Le Brexit, quel impact pour votre business? 2/3 - Règles d'origine, Marc Wegnez

CHAMBRE DE COMMERCE ET D'INDUSTRIE DU LUXEMBOURG BELGE
Le Brexit, quel impact pour votre business ? – 10/01/2019
The preferential origin of the goods: impact of Brexit
Orateur: M. WEGNEZ, SPF Economie

THE PREFERENTIAL
ORIGIN OF THE GOODS
IMPACT OF BREXIT
Marc Wegnez
10/01/2019
http://economie.fgov.be

CONTENT
1.INTRODUCTION
2.FREE TRADE AGREEMENTS
3. RULES OF ORIGIN

1. INTRODUCTION

Origin ? What is that ?
ORIGIN OF A GOOD
=
ITS NATIONALITY

The rules of origin give the production conditions to
which a good has to respond in order to get the
nationality of a country.

There are two different kinds of Origin:
1. NON-PREFERENTIAL ORIGIN
is used for all kinds of commercial policy measures, like, for
instance, anti-dumping duties and countervailing duties,
trade embargoes, safeguard and retaliation measures,
quantitative restrictions, but also for some tariff quotas, for
trade statistics, for public tenders, for origin marking,..
In addition, the EU's export refunds in the framework of the
Common Agricultural Policy are often based on non-
preferential origin.
A good has always an origin (for example: EU, name of a
specific MS, name of a third country).
2. PREFERENTIAL ORIGIN
Preferential origin is conferred on goods from particular
countries, which have fulfilled certain criteria allowing
preferential rates of duty to be claimed.

What’s the use of it ?
PREFERENTIAL ORIGIN:
The international trade is influenced by the system of import duties.
When signing Free Trade Agreements (FTA), partner countries or
territories may grant to each others reductions on those duties
(tariff preferences).
Goods exported within the context of a FTA may benefit from those
preferences if they are originating in a signatory party of the
agreement.
Therefore, a good does not always have a preferential origin.
When it has one, this origin is EU or a partner country.

Importation in the EU: soya sauce
DUTIES

Information also available on tarweb/tarbel DUTIES

http://madb.europa.eu/madb/datasetPreviewFormATpubli.htm?datacat_id=AT&from=publi
Importation in South Korea: tomato ketchup DUTIES

If the value of the sending
= 100.000 Euros
SOYA (import in EU)
Savings = 7,7% third country duties
= 7700 Euros
KETCHUP (import in South Korea)
Savings = 8 % third country duties
= 8000 Euros
DUTIES

2. FREE TRADE AGREEMENTS

MAGHREB
Algeria
Tunisia
Morocco
Examples of FTA’s
MASHRIQ
(MACHREK)
Egypt
Syria
Lebanon
Jordan
Israel
The West Bank
Gaza Strip /
Palestine
EU
(28)

Honduras, Nicaragua
Panama, El Salvador Costa
Rica, Guatemala
Examples of FTA’s
Peru, Colombia
Ecuador
CENTRAL AMERICA
ANDEAN COMMUNITY
Canada (CETA)
Mexico
Chili
EU
(28)

Examples of FTA
Ukraine
Moldova
Georgia
South Korea
South Africa
EU
(28)

EPA’s
EPAs - Economic Partnership Agreements
for ACP countries
CARIFORUM : Antigua and Barbuda, Bahamas,
Barbados, Belize, Dominica, Dominican Republic,
Grenada, Guyana, Jamaica, St Kitts & Nevis, St Lucia,
St Vincent & Grenadines, Suriname, Trinidad and
Tobago
PACIFIC : Papua New Guinea, Fiji
ESA (East and South Africa ) : Seychelles, Zimbabwe,
Mauritius, Madagascar
SADC (Southern African Development Community):
South Africa, Botswana, Lesotho, Namibia, Swaziland,
Mozambique
CENTRAL AFRICA : Cameroon
EU
(28)

