Types of Certificates of Origin
Interlink編集部Types of Certificates of Origin
The types of certificates of origin refer to classifications of origin certificates used in import-export transactions based on differences in purpose, issuing authority, declarant, certification method, and responsibility.
Certificates of origin include general certificates of origin, which are used for purposes other than tariff preferences, and preferential certificates of origin used to apply preferential tariff rates under EPAs, FTAs, GSP, and similar systems.
Preferential certificates of origin include specific certificates of origin under EPAs and FTAs, origin declarations, origin declaration statements, self-declaration systems, certification through authorized exporter schemes, and GSP-related certificates of origin.
Among these, the specific certificate of origin is a form of preferential certificate of origin, primarily issued through a third-party certification system. Although the GSP is a separate system from EPAs and FTAs, because it involves certificates of origin to receive tariff preferences, it is distinguished as a preferential certificate rather than a general origin certificate.
Even when the document is called a “certificate of origin,” differences in the system affect the required documentation, declarants, record retention, and interactions with customs procedures. Therefore, understanding the types of certificates of origin is fundamental for utilizing EPAs, confirming GSP status, obtaining general certificates of origin, and managing export-import documentation.
Scope Covered in This Article
This article addresses how to distinguish types of certificates of origin and origin certification methods in practical business.
This article serves as an intermediate-level overview linking the hub article “What Is a Certificate of Origin” with more specialized articles such as “What Is the Self-Certification System,” “What Is the Third-Party Certification System,” “What Is the Authorized Exporter System,” and “What Is the REX System.”
| Item | Contents Covered in This Article | Contents Covered in Other Articles |
|---|---|---|
| Types of Certificates of Origin | Organizes classification of general certificates of origin, certificates of origin for preferential purposes, specific certificates of origin, GSP certificates, etc. | The overall introduction to certificates of origin is covered in “What Is a Certificate of Origin.” |
| General Certificates of Origin vs. Certificates for Preferential Purposes | Differentiates whether the purpose is customs duty preference or submission to trading partners, letter of credit conditions, or non-preferential purposes. | Details on non-preferential origin rules and origin marking are covered in separate articles. |
| Classification of Certification Methods | Organizes third-party certification, self-certification, exporter declaration, producer declaration, importer self-declaration, and authorized exporter system. | Details on self-certification system, third-party certification system, and authorized exporter system are addressed in separate articles. |
| Specific Certificates of Origin | Positions specific certificates of origin as one form of certificates of origin for preferential purposes. | Details on third-party certification system and issuance procedures by agreement are covered elsewhere. |
| REX System | Clarifies differences between the EU-side REX number and the Japan-side corporate number under the Japan-EU EPA. | Registration requirements, number verification, and example entries for the REX system are covered in “What Is the REX System.” |
| GSP-Related Certification | Explains that GSP operates as a separate system from EPAs and FTAs but is also classified as a certificate of origin for preferential purposes. | Details on eligible countries, products, origin criteria, and required certification for GSP are covered in GSP-related articles. |
| Certification Methods by Agreement | Compares certification methods of CPTPP, Japan-EU EPA, RCEP, GSP, and general certificates of origin. | Procedures, eligible products, and tariff rate confirmation by agreement are covered in specific EPA/FTA articles. |
| Responsible Parties and Records Retention | Organizes who explains origin depending on the certification method and what documents must be retained. | Post-clearance customs verification, verification procedures, and origin investigations are covered in separate articles. |
| Freight Forwarders’ Scope of Involvement | Organizes what freight forwarders can typically assist with under each certification method and cautions against definitive conclusions. | Freight forwarder responsibilities, customs document verification, and details on B/L and transport documents are in related practical articles. |
Reasons for Organizing Types of Certificates of Origin
Grouping all certificates of origin simply as documents showing the country of origin can lead to misunderstandings.
