond to customs post-clearance audits | Only origin declaration statements retained, lacking supporting documentation | Retain HS codes, PSR, materials, processes, costs, and transport documents together |
Verification of Origin Declaration Statements
Under the Japan-EU EPA, it is essential to include the prescribed origin declaration statement on invoices and other commercial documents.
The origin declaration statement should indicate that the goods qualify as originating products under the agreement, specify the country of origin, exporter information, and the criteria used to determine origin.
Having an origin declaration statement alone does not automatically grant EPA preferential tariff rates. It is necessary to verify it together with the HS code, product-specific rules of origin, shipment criteria, and supporting documentation.
| Check Item | Details to Verify | Common Issues | Practical Measures |
|---|---|---|---|
| Wording | Is the statement written in accordance with the prescribed wording? | Statements may be incomplete or confused with wording from other schemes. | Cross-check with the wording requirements of the relevant agreement. |
| Applicable Document | Is the statement clearly indicated on commercial documents that identify the subject goods? | It may be unclear which invoice or product the statement refers to. | Match with invoice number, product description, quantity, and value. |
| Country of Origin | Is the country of origin properly indicated? | Confusion between EU-made labeling and the country of origin under the Japan-EU EPA. | Confirm against origin criteria and supporting documentation. |
| Exporter Number (EU side) | Is the REX number included when required? | Missing REX number despite declared value exceeding 6,000 euros. | Verify whether the declared value requires a REX number and confirm its presence. |
| Exporter Number (Japan side) | Is the exporter reference number, such as a corporate number, handled appropriately? | Misunderstanding that the Japanese exporter must include a REX number. | For shipments from Japan to the EU, confirm the appropriate handling of the corporate number. |
| Multiple Products | Is it clear which goods the declaration applies to? | Mix of originating and non-originating goods causing ambiguity on the scope. | Separately verify applicable product items, quantities, values, and countries of origin. |
| Consistency with Supporting Documents | Does the origin criteria used align with the supporting documentation? | Mismatch between declaration statements and PSR determination documents. | Cross-check HS codes, PSRs, bill of materials, process flowcharts, and RVC calculations. |
HS Codes and Product-Specific Rules of Origin
Under the Japan-EU EPA rules of origin, the HS code of the cargo must be identified first, followed by a check of the corresponding Product-Specific Rules of Origin (PSR) for that HS code.
Product-Specific Rules of Origin are also known as PSR, which stands for Product Specific Rules.
Even when applying the same Japan-EU EPA, the origin criteria required vary by product. For some products, a tariff classification change alone may suffice, while others may require value-added content or specific processing steps.
Misidentifying the HS code can lead to applying incorrect product-specific origin rules. Therefore, it is important not to rely solely on the product name on the invoice, but to verify product specifications, materials, usage, structure, and manufacturing processes.
Main Origin Criteria
| Criterion | What Is Verified | Main Reference Documents | Points to Note |
|---|---|---|---|
| Change in Tariff Classification (CTC) | Whether the HS codes of non-originating materials and the finished product have changed to the level required by the agreement | HS codes of finished product and materials, materials list, classification justification documents | Verification of individual HS codes for each material is required |
| Regional Value Content (RVC) | Whether a specified minimum percentage of the finished product’s value was created within the agreement area | FOB price, value of non-originating materials, cost data, RVC calculation documents | It may be difficult to explain without retaining calculation basis documentation |
| Processing Criterion | Whether specific manufacturing or processing steps required by the agreement were performed | Manufacturing process charts, production records, work instructions, subcontractor documents | Explanation should cover actual operations, not just process names |
| Cumulation | Whether production or originating materials from Japan or the EU can be included in the origin determination | Origin documentation for materials, supplier certifications, process records | Simply sourcing from the partner region is not sufficient |
| Tolerance Thresholds | Whether some non-originating materials that fail to meet criteria can be tolerated | Material price data, weight data, calculation basis | The eligibility and limits under the agreement should be confirmed |
Shipment Criteria and Direct Shipment Requirements
Under the Japan-EU EPA, it is necessary to confirm that originating goods have been properly transported from the exporting country to the importing country.