Generalized System of Preferences (GSP)
75 countries
Caribbean : Aruba, Bermuda, British Virgin Islands,
Netherland Antilles, Anguilla, Cayman islands, Turks
& Caicos islands, Montserrat
Pacific: New Caledonia, Polynesie française, Wallis
& Futuna, Pitcairn
North Atlantic : St Pierre & Miquelon, Greenland
South Atlantic : Falklands islands, South Georgian
and South Sandwich Islands St Helena, Ascension
and Tristan da Cunha
Kosovo (Western Balkan)
Autonomous preferential arrangements
OVERSEAS COUNTRIES & TERRITORIES
(OCT)
EU
(28)
Unilateral

FTA bilateral
(Agricultural Products + Coal & Steel)
contains the PEM protocol
Customs Union
(Industrial Products & Processed
Agricultural Products)
No customs duties
Remark : Not related to origin, but it makes possible to use the
paneuromed cumulation (contains a provision that allows
to establish a link with the PEM protocol)
EU
(28)
Turkey
TURKEY

INDUSTRIAL PRODUCTS & PROCESSED AGRICULTURAL
PRODUCTS
Turkey EU
(28)
Customs Union
Goods in free circulation
= 1. wholly obtained
or
2. entirely or partially manufactured from components originating in third countries
and on which the duties have been paid
or
3. goods originating in third countries and on which the duties have been paid

EU
CUSTOMS UNION
Example 1 wholly obtained
FREE
CIRCULATIONA.T.R.
All components used are
originating in Turkey
BELGIUM
TURKEY
Turkish cakes

EU
FREE CIRCULATION = Duties
have been paid for the non-
originating sugar at the
entrance
A.T.R.
CUSTOMSUNION
MALAWI
Cane Sugar
Chap. 17
Hop (Houblon)
USA
Fruit beer
Example 2 entirely or partially manufactured from non-originating
components
PREFERENCES GSP
Tarif: 0% Everything but arms
BELGIUM
Water, Malt,
Yeast (Levure)
Fruit Extracts
TURKEY

No working or processing, no ‘EU’ origin
A.T.R.
CUSTOMSUNION
Noddles
Example 3 Goods originating in a third counrty
JAPAN
Noddles
FREE CIRCULATION = Duties
have been paid at the
entrance
BELGIUM
EU
TURKEY

PEM CUMULATION ZONE
PAN-EURO-MEDITERRANEAN AGREEMENT
EU
(28)
Norway
Iceland
Liechtenstein
Switzerland
Turkey
Faroe Islands
MAGHREB
Algeria
Tunisia
Morocco
MASHRIQ
Egypt
Syria
Lebanon
Jordan
Israel
The West Bank
Gaza Strip /
Palestine
Western Balkans (6)
EEA
EFTA
OLDPAN-EUROPEANCOUNTRIES
GeorgiaRep of Moldova Ukraine

Preferential rules of origin in the EU in 2018
Mediterranean
countries
Other countries
& territories
Autonomous
preferential
arrangements
+UE=European
EconomicArea(EEA)
Andorra
Chile
EPAs for ACP
countries
Mexico
South Africa
GSP-75 countries
OCT-
20 Overseas countries
and territories
Western Balkans:
Kosovo* until 31/12/2020
Turkey
Pan-euro-mediterranean
cumulation zone
BIH
Serbia
South Korea
* This designation is without prejudice to positions on status, and is in line with UNSC 1244 and the ICJ Opinion on the Kosovo declaration
of independence.
** Ukraine remains in the GSP until 31/12/2018. Ukraine has concluded a FTA only with the EU. The PEM cumul is therefore not yet
possible.
Peru and Colombia
Central America
AL
Montenegro
Former Yugoslav
Republic of
Macedonia
Western Balkans
Iceland
Norway
Switzerland
Pan-european
countries
Faroe Islands
Liechtenstein
EuropeanFreeTradeAssociation
(EFTA)
Pan-european
cumulation
Moldova
Georgia
Ukraine
Algeria
Lebanon
Jordan
Israel
WBGS
Tunisia
Morocco
Egypt
Syria
Ceuta & Mellila
EU (28)
Kosovo*
Canada

3. RULES OF ORIGIN

See the Annex which gives the specific
rule of origin for each product
IDENTIFICATION OF LEGAL BASIS (origin protocol, annex, arrangement,..)
In the specific articles : definitions
1.Wholly obtained 2.Sufficiently working
or processing
4.Cumulation3.Insufficient working
or processing
1. CHANGE OF TARIFF HEADING (CTH)
2. TRANSFORMATION CRITERION
3. VALUE CRITERION
4. CTH + VALUE CRITERION
ORIGIN DETERMINATION : RULES

BASIC PRINCIPLE:
A product keeps its origin unchanged
until this product is sufficiently worked
or processed.