In one transaction, a general certificate of origin may be required to satisfy letter of credit conditions, while in another, a specific certificate of origin or an origin declaration is needed to apply EPA preferential tariff rates. Furthermore, under the Japan-EU EPA, issues arise regarding origin declaration statements and verification of REX numbers or corporate registration numbers, while under the GSP, certificates and direct shipment requirements differ from those under EPAs.
Therefore, when confirming the type of certificate of origin, it is important not to rely solely on the document name but to consider the purpose, system, certification method, declarant, retention of supporting documents, and explanatory responsibilities during customs verification.
Common Misunderstandings
The following misunderstandings frequently arise regarding types of certificates of origin.
| Misunderstanding | Actual Understanding | Potential Issues |
|---|---|---|
| A general certificate of origin can be used for EPA preferential rates | General certificates of origin are often used for non-preferential purposes; preferential certificates of origin specific to each agreement are required to apply EPA preferential tariff rates | EPA preferential rates may not be applied at import, resulting in the standard tariff rate |
| Specific certificates of origin and certificates of origin for preferential purposes are the same | Specific certificates of origin are a form of preferential certificates of origin, mainly issued under third-party certification systems | Other preferential certification methods such as self-declaration or origin declaration statements may be overlooked |
| Having a certificate issued by a third-party institution guarantees origin | Issuing bodies verify the submitted documents, but it is the applicant’s responsibility to manage the supporting materials and accuracy of the declared origin | Unable to explain supporting documents during customs verification |
| Anyone can use self-declaration | The persons eligible for self-declaration vary depending on the agreement or system, requiring confirmation whether exporter's, importer's, or producer's declaration applies | Documents may be prepared by unauthorized declarants |
| A REX number is required for exports from Japan to the EU | The REX number is part of the EU’s Registered Exporter system; when Japanese exporters declare to the EU, typically the Japanese corporate number is used | Confusing the export direction may lead to incorrect number requirements |
| Supporting documents are unnecessary if an origin declaration statement is provided | The declaration statement is a means of certification; however, documentary evidence such as materials, processing records, and cost data verifying origin criteria must be retained | Unable to substantiate origin during post-verification |
| GSP is a type of EPA | GSP is a separate scheme from EPAs and FTAs, but it is categorized under preferential certificates of origin as it relates to origin certification for tariff preferences | Misunderstanding the system can lead to inadequate preparation of necessary certificates or verification documents |
| Importer self-declaration means importers alone can complete the process | Even with importer self-declaration, supporting materials such as material lists, processing records, and cost data held by the exporter or producer may be required | Origin cannot be fully explained by the importer alone during customs inspection |
| Freight forwarders make the final decision on certification methods | Freight forwarders can assist with document coordination and transport data management but are not the final decision-makers on origin or certification methods | The responsible party becomes unclear, risking failure to fulfill explanation responsibilities after declaration |
Differences Between General Certificates of Origin and Certificates of Origin for Preferential Purposes
Certificates of origin can be broadly categorized into general certificates of origin and certificates of origin for preferential purposes.
General certificates of origin primarily serve to certify the country of origin of export cargo. They may be used for import customs procedures, letter of credit requirements, trading partner requests, import restrictions, and origin marking.
On the other hand, certificates of origin for preferential purposes certify or declare that cargo qualifies as originating goods under systems such as EPAs, FTAs, and the GSP to benefit from preferential tariff rates. This category includes specific certificates of origin, origin declarations, origin declaration statements, self-declarations, certified exporter systems, and GSP-related certificates of origin.
