Key Takeaways
- Four main types of proof of origin are recognised by HMRC: EUR1/EUR-MED movement certificates, origin declarations, importer’s knowledge, and Form A for DCTS imports.
- The £5,400 threshold determines when you need approved exporter status to make an origin declaration — reduced from £5,500 in January 2022.
- HMRC processes digital EUR1 certificates within 48 hours, issued by Chambers of Commerce or the Institute of Chartered Shipbrokers.
- Origin declarations must be presented to HMRC within 2 years of the import date, with validity periods varying by trade agreement.
- Records must be kept for at least 4 years, including proof of origin and all supporting documentation.
What Is a Certificate of Origin?
A certificate of origin (CO) is a document that certifies the country where goods were manufactured or produced. For UK traders, it serves as proof that goods meet the rules of origin under a trade agreement, enabling importers to claim preferential duty rates — often zero or reduced compared to standard Most Favoured Nation (MFN) rates.
Without valid proof of origin, you pay the full UK Global Tariff rate. For many goods, this means the difference between 0% duty and 4-12% duty on the customs value. On a £50,000 shipment of machinery, that’s £0 versus £6,000 in duty.
HMRC recognises four main types of proof of origin, each with specific use cases and issuing procedures. The type you need depends on your destination country, the trade agreement in force, and the value of your consignment.
Preferential vs Non-Preferential Certificates of Origin
The fundamental distinction lies in whether the certificate supports a claim for preferential duty treatment under a trade agreement.
Preferential certificates of origin apply when goods qualify for reduced or zero duty under a UK trade agreement, such as the UK-EU Trade and Cooperation Agreement (TCA), the UK-Australia Free Trade Agreement, or the Developing Countries Trading Scheme (DCTS). These include EUR1 movement certificates, origin declarations, and Form A.
Non-preferential certificates of origin confirm the origin of goods but do not confer any duty preference. They’re used for goods not subject to preferential treatment, often required by certain destination countries for statistical or regulatory purposes. The International Chamber of Commerce (ICC) issues non-preferential COs through local Chambers of Commerce.
For most UK exporters and importers trading under FTAs, preferential certificates are the relevant category. The remainder of this guide focuses on these.
EUR1 and EUR-MED Movement Certificates
EUR1 movement certificates are used for trade with countries that have a preferential trade agreement with the UK where an origin declaration cannot be made. The EUR-MED variant applies specifically to pan-Euro-Mediterranean cumulation zones, covering trade with countries across Europe and the Mediterranean basin.
Who Issues EUR1 Certificates?
EUR1 and EUR-MED certificates are issued by local Chambers of Commerce or the Institute of Chartered Shipbroers. HMRC no longer issues these directly but processes digital versions submitted by exporters.
For digital processing, complete form C1299 (EUR1) or C1300 (EUR-MED) and email it to NCH.Movements.Digital@hmrc.gov.uk. HMRC will issue a plain PDF version back to your company’s email address within 48 hours. Paper forms must be sent to the NCH MICS Team in Salford.
Chambers of Commerce may charge a fee for issuing EUR1 certificates — typically £25-£40 per certificate, though some offer discounted rates for members or high-volume users. Always check with your local Chamber before applying.
When to Use EUR1 vs Origin Declaration
You can make an origin declaration on a commercial invoice for most consignments. However, some trade agreements require an EUR1 certificate regardless of value. Check the specific agreement text or use the UK Trade Tariff tool to verify which proof of origin is accepted for your destination country and commodity code.
Retrospective and Replacement Certificates
EUR1 certificates can be issued retrospectively if not issued at the time of export due to error, oversight, or special circumstances — for example, if a preferential rate becomes available after shipment. The certificate must be marked “Issued Retrospectively” in the remarks field.
If an original EUR1 is lost, destroyed, or stolen, a duplicate can be issued. The exporter must declare in writing that the original is not held. The duplicate certificate is marked “Duplicate” and references the original issue date.