Even if the cargo meets the origin criteria, processing, alteration, or storage in a non-bonded status while passing through a third country may affect the application of EPA preferential rates.
Passing through a third country is not automatically an issue. However, it must be demonstrated that handling in the third country falls within the scope allowed by the agreement, such as transshipment, temporary storage, or operations necessary for preserving the goods.
| Situation | Verification Items | Main Documents | Practical Measures |
|---|---|---|---|
| Direct Transport | Whether transportation occurs directly between Japan and the EU | B/L, Sea Waybill, Air Waybill | Cross-check cargo details between transport documents and invoice |
| Via Third Country | Whether processing or alteration occurred at the transit point | Through B/L, transshipment records, documentation from transit location | If routing via a third country exists, verify required documents before shipment |
| Temporary Storage | Whether storage was under bonded status or customs control | Bonded storage documentation, warehouse certificates, proof of no processing | Confirm availability of documents through importer, freight forwarder, or local agent |
| Multimodal Transport | Whether the transport route and cargo identity can be substantiated | Multiple transport documents, transshipment records, cargo delivery records | Manage documents for each transport segment as a single set |
Declaration Based on Importer's Knowledge
Under the Japan-EU EPA, it is also legally permissible to request the application of preferential tariff rates based on the importer’s knowledge.
This method relies on information held by the importer to demonstrate that the goods qualify as originating products under the agreement.
However, when using declaration based on the importer’s knowledge, the importer must have sufficient documentation to substantiate origin.
If manufacturing details, raw material information, RVC calculation data, or other evidence are exclusively held by the exporter or producer, the importer may not be able to provide adequate explanation.
Documents Commonly Required by Importers
| Document | What to Verify | Common Issues | Practical Handling |
|---|---|---|---|
| HS Code Confirmation Documents | Identify the cargo and the applicable product-specific rules of origin | Unable to explain basis for product classification | Retain specifications, catalogs, and advance rulings for reference |
| Product-Specific Rules of Origin (PSR) Confirmation Documents | Confirm which origin criteria need to be met | Referring to PSR from agreements other than Japan-EU EPA | Verify the PSR under the Japan-EU EPA |
| Raw Materials List / Parts List | Distinguish between originating and non-originating materials | Explanation is difficult if importer cannot obtain the list | Agree with the exporter or manufacturer on the scope of provision prior to import |
| Material HS Code Documents | Check if the tariff classification change (CTC) requirement is met | No basis for classification of individual materials | Retain material lists together with classification rationale documentation |
| Manufacturing Process Chart | Confirm which country performed which manufacturing steps | Unable to explain processes under processing criteria | Review process charts, work records, and subcontracting documents |
| Regional Value Content (RVC) Calculation Documents | Verify compliance with value-added requirements | Unable to obtain pricing or cost data | Establish a confidential data-sharing system as needed |
| Supplier Certificates | Confirm origin status and values of materials | Difficulty obtaining cooperation within the supply chain | Check availability of supplier documents at start of transaction |
| Shipment Criteria Documents | Confirm whether originating status is maintained when transshipping via a third country | Unable to provide transport route or bonded control documents | Verify necessary documents with the freight forwarder before shipment |
Declarations based on the importer’s knowledge can be effective when the importer has sufficient documentation. However, using this approach without cooperation from the exporter or manufacturer may complicate responding to customs inquiries.
Post-Import Customs Verification
When using EPA preferential tariff rates under the Japan-EU EPA, customs may conduct a verification of origin after importation.
This verification could require submission and explanation of documents supporting the declared origin, not just the origin declaration statement.
For example, customs may review the HS code, product-specific rules of origin, manufacturing processes, raw materials, RVC calculations, supplier documentation, and shipping documents related to shipment criteria.