| Item | General Certificates of Origin | Certificates of Origin for Preferential Purposes | Practical Points |
|---|---|---|---|
| Main Purpose | Requests from the importing country, letter of credit conditions, origin marking, submission to trading partners, etc. | To utilize preferential tariff rates under EPAs, FTAs, GSP, etc. | Confirm whether the submission purpose is non-preferential or for tariff preference |
| Main Documents / Methods | General certificates of origin issued by chambers of commerce, etc. | Specific certificates of origin, origin declarations, origin declaration statements, self-declarations, certified exporter schemes, GSP-related certificates of origin, etc. | Organize specific certificates of origin as one type of preferential certificate of origin |
| Relation to Tariff Preferences | Generally not intended for the application of EPA or GSP rates | Directly related to the application of preferential tariff rates | General certificates of origin alone do not guarantee application of EPA or GSP rates |
| Main Issuing / Preparing Entities | Issuing bodies such as chambers of commerce | Issuing entities, exporters, producers, importers, etc., depending on the agreement or system | Confirm who can prepare or declare per each agreement |
| Rules to Verify | Non-preferential rules of origin, importing country requirements, transaction conditions | Preferential rules of origin under the relevant agreement or system, PSR, shipment criteria, certification methods | Do not confuse origin determination for marking with that for preferential tariff application |
| Documentation Retention | Transaction documents, manufacturing country documents, materials required by the submission destination, etc. | HS codes, PSR, material lists, process charts, cost data, shipment documentation, etc. | For preferential purposes, retaining supporting documents in addition to certificates is important |
Overall Classification of Certificates of Origin, Certification Methods, and Responsible Parties
Understanding certificates of origin and their certification methods becomes clearer when purpose, issuing entity, declarant, responsible party, and documentation retention are considered as an integrated framework.
| Type / Method | Main Purpose | Issuing / Creating Entity | Main Party Explaining Origin | Documents to Retain | Typical Use Cases |
|---|---|---|---|---|---|
| General Certificate of Origin | Indicates country of origin for non-preferential purposes | Issuing bodies such as Chambers of Commerce | Applicant, Exporter | Application documents, invoice, manufacturing country documents, client requirements | Letter of credit conditions, client requests, importing country requirements |
| Specific Certificate of Origin | A type of preferential certificate of origin for utilizing EPA tariff rates | Designated issuing authorities under the agreement | Exporter, Applicant, Producer | Origin determination documents, material lists, manufacturing certificates, invoices, PSR verification documents | EPAs employing third-party certification systems |
| Exporter’s Self-Declaration | Exporter declares the origin status | Exporter | Exporter | PSR verification documents, material lists, process charts, RVC calculation documents, supplier certificates | Japan-EU EPA, CPTPP, etc. |
| Producer’s Declaration | Producer declares origin based on manufacturing information | Producer | Producer | Manufacturing process charts, raw material lists, cost breakdowns, supplier certificates | When the producer holds origin information |
| Importer’s Self-Declaration | Importer declares application for preferential tariff rate | Importer | Importer | Supporting documents obtained from exporter/producer, import declaration documents, PSR verification documents | Accepted under CPTPP, RCEP, etc., in some cases |
| Authorized Exporter System | Authorized exporters make the declaration | Authorized Exporter | Authorized Exporter | Certification-related documents, origin documents, internal control records, copies of declarations | Companies using EPAs on a continuing basis |
| REX System | EU-registered exporters prepare origin declarations | EU-registered Exporter | EU-registered Exporter | REX registration data, origin declarations, invoices, origin support documents | Transactions under the EU-Japan EPA, etc. |
| Certificates of Origin for GSP | Utilization of the Generalized System of Preferences, separate from EPAs and FTAs | Varies by system | Exporter, Importer, Issuing bodies, etc. | Documents related to GSP origin criteria, direct shipment requirements, required certificates | Imports of GSP-eligible countries and products |
Third-Party Certification System
The third-party certification system is a process where issuing organizations, such as Chambers of Commerce, review documents submitted by applicants and issue certificates of origin.
In addition to general certificates of origin, some EPAs use specific certificates of origin issued under the third-party certification system.
Specific certificates of origin are a form of certificate used for preferential purposes and are categorized as certificates issued under the third-party certification system. Therefore, the terms "specific certificate of origin" and "certificate of origin for preferential purposes" are not exactly synonymous; the former is one specific type within the latter category.
Under the third-party certification system, exporters or applicants prepare and submit documents such as invoices, manufacturing certificates, raw material documentation, and origin determination documents.
