It’s July and summer is definitely here! Other than hot weather, this month started with important news concerning certification of origin. As of 1st July 2018, some GSP beneficiary countries and territories need to fully apply the Registered Exporter (REX) System, as confirmed by the Commission’s note. Hence, documents used as proof of preferential origin for goods imported from these GSP countries have changed. This will have important consequences for customs managers, who will need to take the necessary steps to ensure that suppliers in GSP countries use the correct origin certification so that they can still benefit from the preferences upon the importation of goods.
In practice, FORM A certificates issued after 1st July 2018 are no longer accepted as proofs of GSP preferential origin from the concerned countries. Likewise, invoice declarations made out after 1st July 2018 are also no longer accepted as proof of GSP preferential origin from certain GSP countries, in the case of consignments whose value does not exceed EUR 6000. Instead, to be able to continue to benefit from GSP preferences, exporters in these GSP countries need to have a valid REX registration and issue statements of origin on the invoice or any commercial document. For consignments whose value is up to EUR 6000, no registration in REX is required, and exporters from GSP countries must make a statement of origin to certify the preferential origin of goods.
But that is not all. For the origin certification to be accepted in the EU, each GSP beneficiary country has to satisfy two prerequisites:
- submit to the Commission an Undertaking providing for administrative cooperation in the framework of the REX system (art. 70 UCC IA);
- communicate to the Commission the contact details of the competent authorities dealing with the registration of the exporters and administrative cooperation (art. 72 UCC IA).
Until these two prerequisites are fulfilled, GSP countries cannot benefit from trade preferences. Check below among the GSP countries that must fully apply REX as from 1st July 2018, which ones have fulfilled the prerequisites and which have not:
Source: DG Taxud website, status of GSP countries as of 11 July 2018.
Customs managers that import goods from GSP countries where REX is already applicable should check that their suppliers are REX registered and issuing the correct statement of origin. As for imports from GSP countries that have not yet fulfilled the requirements, preferences simply cannot be claimed. Customs managers can calculate the financial impact of having to pay MFN duties and, assess whether to change suppliers.