Even if a declaration exists, lacking supporting evidence may result in denial of the preferential tariff rate. Therefore, managing documentation not only at the time of import declaration but also in preparation for possible post-import verification is crucial.
Practical Workflow
When verifying the rules of origin under the Japan-EU EPA, the process generally follows these steps:
- Confirm whether the transaction utilizes the Japan-EU EPA
- Confirm the export direction: from the EU to Japan or from Japan to the EU
- Verify the HS code of the cargo concerned
- Check if the cargo has an EPA tariff rate applied
- Review the product-specific rules of origin
- Identify which criteria explain origin: CTC, RVC, processing criteria, etc.
- For EU-side exporters, confirm whether a REX number is required
- For Japan-side exporters, verify how the exporter reference number, such as the corporate number, is handled
- Check the content of the origin declaration statement
- If using the importer’s knowledge, confirm whether the importer holds the supporting documentation
- If there is transshipment via a third country, confirm the applicable shipment criteria and direct shipment requirements
- Declare the use of EPA tariff rates at the time of import declaration
- Retain documentation supporting the origin status
- Prepare for potential customs audit and post-clearance verification
Checklist for Decision Points
The rules of origin under the Japan-EU EPA should not be checked only immediately before import declaration. They need to be organized chronologically from the start of the transaction through customs post-verification.
| Decision Point | Persons to Consult | Matters to Confirm | Action if Issues Arise |
|---|---|---|---|
| At Start of Transaction | Importer, Exporter, Sales Representative | Whether the transaction will use the Japan-EU EPA, origin in the EU or Japan, availability of EPA tariff rates | If the applicable agreement or tariff rates are unclear, verify both the standard and EPA tariff rates |
| When Confirming HS Codes | Importer, Exporter, Customs Broker | HS code for the cargo, basis for classification, product-specific rules of origin | If classification is questionable, consider gathering additional documents, consulting experts, or requesting advance rulings |
| When Determining Origin | Exporter, Producer, Importer | Use of CTC, RVC, processing criteria, cumulation, and tolerance limits | If supporting evidence is insufficient, suspend preferential use and prioritize obtaining necessary documentation |
| When Reviewing Declaration Statements | Exporter, Importer, Customs Broker | Origin declaration statement, REX number, corporate number, country of origin, correspondence with the cargo | If numbers or cargo correspondence are unclear, confirm with the exporter and correct as needed |
| When Using Importer’s Knowledge | Importer, Exporter, Producer | Whether the importer holds documentation to explain the origin status | If unable to provide necessary documents, consider using exporter’s declaration method or improving document provision system |
| When Arranging Transport | Exporter, Importer, Freight Forwarder | Direct shipment, transit through third countries, transshipment, shipment criteria | If transit through a third country occurs, confirm the availability of Through B/L or bonded control documents |
| At Import Declaration | Importer, Customs Broker | EPA tariff rate declaration, validity of declaration statement, consistency with cargo details | If inconsistencies exist, consider supplementary explanation, correction, or declaring at the standard tariff rate |
| During Customs Post-Verification | Importer, Exporter, Producer | Evidence supporting origin, materials, processes, costs, shipment criteria, retained documents | Obtain missing documents as needed and check for any impacts on past declarations |
Main Documents
The key documents important when verifying the Rules of Origin under the Japan-EU EPA are as follows.