However, the fact that a third-party organization issues the certificate does not mean that all substantive responsibility for proving origin shifts entirely to the issuing body. While the issuing body verifies the submitted documents, the underlying data supporting the origin determination and the accuracy of the application content generally remain the responsibility of the applicant.
Self-Declaration System
The self-declaration system allows authorized parties under the agreement—such as exporters, producers, or importers—to declare the origin of the cargo.
Under this system, prior certification by a third-party body is not required; however, the declarant bears greater responsibility for compliance. It is important to maintain accurate documentation such as HS codes, product-specific rules of origin, material lists, manufacturing process descriptions, and RVC calculation data.
Who may make a self-declaration varies depending on the agreement and the importing country’s system. Exporters, producers, or importers may be authorized to declare origin, so it is necessary to verify the applicable rules for each system.
Differences Among Exporter’s Self-Declaration, Producer’s Declaration, and Importer’s Self-Declaration
| Method | Declarant | Information Easier to Explain | Common Issues | Practical Measures |
|---|---|---|---|---|
| Exporter’s Self-Declaration | Exporter | Export cargo, invoice, transaction details, supplier information | Exporter may lack sufficient manufacturing process or cost information | Confirm that it is possible to obtain material lists, process sheets, and origin documentation from the producer |
| Producer’s Declaration | Producer | Manufacturing process, raw materials, processing details, cost information | Exporter or importer may not be able to directly access producer documentation | Establish handling of confidential information and predefine the scope of documents to be submitted |
| Importer’s Self-Declaration | Importer | Import declaration, tariff application, customs procedures after import | Importer alone may not be able to explain manufacturing processes or cost data | Ensure prior to import that supporting documents from the exporter or producer are obtained or can be submitted |
Approved Exporter System
The Approved Exporter System allows exporters who meet certain requirements to make origin declarations after being certified by customs authorities. In English, this is referred to as the Approved Exporter.
When utilizing the Approved Exporter System, exporters prepare the prescribed origin declaration statement using their certification number or other identification. This can streamline procedures for companies that continuously use EPAs.
However, obtaining certification requires exporters to establish origin management systems, internal procedures, document retention, and verification mechanisms. Even after certification, exporters must maintain documentation to demonstrate compliance with rules of origin and be prepared for customs verification.
REX System
The REX system, or Registered Exporter System, is an exporter registration scheme on the EU side.
Under the Japan-EU EPA, when an EU exporter issues an origin declaration for cargo exceeding a certain value, including the REX number may be required.
The REX number is key information used to identify the EU exporter. For imports from the EU to Japan, it is necessary to verify the presence of an origin declaration and REX number on the invoice or related documents, the value of the relevant cargo, and the country of origin markings.
Conversely, when a Japanese exporter issues an origin declaration for shipments to the EU, the Japanese corporate number is generally used as the exporter reference number instead of an EU REX number.
Since the identification number to be confirmed differs depending on the export direction, it is important to separately handle the process for shipments from the EU to Japan and those from Japan to the EU.
Certificates of Origin under the GSP
The GSP, or Generalized System of Preferences, is a system that grants preferential tariff treatment for imports from developing countries and others, provided certain conditions are met.
Although separate from EPAs and FTAs, the GSP also requires certification of origin to obtain tariff preferences. Therefore, it is distinguished from general certificates of origin and classified as origin certification for preferential purposes.
When using the GSP, it is essential to confirm the eligible countries, applicable products, origin criteria, direct shipment requirements, and the required certificate of origin. Procedures may differ from those under EPA-specific certificates of origin or self-certification systems.
In practice, it is important to clearly distinguish whether the transaction uses EPA, GSP, or only requires a general certificate of origin.
