Proof of origin : A supplier’s declaration

With all the changes that go live from January 2022 one which freight forwarders and shippers need to tighten up is proof of origin. As “EU” Origin has crept into the language on a commercial invoice this has followed onto customs declarations. This is and has always been wrong. HMRC guidance on this is clear.

EU Can be used to indicate the origin of goods used on the invoice declaration. However, in order to complete the customs clearance, the importee and import customs agent must enter the specific country of origin ( Country of Manufacture ) of the imported goods


It is not good enough to declare goods as EU Origin.

Chief and CDS

HMRC plan to remove the “EU” Country code from Chief and CDS. This should be complete by 01st Jan 2022. All freight forwarders and importers should be aware of this. There are issues with statistical trade data covering import shipments coming into the UK. “EU” as a country code hides the true origin of goods. From Jan 01st 2022 this may cause delays with electronic customs entries rejected.

For importers who need a better understanding of what should be on an import customs declaration the summary Proof of origin document is here. Your customs import agent should be able to assist. Remember the importer remains responsible for the import declaration. If your broker doesn’t ask you to complete a direct representation form check your customs entry carefully.

An AEO approved freight forwarder should complete under direct representation for UK based companies. Importers who challenge this document are at risk. The assumption by importers that the forwarder does it is incorrect. They act under the importers instruction. If you are not asked to complete a direct representation form are they the correct forwarder for you. Are they protecting your interests?. Do they understand the rules?.

Proof of origin within the EU

Proof of origin has always been at country level. Within the EU this is no different. 27 member states make up the European union, these are all individual countries. It is key that each country declares separately on UK customs entries. The EU itself is a trading block of individual countries. Many countries within the EU protect there separate trading brands. Champagne is a good example of a Protected name. All Champagne comes from France and a particular region of France. Other EU countries cannot produce Champagne. It is a Protected Designation of Origin. By declaring EU on a customs entry the distinction between Champagne and other European wine remains hidden.

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