| Document/Material | Purpose of Verification | Party to Verify With | Points to Note |
|---|---|---|---|
| Invoice or Commercial Document with Origin Declaration Statement | Confirm exporter’s self-declaration | Exporter, Importer, Customs Broker | Verify the applicable goods, country of origin, exporter reference number, and origin criteria |
| Document Showing the REX Number | Confirm EU exporter | EU Exporter, Japanese Importer | For EU exports to Japan, check relation to the €6,000 threshold |
| Material Confirming Japanese Exporter’s Corporate Number | Verify Japanese exporter’s reference number | Japanese Exporter, EU Importer | For Japan exports to EU, avoid confusing this with REX number |
| Invoice and Packing List | Confirm cargo details, prices, quantities, and applicable items | Exporter, Importer, Freight Forwarder | Clarify which goods the declaration applies to |
| HS Code Verification Materials | Identify applicable products and PSR | Importer, Exporter, Customs Broker | Incorrect HS codes could lead to incorrect origin determination |
| Product-Specific Rules of Origin Reference Materials | Check which origin criteria need to be met | Importer, Exporter, Origin Compliance Officer | Confirm PSR under Japan-EU EPA |
| List of Raw Materials, Parts List, Material List | Organize originating and non-originating materials | Manufacturer, Exporter, Importer | Important for confirming CTC, RVC, and cumulation |
| Manufacturing Process Chart | Verify which processes were performed in which countries | Manufacturer, Exporter | Used to explain processing criteria and manufacturing realities |
| RVC Calculation Materials | Confirm compliance with value-added criteria | Manufacturer, Exporter, Importer | Keep pricing and cost records |
| Supplier Certificates | Verify origin and value of materials | Supplier, Manufacturer, Exporter | Important when materials are treated as originating materials |
| B/L, Sea Waybill, Air Waybill | Confirm transport routes and shipment criteria | Freight Forwarder, Shipping Line, Airline, Importer | Check additional documents if transshipment through third countries occurs |
| Bonded Control Documents and Non-Processing Certification for Third-Country Transshipment | Ensure originating status is maintained at transit locations | Importer, Freight Forwarder, Local Agent | Prepare to explain transshipment and temporary storage conditions |
| Retention of Documents for Customs Verification | Explain origin in post-import verification | Importer, Exporter, Manufacturer | Retain not only declarations but also all supporting documentation |
Scope of Freight Forwarder Involvement
Freight forwarders are not responsible for determining the rules of origin under the Japan-EU EPA.
Assessing origin requires information such as HS codes, raw materials, manufacturing processes, cost calculations, and supplier details, which should be managed by importers, exporters, and producers.
However, freight forwarders play a role in verifying the consistency of documents such as invoices, packing lists, Bills of Lading, Sea Waybills, and Arrival Notices, as well as checking the presence of origin declaration statements or REX numbers.
They may also assist in organizing transport documents related to shipment criteria when third-country transit is involved.
What Freight Forwarders Can Support and What They Should Not Conclude
| Item | What Freight Forwarders Can Support | What Freight Forwarders Should Not Conclude | Practical Approach |
|---|---|---|---|
| Document Consistency | Check consistency among Invoice, Packing List, B/L, and Sea Waybill entries | Final determination of whether goods qualify as originating under the Japan-EU EPA | If inconsistencies arise, advise verification with importer, exporter, or customs broker |
| Origin Declaration Statement | Formally confirm presence of declaration statement, relevant goods, country of origin, and number entries | Guarantee that the declaration statement content meets origin criteria | Verify consistency between declaration statement, invoice, relevant goods, and declaration number |
| REX Number and Corporate Number | Organize which number should be checked depending on whether shipment is EU or Japan origin | Guarantee origin status solely based on presence of numbers | Separate export direction and number types and confirm these details with the shipper |
| Shipment Criteria | Organize documents related to third-country transit, transshipment, through B/Ls, and transit point materials | Legally conclude whether shipment meets agreement criteria | Confirm availability of Through B/L, bonded storage documents, and non-processing certificates |
| Guidance to Shippers | Prompt exporters, importers, and producers to confirm necessary documents | Guarantee fulfillment of CTC, RVC, or processing operation requirements | Ensure origin determination is confirmed by shipper, exporter, producer, or customs broker |
| Preparation for Customs Verification | Support re-acquisition of transport and shipping documents | Guarantee sufficiency of origin documentation | Separate management of personnel handling transport and origin documentation |
In freight forwarder operations, rather than conclusively determining eligibility under the Japan-EU EPA, it is safer to position the role as supporting verification of declaration statements, REX numbers, corporate numbers, shipping routes, and document consistency, thereby assisting preparations for customs verification.