Certification Methods and Declaration Points to Note by Agreement and System
The methods for certifying origin vary by agreement. Even with the same cargo, the required certification method, declarant, and handling of identification numbers may differ depending on whether a CPTPP, RCEP, Japan-EU EPA, GSP, or general certificate of origin is used.
| Agreement / System | Main Certification Method | Declarant / Issuer | Handling of Numbers and Wording | Practical Points to Note |
|---|---|---|---|---|
| CPTPP | Self-Declaration System | Exporter, producer, importer, etc. | Confirm mandatory information required by the agreement | Compliance with mandatory information is critical rather than use of a unified format |
| Japan-EU EPA | Origin Declaration | Exporter, importer, etc. | EU exporters must verify the REX number; Japanese exporters should verify the corporate number | Verification of numbers differs between EU-to-Japan and Japan-to-EU shipments |
| RCEP | Third-Party Certification, Certified Exporter Declaration, Self-Declaration, etc. | Exporter, producer, importer, issuing authorities, etc. | Certified exporter numbers and similar identifiers may be involved | Confirm which certification methods are available by country and time period |
| GSP | Origin Certification Methods under GSP | Varies depending on the system | Verify the required certificates or declarations under the GSP system | Confirm as a separate preferential tariff system apart from EPA and FTA |
| General Certificate of Origin | General Certificates of Origin from Chambers of Commerce etc. | Applicant, issuing authority | Confirm requirements of the submission destination, letter of credit conditions, and content | Commonly used for non-preferential purposes and should be distinguished from EPA tariff use |
Main Documents
The key documents to review when confirming the types of certificates of origin are as follows.
| Document / Material | Main Purpose | Parties to Confirm With | Points to Note |
|---|---|---|---|
| General Certificate of Origin | Indicates country of origin for non-preferential purposes | Exporter, Chamber of Commerce, Trading Partner | Not necessarily for EPA preferential rates |
| Specific Certificate of Origin | A form of preferential certificate of origin proving the goods qualify for EPA tariff rates | Exporter, Issuing Authority, Importer | Confirm applicable agreement and issuance method |
| Certificate of Origin for GSP | Used to apply the Generalized System of Preferences (GSP) | Exporter, Issuing Authority, Importer | Recognize as a preferential system separate from EPA/FTA |
| Origin Declaration | Self-declaration system to attest origin status | Exporter, Producer, Importer | Confirm mandatory details and declarant entity |
| Invoice or Commercial Document with Origin Declaration Statement | Indicates origin through agreement-mandated origin declaration wording | Exporter, Importer | Check wording, applicable documents, and number handling |
| Documents with REX Number | Confirms declaration by EU-registered exporters | EU Exporter, Importer | Distinguish EU-to-Japan shipments from Japan-to-EU shipments |
| Documents with Authorized Exporter Number | Confirms declaration under the Authorized Exporter system | Authorized Exporter, Importer | Confirm scope of authorization and applicable agreement |
| HS Code Reference Materials | Verify applicable products and Product-Specific Rules of Origin (PSR) | Importer, Exporter, Customs Broker | Misclassification of HS codes may cause errors before proof of certificate type |
| Reference Materials for Product-Specific Rules of Origin | Confirm which origin criteria apply | Importer, Exporter, Customs Broker | Varies by agreement |
| Manufacturing Process Sheets, Material Lists, RVC Calculation Documents | Provide evidence supporting origin claims | Producer, Exporter, Importer | Retain for customs verification |
| B/L, Sea Waybill, Air Waybill | Verify transportation routes and shipment criteria | Freight Forwarder, Shipping Line, Airline, Importer | Additional documentation may be required for transit via third countries |
Scope of Freight Forwarders’ Involvement by Certification Method
Freight forwarders are neither the issuing authorities of certificates of origin nor the parties responsible for determining origin status.