•The origin protocols may differ from one agreement to another.
Consequence :
Goods may have a preferential origin within the framework of a
specific agreement while having no preferential origin in the
framework of another agreement.
•The following elements have to be taken into account :
- origin cumulation
- tolerance rule
- prohibition of drawback
- territorial requirements and non-manipulation
Remarks

 EASY CASES :
Only one country is concerned in the production of the good
(for the components as well as the transformations/workings)
= wholly obtained product
 LESS EASY CASES :
Non-originating components or raw materials are used during the
production of the good.
OR
Another country performs some transformation(s) or working(s) on
the good.

1. WHOLLY OBTAINED PRODUCTS
- Goods naturally occurring
- Live animals born and raised in a given
country
- Plants harvested in a given country
- Minerals extracted or taken in a single country
- Etc.
List contained in the “rules of origin”-part of
an agreement

1. WHOLLY OBTAINED PRODUCTS (EXAMPLE 1)
Comprehensive Economic and Trade Agreement
(CETA) between EU & Canada
Article 4 - Wholly obtained products
1. The following products shall be considered as wholly
obtained in a Party :
(c) live animals born and raised there;
Hampshire in southern England (EU)
Preferential origin EU when exported to Canada ? Yes
Gerpinnes, Belgium (EU)
New Forest Poney
BEFORE THE BREXIT
FREE CIRCULATION
No customs duties

Comprehensive Economic and Trade Agreement
(CETA) between EU & Canada
Article 4 - Wholly obtained products
1. The following products shall be considered as wholly
obtained in a Party :
(c) live animals born and raised there;
UK (= third country)
Preferential origin EU when exported to Canada ? No
Belgium (EU)
AFTER THE BREXIT
? No-deal: duties
? FTA: duties will be reduced
? Customs union : no duties

Wheat flour
HS: 1101
ITALY
Tomato sauce
HS: 2103
ITALY
Preferential
treatment
when exported to
Switzerland ?
Lasagne produced in BELGIUM
HS : 1902
Meat= more that 20% of weight
Milk
Chap. 04
BELGIUM
Olive oil
HS: 1509
BELGIUM
Mushrooms
(agaricus)
HS: 0709.51
FRANCE
Onions
HS: 0703
SPAIN
Eggs
HS: 0407
BELGIUM
Beef
HS: 0201
UK
BEFORE THE BREXIT

(PEM Protocol)
1902 Pasta, whether or not cooked or stuffed (with meat or other substances)
or otherwise prepared, such as spaghetti, macaroni, noodles, lasagne, gnocchi,
ravioli, cannelloni; couscous, whether or not prepared:
– Containing more than 20 % by weight of meat, meat offal, fish, crustaceans
or molluscs
Rule of origin
Manufacture in which:
— all the cereals and their derivatives (except durum wheat and its
derivatives) used are wholly obtained, and
— all the materials of Chapters 2 and 3 used are wholly obtained

Wheat flour
HS: 1101
ITALY OK
Tomato sauce
HS: 2103
ITALY
HS : 1902
Milk
Chap. 04
BELGIUM
Olive oil
HS: 1509
BELGIUM
Mushrooms
(agaricus)
HS: 0709.51
FRANCE
Onions
HS: 0703
SPAIN
Eggs
HS: 0407
BELGIUM
Beef
HS: 0201
UK OK
BEFORE THE BREXIT
The conditions set by the rule are respected
=> Preferential origin EU when exported to Switzerland !