Common Issues with Rules of Origin under the Japan-EU EPA
| Situation | Issue | Points to Check | Practical Response |
|---|---|---|---|
| Missing REX Number | The EU exporter’s invoice includes an origin declaration statement, but the required REX number is not provided | Value of goods subject to declaration, the €6,000 threshold, exporter information | Confirm with the exporter before filing and request document correction if necessary |
| Failure to Verify the €6,000 Threshold | The invoice amount exceeds €6,000, but the necessity of the REX number has not been checked | Declared items, invoice amount, distinction between originating and non-originating materials | Clarify the scope of the declaration and verify if a REX number is required |
| Insufficient Confirmation of Japan Exporter Number | Confusion between the REX number and corporate number for exports from Japan to the EU | Export direction, corporate number, content of the origin declaration statement | For exports from Japan to the EU, manage the corporate number as the exporter reference number |
| Incorrect HS Code | Checking product-specific rules of origin based on an incorrect HS code, resulting in a mistaken origin determination later | Product classification materials, PSR, HS codes of materials | Review product specifications, materials, end use, and seek advance rulings if needed |
| Incomplete Origin Declaration Statement | The declaration statement lacks necessary details, requiring additional confirmation during import declaration or customs inspection | Declaration statement content, country of origin, exporter reference number, correlation with cargo | Verify the declaration statement details before import filing, and confirm with the exporter if discrepancies are found |
| Importer’s Lack of Documentation or Knowledge | Attempting to file based on importer’s knowledge but lacking manufacturing data or raw material information | Material lists, process flow charts, RVC calculation data, supplier certificates | If unable to obtain documentation, consider using the exporter’s origin declaration statement |
| Insufficient Proof of Shipment Criteria | Though the product originates from the EU, there is inadequate documentation to explain bonded storage or non-processing during transit through third countries | Through B/L, transshipment records, bonded storage documentation, non-processing certificates | Confirm required transportation documents with the freight forwarder before shipment |
| Lack of Supporting Documentation | Origin declaration statement exists, but manufacturing process or material documents cannot be presented during customs post-clearance inspection | PSR verification documents, material lists, process charts, cost data, full record retention | Maintain documentation from the time of declaration, anticipating customs verification |
Application Scenarios of the System
Scenario 1: The EU Exporter’s REX Number Is Missing
For cargo imported from the EU to Japan, there are cases where the origin declaration statement appears on the invoice but the REX number is not included.
In this situation, first verify the value of the originating products covered by the declaration statement and assess its relationship to the 6,000-euro threshold. If the value is 6,000 euros or less, an origin declaration statement may still be acceptable without a REX number; however, if it exceeds 6,000 euros, the requirement to include the REX number becomes an issue.
In practice, judgment should not be based solely on the total invoice amount. Instead, verify the items targeted by the origin declaration statement, the distinction between originating and non-originating materials, exporter information, and value. If a REX number appears to be necessary but is missing, confirm with the EU exporter before import declaration and coordinate with the customs broker on the appropriate response.
Scenario 2: Misunderstanding That No Declaration Is Needed for Cargo Under 6,000 Euros
There are cases where the EU exporter explains that because the cargo value is 6,000 euros or less, a REX number is not required, which leads to the mistaken belief that an origin declaration statement is also unnecessary.
However, the 6,000-euro threshold pertains only to the requirement for including the REX number, not to eliminating the need for the origin declaration statement itself or the substantiating documents for origin.
In such cases, verify that the origin declaration statement is indeed included in the commercial documents, corresponds to the applicable cargo, and contains confirmable origin countries and exporter details. Additionally, prepare to support post-clearance customs verification by possessing or retaining supporting documents such as HS codes, PSR, material lists, production process charts, and RVC calculation data.