However, depending on the certification method, there are specific situations where freight forwarders can provide support more easily. For general certificates of origin, this includes verifying consistency with shipping documents; for self-declaration systems, confirming the presence of origin declaration statements; for the REX system, verifying numbers on invoices; and for GSP, organizing transport documentation related to direct shipment requirements.
| Certification Method / Situation | Support Freight Forwarders Can Provide | What Freight Forwarders Should Not Decide | Practical Actions |
|---|---|---|---|
| General Certificate of Origin | Verify consistency of information with Invoice, Packing List, B/L, and Sea Waybill | Determine whether the certificate fully meets the importing country’s requirements | Confirm submission requirements, L/C conditions, and certificate details with the shipper and issuing authority |
| Third-Party Certification System | Confirm presence of the certificate, consistency with shipping documents, and timing of issuance | Guarantee the origin determination of the specific certificate of origin | Promptly share any discrepancies between issued certificates and shipping documents |
| Exporter Self-Declaration | Formally confirm whether origin declaration statements appear on invoices or commercial documents | Determine whether the exporter maintains documentation satisfying origin criteria | Verify declaration presence and document consistency; ensure origin documents are checked by the exporter |
| Importer Self-Declaration | Check consistency among transport documents, cargo information, and shipping documents | Determine whether the importer holds origin documentation that can withstand customs scrutiny | Encourage importers and customs brokers to confirm necessary documents |
| REX System | Confirm that EU exports to Japan include REX numbers and origin declaration statements on invoices and related documents | Guarantee the validity of REX numbers and the exporter’s registration status in the EU | Consult importers and exporters if any doubts arise regarding numbers, amounts, or export direction |
| GSP Certification | Organize transport documents relating to direct shipment, third-country transit, transshipment, and through Bills of Lading | Determine whether the goods meet eligible countries, products, and origin criteria under GSP | As a preferential system separate from EPAs and FTAs, encourage verification of certificates and direct shipment requirements |
| Post-Clearance Customs Verification | Support re-acquisition of B/L, Sea Waybill, transit documents, transshipment records, and bonded storage documentation | Judge fulfillment of origin criteria, RVC, CTC, and processing requirements | Organize transport-related documents and supplement origin explanation with shipper-provided materials |
Practical Workflow for Verifying Types of Certificates of Origin
- Confirm the reason why a certificate of origin is required.
- Determine whether a general certificate of origin or a certificate for preferential purposes is needed.
- Identify which system—EPA, FTA, or GSP—is applicable.
- If using EPA or FTA, verify the specific applicable agreement.
- Check the HS code of the relevant cargo.
- Review the Product-Specific Rules of Origin for the item.
- Confirm the available certification methods.
- Decide whether to use third-party certification, exporter’s declaration, producer’s declaration, or importer’s declaration.
- Check if the Authorized Exporter system, REX number, corporate number, or Authorized Exporter number is required.
- Prepare the necessary documents such as certificates of origin, origin declarations, or origin declaration statements.
- Retain supporting documents that substantiate origin.
- Ensure all documentation is ready to explain origin status at import declaration or customs inspection.
Checklist for Decision-Making at Each Stage
The type of certificate of origin should not be confirmed only immediately before submitting documents. It is necessary to organize who checks what and when, from the start of the transaction through customs verification.