Origin Declarations (Invoice Declarations)
An origin declaration is a statement of origin made on a commercial document — typically an invoice, packing list, or delivery note. It’s the simplest and most common form of proof of origin for UK traders.
The £5,400 Threshold
For consignments with a value not exceeding £5,400, any exporter can make an origin declaration without special status. This threshold was reduced from £5,500 in January 2022 (previously £5,700 before March 2021).
For consignments over £5,400, some trade agreements require the exporter to hold approved exporter status. The UK-EU TCA, for instance, permits origin declarations for any value if the exporter is approved. Other agreements may still require EUR1 certificates for high-value consignments even with approved status — always verify the specific agreement requirements.
How to Make an Origin Declaration
The declaration must include sufficient detail to identify the goods and their origin. The exact wording varies by trade agreement. For the UK-EU TCA, the required text appears in Annex 6 of the agreement:
“The exporter of the products covered by this document declares that, except where otherwise clearly indicated, these products are of UK preferential origin.”
Include this statement on your invoice, packing list, or delivery note. The document must be signed if you’re not an approved exporter with a signature waiver from HMRC.
Validity Periods
Origin declarations must be presented to HMRC within 2 years of the import date. The validity period of the declaration itself varies by trade agreement — typically 12 months from the date of issue, but some agreements specify shorter or longer periods. Check the relevant agreement text or the UK Trade Tariff guidance for your commodity code.
Importer’s Knowledge
Importer’s knowledge is an alternative to an origin declaration available under some trade agreements. Instead of receiving a certificate or declaration from the exporter, the importer claims preference based on their own knowledge of the goods’ origin, supported by documentary evidence.
Required Supporting Evidence
To use importer’s knowledge, you must hold documents covering:
- The commodity code of the imported goods
- A description of the production process
- The origin criterion (whether wholly obtained or sufficiently worked/processed)
- Value or weight data supporting the origin claim
This route is useful when commercial confidentiality prevents the exporter from providing a full origin declaration. However, if you cannot obtain the necessary information from your supplier, you cannot use importer’s knowledge — you must request an origin declaration instead.
Limitations
Not all trade agreements permit importer’s knowledge. The UK-EU TCA allows it, but other agreements may not. Verify the specific agreement terms before relying on this method. Additionally, HMRC may request to see your supporting evidence during a post-clearance audit, so maintain organised records.
Form A for the Developing Countries Trading Scheme
Form A applies exclusively to imports under the Developing Countries Trading Scheme (DCTS), which grants preferential duty rates to goods from eligible developing countries.
Structure and Completion
Form A is a 12-box form with specific completion rules:
- Box 1: Exporter details (name, address, country)
- Box 2: Consignee details
- Box 3: Competent authority reference number
- Box 4: Country of origin and destination country
- Box 5: Transport details (optional)
- Box 6: Customer reference (optional)
- Box 7: Marks and numbers, package count, description of goods
- Box 8: Origin criterion code (“P” for wholly obtained, “W” plus heading for sufficiently processed)
- Box 9: Gross weight or other quantity
- Box 10: Invoice number and date
- Box 11: Competent authority stamp and signature
- Box 12: Exporter signature
Form A no longer requires a stamp and signature from a designated authority in the beneficiary country. It must bear a serial number or invoice reference. If issued after shipment, mark “Issued Retrospectively” in Box 4.
Suppliers’ Declarations
A suppliers’ declaration is not a certificate of origin itself but supporting evidence that materials or components meet origin rules. Exporters use these when their goods incorporate non-originating materials that have undergone sufficient processing in the UK.
Four Types of Suppliers’ Declarations
- Single-consignment preferential: Covers one shipment of preferential goods
- Long-term preferential: Covers multiple shipments over up to 24 months from the start date
- Single-consignment non-preferential: Covers one shipment of non-preferential goods
- Long-term non-preferential: Covers multiple non-preferential shipments over up to 24 months
Long-term declarations for preferential goods can cover a period starting up to 12 months before or 6 months after the issue date. The supplier must immediately notify you if the declaration is no longer valid.