Wheat flour
HS: 1101
ITALY OK
Tomato sauce
HS: 2103
ITALY
Preferential
treatment
when exported to
Switzerland ? NO
HS : 1902
Milk
Chap. 04
BELGIUM
Olive oil
HS: 1509
BELGIUM
Mushrooms
(agaricus)
HS: 0709.51
FRANCE
Onions
HS: 0703
SPAIN
Eggs
HS: 0407
BELGIUM
Beef
HS: 0201
UK
AFTER THE BREXIT
The beef is non-originating because
UK has become a third country !
(=> import duties to pay)

2. SUFFICIENTLY WORKING OR PROCESSING
2.1 A criterion of a change in tariff classification
A good is considered substantially transformed when the
good is classified in a heading or subheading (depending
on the exact rule) different from all non-originating materials
used
chapter level (2-digit)
heading level (4-digit) – most commonly applied
sub-heading level (6-digit)
item level (8 or 10-digit)

Door locks of heading 83.01
(PEM protocol)
As the list of products does not contain products of heading 83.01 the list
rule for « ex Chapter 83 - Miscellaneous articles of base metal; except for :
.. » covers the origin requirements for heading 83.01
The rule is :
“ Manufacture from materials of any heading,
except that of the product “
2.1 CHANGE OF TARIFF HEADING CRITERION (EXAMPLE1)

Rivets (HS 73.18)
€ 0.10
Nuts (HS 73.18)
€ 0.13
Steel bar (HS 72.15)
€ 0.30
Lock mechanism (HS 83.01)
€ 1.50 China
Steel plate (HS 72.19)
€ 0.20
Screws (HS 73.18)
€ 0.11
Varnish (HS 32.08)
€ 0.02

The door locks are sold at an ex-works price of € 20.-
The final product is not originating because of the non-
originating lock mechanism that occupies the same
heading (83.01)
but
Art 5 - Sufficiently worked or processed products :
2. Notwithstanding paragraph 1, non-originating
materials which, according to the conditions set out
in the list in Annex II, should not be used in the
manufacture of a product may nevertheless be
used, provided that :
(a) their total value does not exceed 10 % of the ex-works price of the product;
(b) any of the percentages given in the list for the maximum value of non-
originating materials are not exceeded by virtue of this paragraph.

Rivets (HS 73.18)
€ 0.10
€ 0.30
Lock mechanism (HS 83.01)
Art 5. Sufficient working : Tolerance Max 10% Ex Works
€ 1.50 is only 7,5% of the ex-works price of the lock (€ 20.-)
€ 0.20
Screws (HS 73.18)
€ 0.11
Varnish (HS 32.08)
€ 0.02
Nuts (HS 73.18)
€ 0.13
Preferential
origin

Rivets (HS 73.18)
€ 0.10
Nuts (HS 73.18)
€ 0.13
€ 0.30
Lock mechanism – origin UK (HS 83.01)
€ 8 (UK = third country)
€ 0.20
Screws (HS 73.18)
€ 0.11
Varnish (HS 32.08)
€ 0.02
AFTER THE BREXIT
Remark : 2,7% duties to pay when imported in the EU

Rivets (HS 73.18)
€ 0.10
€ 0.30
Lock mechanism – origin UK (HS 83.01)
Art 5. Sufficient working : Tolerance Max 10% Ex Works
€ 8 >30% of the ex-works price of the lock (€ 26,50.-)
€ 0.20
Screws (HS 73.18)
€ 0.11
Varnish (HS 32.08)
€ 0.02
Nuts (HS 73.18)
€ 0.13
preferential
origin? NO !

Trituration - Extraction
Harvest
UK
USA
HS: 1507.10.90
Crude soya-bean oil, whether
or not degummed (excl. for
technical or industrial uses)
HS: 12019000
Soya beans, whether or not
broken (excl. seed for sowing)
HS: 1507
Soya-bean oil and its fractions,
whether or not refined (excl.
for technical or industrial uses,
chemically modified, and crude)
Refining
BE
EU
EXAMPLE 2 CASE : SOYA OIL
EU preferential origin?
BEFORE THE BREXIT
ISRAEL