| Stage | Parties to Confirm With | Items to Confirm | Actions if Issues Arise |
|---|---|---|---|
| Start of Transaction | Exporter, Importer, Sales Representative | Whether a certificate of origin is required and if it is a general certificate or for preferential purposes | If the purpose is unclear, confirm with the trading partner, L/C terms, and import country requirements |
| Verification of Agreement / System | Exporter, Importer, Customs Broker | Which system is used: EPA, FTA, or GSP; applicable agreements and countries | If unclear, separately confirm the standard tariff rate, EPA tariff rate, and GSP tariff rate |
| Origin Determination | Exporter, Producer, Importer | HS code, PSR, CTC, RVC, processing criteria, cumulation, de minimis rules | If supporting documents are insufficient, hold off on certificate preparation and preferential treatment application |
| Certification Method Confirmation | Exporter, Importer, Customs Broker | Whether to use third-party certification, self-declaration, authorized exporter, REX, or GSP certificate | Ensure the chosen method is permitted under the applicable system |
| Document Preparation | Exporter, Producer, Applicant | Certificate of Origin, Origin Declaration, origin declaration statement, required numbers recorded | Correct any missing wording, numbers, declarant, or applicable documents |
| Transport Arrangement | Exporter, Importer, Freight Forwarder | Shipment criteria, direct shipment, third-country transit, transshipment, transport documents | For third-country transit, confirm whether through B/L or bonded storage documents can be obtained |
| Import Declaration | Importer, Customs Broker | Applicability of preferential tariff rate, validity of certificates, consistency with cargo details | If discrepancies exist, consider replacement, supplementary explanation, or declaring standard tariff rate |
| Customs Post-Verification | Importer, Exporter, Producer | Certification method, origin criteria, supporting documents, materials, processes, costs, shipment criteria | Obtain additional documents as needed and check for impact on past declarations |
Common Issues by Type of Certificate of Origin
| Situation | Common Issues | Points to Confirm | Practical Response |
|---|---|---|---|
| General Certificate of Origin | Misunderstanding that a general certificate of origin obtained due to the importing country’s request is for EPA tariff rates | Whether the purpose is non-preferential or for EPA tariff rates | Confirm the purpose of submission; if for EPA tariff rates, verify the certification method required by the applicable agreement |
| Specific Certificate of Origin | Equating the specific certificate of origin with all preferential certificates of origin | Whether it is a certificate under a third-party certification system or a self-declaration system | Classify the specific certificate of origin as one form of preferential certificate of origin |
| Preferential Certificates of Origin | Certificate or declaration prepared without adequate verification of the applicable agreement or PSR | Applicable agreement, PSR, certification method, shipment criteria | Verify not only the certificate but also the supporting documents for origin |
| GSP Certificates of Origin | Confusing GSP procedures with those for EPA/FTA despite being separate systems | Eligible countries, covered products, direct shipment requirements, required certificates | Delineate EPA, GSP, and standard tariff rates separately |
| Exporter Self-Declaration | Exporter includes origin declaration on the invoice but does not retain supporting documents | Exporter’s retained documents, material lists, process charts, PSR verification materials | Confirm the retention of origin documentation before declaration |
| Importer Self-Declaration | Importer makes self-declaration but cannot obtain documents only held by the producer | Documents obtainable from exporter/producer, ability to respond to customs inquiries | Agree on the scope of document provision before import |
| REX Number Confirmation | Confusion over which REX number to verify between EU export for Japan and Japan export for the EU | Export direction, REX number, corporate identification number, origin declaration statement | Confirm whether the exporter is on the EU or Japanese side separately |
| Misunderstanding Certification Methods | Preparing only a self-declaration when third-party certification is required by the applicable agreement | Certification methods allowed under the specific agreement | Check available methods by agreement and, if necessary, reacquire the certificate |
| Lack of Supporting Documentation | Having an origin declaration but no manufacturing process charts or material documents preserved; unable to respond to customs checks | Certificates, declarations, material lists, process charts, cost data, supplier certificates | Retain supporting documents from the declaration stage anticipating possible post-verification |
Applicable Scenarios
Scenario 1: Mistaking a General Certificate of Origin for Use with EPA Tariff Rates
Sometimes, a business partner requests a certificate of origin, leading to obtaining a general certificate of origin from the Chamber of Commerce with the assumption that it can be used to apply EPA tariff rates.
However, a general certificate of origin is often used for non-preferential purposes such as letter of credit conditions, submission to a trading partner, or import country requirements, and differs from the preferential certificates of origin used to apply EPA tariff rates.
In this case, it is important first to confirm the purpose of submitting the certificate of origin, and if EPA tariff rates are to be applied, verify the certification method permitted under the relevant agreement.
Scenario 2: Confusing a Specific Certificate of Origin with the Self-Declaration System
A specific certificate of origin is one form of preferential certificate of origin, but not all preferential certificates of origin are specific certificates of origin.
Depending on the agreement, origin declarations may be made through self-declaration by the exporter, producer certification, importer self-declaration, or approved exporter systems rather than third-party certification.