Scenario 3: Misunderstanding That Japanese Exporters Must Obtain a REX Number
In transactions exporting from Japan to the EU, there are cases where the EU counterpart requests an identification number, causing Japanese exporters to mistakenly believe they must acquire a REX number.
The REX number is related to the EU’s registered exporter system. When a Japanese exporter prepares an origin declaration statement for goods destined for the EU, the exporter’s corporate number in Japan is typically used as the exporter reference number.
In these cases, first confirm the export direction and clarify that the shipment is from Japan to the EU. Then verify the origin declaration statement on the invoice or other commercial documents, the corporate number, applicable cargo, origin country, and compliance documentation with origin criteria. It is also important to confirm in advance the specific declaration format required by the EU importer or local customs broker.
Scenario 4: Importer Attempts Declaration Based on Own Knowledge but Lacks Supporting Documents
Japanese importers may attempt to declare under the Japan-EU EPA preferential rates based on their own knowledge but find they do not have sufficient documents such as production process charts, raw material information, RVC calculation data, or supplier certificates.
Declaration based on the importer’s knowledge requires that the importer have documents sufficient to explain the origin of the cargo. If documents are only available from the exporter or producer, the importer may not be able to satisfactorily respond during customs verification.
In such cases, confirm before import which documents can be obtained from the exporter or producer. If the necessary documents cannot be secured, reconsider the declaration approach—for example, using the exporter’s origin declaration statement or postponing the use of the EPA preferential rate.
Scenario 5: PSR Met but Shipment Criteria Documents Are Insufficient
Even if the cargo meets the Product-Specific Rules of Origin (PSR) as an EU-originating product, issues may arise regarding documents proving compliance with shipment criteria when the goods are transported via a third country en route to Japan.
Passing through a third country does not automatically disqualify the application of the EPA preferential tariff rate; however, it must be demonstrated that no processing or alteration occurred in the transit country and, if necessary, that the goods were stored under customs control or in a bonded warehouse.
In practice, verify documents such as Through B/Ls, transshipment records, transit country documentation, customs control records, and certificates of non-processing. Freight forwarders can assist in organizing shipping routes and shipping documents, but the final determination of whether goods qualify as originating under the Japan-EU EPA should be confirmed by the importer, exporter, producer, or customs broker.
Practical Checklist
When verifying the rules of origin under the Japan-EU EPA, confirm the following points.
- Whether the transaction uses the Japan-EU EPA
- Whether the shipment is EU export to Japan or Japan export to EU, and organize accordingly
- Confirm the HS code of the cargo involved
- Confirm whether an EPA preferential tariff rate applies to the cargo
- Check the product-specific rules of origin under the Japan-EU EPA
- Determine whether origin is explained by CTC, RVC, or processing criteria
- For EU-side exporters, confirm if a REX number is required
- Understand the EUR 6,000 threshold separately regarding the need for a REX number and the requirement for an origin declaration statement
- For Japanese-side exporters, confirm how the corporate number is handled
- Confirm the wording of the origin declaration statement, country of origin, cargo covered, and the applicable number
- If relying on importer’s knowledge, confirm that the importer holds supporting documentation
- If transshipping via a third country, check the shipment criteria
- Keep supporting documents for customs post-clearance verification
- Do not delegate origin determination entirely to the freight forwarder
Summary
The rules of origin under the Japan-EU EPA are characterized by the adoption of a certificate of origin system centered on self-certification.
In practical logistics, the REX number for EU exporters, the corporate number for Japanese exporters, the origin declaration statement, HS codes, product-specific rules of origin, shipment criteria, and retention of supporting documents are all important.
Goods labeled as “Made in the EU” are not necessarily originating products under the Japan-EU EPA. Likewise, possession of a REX number alone does not prove origin status.
In practice, it is necessary to separately organize shipments from the EU to Japan and from Japan to the EU. Based on that, the contents of the origin declaration statement, handling of the REX or corporate number, compliance with origin criteria, transport routes, and documentation available to respond to customs’ post-verification should be confirmed before determining application of the EPA preferential tariff.