When Suppliers’ Declarations Are Needed
You need suppliers’ declarations when:
- Goods do not originate but have undergone UK processing, and your EU customer needs them to produce a product meeting rules of origin (bilateral cumulation with EU)
- You supply UK customers who need to prove UK origin of materials for their own exports to third countries
Specific wording is required per trade agreement. For the UK-EU TCA, refer to Annex 6 for the exact text.
Approved Exporter Status
Approved exporter status allows you to make origin declarations for consignments of any value without needing an EUR1 certificate (where the trade agreement permits). You apply using form C1454.
Application Requirements
To qualify, you must demonstrate:
- Regular exporting activity
- Goods meet the relevant rules of origin
- Ability to correctly complete origin declarations
Apply online via Government Gateway or by post. You need an EORI number and the commodity codes for goods you export. Processing typically takes 2-4 weeks.
Signature Waiver
Approved exporters can obtain a signature waiver from HMRC, allowing unsigned origin declarations. You must confirm in writing that you accept full responsibility for the declarations made. This streamlines high-volume export operations significantly. You’ll need an EORI number to apply — see our complete guide to EORI numbers if you don’t have one yet.
Record Keeping and Verification
HMRC requires you to keep proof of origin and all supporting documents for at least 4 years from the date of import or export. This includes the certificate of origin or origin declaration, suppliers’ declarations, commercial invoices, packing lists, transport documents, and any correspondence with suppliers regarding origin. For customs warehousing, goods must be released to free circulation within 2 years to claim preferential rates. HMRC may conduct post-clearance audits to verify origin claims through the Customs Declaration Service. Inaccurate declarations can result in duty demands, penalties, and loss of approved exporter status.
Discrepancies and Obvious Errors
HMRC accepts small discrepancies between the origin declaration and submitted import documents if the information clearly agrees with the goods. Obvious mistakes — such as typographical errors that don’t suggest the statements are wrong — are also accepted. However, material errors affecting the origin determination will invalidate the proof.
Key Takeaways
- Four types of proof of origin exist: EUR1/EUR-MED, origin declarations, importer’s knowledge, and Form A for DCTS imports.
- The £5,400 threshold determines when approved exporter status is required for origin declarations.
- HMRC processes digital EUR1 certificates within 48 hours via email submission.
- Origin declarations must be presented within 2 years of import; records must be kept for 4 years.
- Suppliers’ declarations support origin claims when goods incorporate non-originating materials.
- Approved exporter status (form C1454) enables origin declarations for any consignment value.
Frequently Asked Questions
What’s the difference between EUR1 and an origin declaration? EUR1 is a formal movement certificate issued by Chambers of Commerce or HMRC. An origin declaration is a statement you make on your commercial invoice. Origin declarations are simpler and free, but some trade agreements require EUR1 for certain goods or values.
Do I need a certificate of origin for exports to the EU? For most goods under the UK-EU TCA, you can make an origin declaration on your invoice if the goods meet rules of origin. EUR1 certificates are not typically required for EU trade, but verify the specific requirements for your commodity code.
How long does it take to get approved exporter status? HMRC typically processes C1454 applications within 2-4 weeks. Apply well before you need to make high-value origin declarations. You can continue using EUR1 certificates or origin declarations for consignments under £5,400 while waiting.
Can I use importer’s knowledge if my supplier won’t provide origin information? Only if you can obtain the required evidence through other means — production process descriptions, commodity codes, and value data. If commercial confidentiality prevents disclosure, you cannot use importer’s knowledge and must request an origin declaration from your supplier.
What happens if I lose my EUR1 certificate? Contact the issuing authority (Chamber of Commerce or HMRC) to request a duplicate. You must declare in writing that the original is not held. The duplicate will be marked accordingly and reference the original issue date.