Therefore, when using EPA or FTA, it is important not to assume that simply obtaining a specific certificate of origin is sufficient, but to verify the acceptable certification methods under the relevant agreement.
Scenario 3: Confusing the REX Number with the Corporate Number under the Japan-EU EPA
For transactions under the Japan-EU EPA, the identification numbers to be confirmed differ between exports from the EU to Japan and from Japan to the EU.
When an EU exporter makes an origin declaration for shipments to Japan, the inclusion of the REX number becomes relevant for shipments exceeding a certain value. Conversely, when a Japanese exporter prepares an origin declaration for shipments to the EU, the Japanese corporate number is generally used as the exporter’s reference number.
If this distinction is not confirmed before preparing documents, it can lead to misinterpretation of number requirements or deficiencies in the declaration. It is important to separately check the export direction, party making the declaration, shipment value, and the details shown on the invoice.
Scenario 4: Failure to Secure Supporting Documents under Importer Self-Declaration
When using importer self-declaration, it is assumed that the importer declares preferential tariff eligibility themselves and holds documentation necessary to respond to customs verification.
In practice, documents such as raw material information, manufacturing processes, and RVC calculation data are often only held by exporters or producers. If the importer files a self-declaration without obtaining these documents, there is a risk of being unable to substantiate origin in subsequent verification.
Therefore, when using importer self-declaration, it is necessary to confirm before import which documents can be obtained from the exporter or producer, or whether they can be provided upon customs inquiry.
Scenario 5: Confusing GSP with EPA
When importing from developing countries, some consider preferential tariff rates under GSP and treat GSP and EPA as the same system.
GSP is a separate system from EPA and FTA, with differences in eligible countries, covered products, origin criteria, direct shipment requirements, and required certificates of origin. However, since both are systems to certify origin for customs duty preference, they are categorized as preferential certificates of origin rather than general certificates.
In practice, it is important first to check the MFN tariff rate, then clarify whether to apply EPA/FTA, GSP, or declare under the regular tariff rate.
Practical Checklist
When verifying the type of certificate of origin, confirm the following points.
- Whether the reason a certificate of origin is required has been confirmed
- Whether it is a general certificate of origin or a preferential certificate of origin
- Understanding that a specified certificate of origin is a form of preferential certificate of origin
- Which system—EPA, FTA, or GSP—is being utilized
- That GSP is organized as a separate preferential system from EPA and FTA
- Whether the applicable agreement and the exporting and importing countries have been identified
- Whether the HS code for the applicable cargo has been confirmed
- Whether the Product-Specific Rules of Origin have been checked
- Which certification methods are available for use
- Understanding the differences between third-party certification, exporter declarations, producer declarations, and importer declarations
- Whether the necessity of an Authorized Exporter number, REX number, or corporate number has been confirmed
- Whether the wording and required items of the origin declaration statement have been confirmed
- Whether documentation supporting origin determination is being retained
- For shipments routed through a third country, whether shipment criteria have been confirmed
- Ensuring that origin determination is not blindly delegated entirely to the freight forwarder
Summary
There are various types of certificates of origin, including general certificates of origin, certificates for preferential purposes, specific certificates of origin, third-party certificates, exporter self-declarations, producer declarations, importer self-declarations, authorized exporter schemes, the REX system, and certificates related to the GSP.
In practice, it is important first to clarify the purpose for which the certificate of origin is required, and then categorize whether it is a general certificate of origin or a certificate related to preferential systems such as EPAs, FTAs, or the GSP.
Specific certificates of origin are a form of preferential certificates of origin, generally issued under a third-party certification system. Meanwhile, the GSP, though separate from EPAs and FTAs, is a system granting customs preferences and should be distinguished from general certificates of origin as a preferential certificate.
It is also essential to confirm the relevant agreement, the certification method, the declarant, the required identification numbers, and the documentation that must be retained.
A certificate of origin should not be judged by its document title alone. Confirming its purpose, system, issuing authority, declarant, and responsibility structure is critical, along with retaining supporting documentation that can withstand customs scrutiny.
