UK-EU Trade and Cooperation Agreement Rules of Origin Readiness Assessment
Zero tariff on UK-EU goods trade under the Trade and Cooperation Agreement is not automatic: the goods must meet the rules of origin and the exporter must be able to prove it. This quick assessment shows where your process is thin.
1. Do you know which of your products are traded between the UK and EU and their commodity codes?
2. Have you checked the product-specific rule of origin for each traded product?
3. Can you identify the origin and value of every non-originating input in your bill of materials?
Rules are usually tested by change of tariff heading, a maximum share of non-originating material, or a specific process.
4. Do you hold current supplier origin declarations for inputs?
5. Do you know when the statement on origin can be made by any exporter and when registration is required?
Higher-value consignments need the exporter to hold a registration, such as a REX number for EU exporters or an EORI number for UK exporters.
6. Can your system print the statement on origin on invoices for eligible shipments?
7. Do you apply the tolerance and cumulation provisions where they help?
8. Do you keep origin records ready for a customs verification request?
9. How do you handle preference claims on imports from the other side?
10. Do you review origin status when a BOM, supplier or process changes?
How to use the assessment
Answer the ten questions for your main export or import flow. Each answer is scored and the total converts to a percentage that lands in one of three bands. The aim is not a certificate but a prioritised list. Ask procurement, trade compliance and your ERP owner to answer together, because the answers sit in different teams. Export the result and use the recommendations as the first items on your action list.
The rules behind the questions
Preferential origin depends on the product-specific rules in the agreement. Depending on the product, the test can be a change of tariff classification, a limit on the value share of non-originating materials, or a required manufacturing process. The agreement also has provisions on tolerance for limited non-originating content and on cumulation with materials from the partner. The proof is normally a statement on origin made by the exporter on an invoice or other document. For higher-value consignments the exporter must be registered. Importers claim the preference and must have the knowledge or proof to support it.
- Check the rule for each product, not for the whole company.
- Know where bill of materials data and supplier declarations live.
- Retain records for the period required in the agreement and national law.
Common mistakes
Businesses often assume that goods shipped from the UK or EU are automatically originating, when a product assembled from imported parts may not qualify. Others use a statement on origin without having the evidence, or leave out the registration number when the value requires one. Finally, many forget to re-test origin after a supplier change. Note that a statement can be valid for a period after issue, but a wrong statement may lead to repayment of duty and penalties. Use the BOM and routing data in your ERP as the evidence base, and ask your customs adviser about edge cases.
Frequently Asked Questions
Do UK-EU goods trade duty-free automatically?
No. The agreement offers zero tariffs on goods that meet the rules of origin. If the goods do not qualify, normal duty applies. You need to be able to prove origin if an authority asks.
What is a statement on origin?
It is a declaration by the exporter, made on an invoice or other commercial document, that the goods originate in the UK or EU under the agreement. It uses the wording set out in the agreement and supports the importer's preference claim.
When do I need an EORI or REX registration?
For consignments above a set value threshold in the agreement, the exporter must be registered, with a REX number in the EU or an EORI number in the UK. Below that value any exporter can make the statement. Check the current threshold before relying on it.
How long must origin records be kept?
The agreement requires records to be kept for a minimum period, commonly four years, and national law may require longer. Keep BOMs, supplier declarations and calculations so you can respond to a verification request.
If you want origin calculations driven directly from your ERP bill of materials and supplier data, we can scope that with your trade compliance team.
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