CDS Declarations
📞 +44 1480 470 114
tariff compliance

UK-EU Trade: Rules of Origin and How They Affect Your Import Duty

By CDS Declarations Team6 min read

The UK-EU Trade and Cooperation Agreement (TCA)

Since 1 January 2021, trade between the UK and the European Union has been governed by the UK-EU Trade and Cooperation Agreement (TCA). The TCA provides for zero tariffs on qualifying goods traded between the UK and EU — but this is not automatic. To benefit from preferential (zero) duty rates, goods must meet the rules of origin set out in the agreement.

What Are Rules of Origin?

Rules of origin determine the "economic nationality" of a product — i.e. where it was made or sufficiently processed. For trade preference purposes, a product must originate in the UK or EU to qualify for the preferential tariff rate under the TCA.

Simply shipping goods through the UK or EU is not sufficient. The goods must be substantially produced or transformed there.

The Two Main Rules of Origin Tests

1. Wholly Obtained Products that are entirely grown, raised, harvested, or extracted in the UK or EU. This applies primarily to agricultural, fishery, and mineral products.

2. Sufficiently Processed For manufactured goods, the product must undergo sufficient processing in the UK or EU. This is typically defined by one of the following criteria:

  • Change of Tariff Heading (CTH): The processing must result in a change in the product's tariff classification at the 4-digit heading level.
  • Specific Process Rules: Certain products require particular manufacturing steps.
  • Value-Added Rules: The non-originating content must not exceed a specified percentage of the ex-works price.

Evidence of Origin

To claim preference under the TCA, you must have evidence that your goods originate in the UK or EU. This can be:

  • Statement on Origin: A declaration on the commercial invoice made by an approved exporter or any exporter for consignments of €6,000 or less.
  • Importer's Knowledge: The importer can claim preference based on their own knowledge that the goods originate in the exporting country.

Common Pitfalls

Goods assembled in the UK from non-UK/EU components: Assembly alone may not constitute sufficient processing. The components' origin must be considered.

Rules of origin for complex supply chains: If your product uses components from multiple countries, establishing origin can be complex. Incorrect claims can result in the preferential duty being denied and back-duties being charged.

Bilateral cumulation: Under the TCA, UK and EU materials and processing can be combined to meet origin requirements. This is an important benefit for manufacturers with cross-channel supply chains.

Practical Advice

Before claiming TCA preference, verify:

  1. The commodity code of your goods
  2. The specific rule of origin for that commodity code in the TCA
  3. That you have adequate evidence of origin
  4. That your supplier can provide a statement on origin if required

How We Can Help

Origin determination can be complex, particularly for manufactured goods with international supply chains. Our compliance consultants can assess your product's origin status and ensure your declarations correctly claim (or avoid incorrectly claiming) preferential tariff rates. Contact us for guidance.