(PEM Protocol)
1507 to 1515 Vegetable oils and their fractions:
- Soya, ground nut, palm, copra, palm kernel, babassu, tung and
oiticica oil, myrtle wax and Japan wax, fractions of jojoba oil
and oils for technical or industrial uses other than the
manufacture of foodstuffs for human consumption
- Solid fractions, except for that of jojoba oil
- Other
Rule of origin :
“Manufacture from materials of any heading, except that of the
product”

UK (EU)
HS: 1507.10.90
HS: 2304
Oilcake (tourteau) and other solid
residues, whether or not ground
or in the form of pellets, resulting
from the extraction of soya-bean
oil
HS: 12019000
Conclusion for soya oil :
- non-originating soya beans may be used;
- non-originating crude soyal oil may not be
used because the remaining operation
(refining) causes no CTH;
- the operation of trituration/extraction has
to be done in the EU !
=>Preferential origin when exported to a
PEM country.
HS: 1507
Refining
USA
(PEM Protocol)
Ex Chap23: Residues and waste from the
food industries; prepared animal fodder;
Rule of origin :
“Manufacture from materials of any
heading, except that of the product”
Conclusion for the oilcake :
=>Preferential origin when exported
to a PEM country.

Harvest
UK = third country
USA
HS: 1507.10.90
HS: 12019000
HS: 1507
Refining
BE
EU
EU preferential origin?
No because refining is
insufficient !
AFTER THE BREXIT
ISRAEL

EU
2. SUFFICIENTLY WORKING OR PROCESSING
2.2 TRANSFORMATION CRITERION
not used for (processed) agricultural products
EU
Cotton fabrics
TURKEY
BELGIUM
Weaving
ORIGIN ?
Spinning
UK
UZBEKISTAN
Cotton fibres
BEFORE THE BREXIT
Cotton yarns

52.08 to 52.12 (notably) manufacture from
natural fibres
The fabrics are manufactured from cotton fibres
Cotton fibres = natural fibres
->The transformation criterion (=double transformation rule) is satisfied
CONCLUSION : the fabrics are originating in the EU
COTTON FABRICS WHOLLY OBTAINED ? NO
SUFFICIENT TRANSFORMATION OR WORKING ?
Criterion for the product (in the pan-euro-med protocol):
Remark:
->Industrial products (Customs Union)
->Useful to know their origin if re-exported later

EU
2.2 TRANSFORMATION CRITERION
not used for (processed) agricultural products
EU
Cotton fabrics
TURKEY
BELGIUM
Weaving
ORIGIN ?
Spinning
UK
UZBEKISTAN
Cotton fibres
AFTER THE BREXIT
Cotton yarns

52.08 to 52.12 (notably) manufacture from
natural fibres
The fabrics are manufactured from cotton yarns.
->The transformation criterion is not satisfied
(we have only a single transformation)
CONCLUSION : the fabrics are not originating in the EU
=>It is impossible to re-export the fabrics from Turkey to a PEM partner
with a preferential treatment !
COTTON FABRICS WHOLLY OBTAINED ? NO
SUFFICIENT TRANSFORMATION OR WORKING ?
Criterion for the product (in the pan-euro-med protocol):
Remark:
->Industrial products (Customs Union)
->Useful to know their origin if re-exported later

2.3 VALUE CRITERION
PREFERENTIAL ORIGIN: UE
Rule for 0403 (protocol FTA UE-MEXICO) :
- all the materials of Chapter 4 used must be wholly
obtained,
- any fruit juice (expect those of pineapple, lime or
grapefruit) of heading No 2009 used must already be
originating,
- the value of any materials of Chapter 17 used does not
exceed 30 % of the ex-works price of the product
UK
Milk
Chap. 4
SPAIN
Pineapple
HS: 0804.30
BELGIUM
Sugar,
powder milk,
powder vanilla
EU
BEFORE THE BREXIT
SWITZERLAND
Milk Chap. 4
Cane sugar
Chap.17 Value ≤ 30%
BRAZIL
MEXICO
Yoghurt
HS : 04031012000

(protocol FTA UE-MEXICO)
Art 5 :Sufficiently worked or processed products
3. Notwithstanding paragraph 1, non-originating materials which,
according to the conditions set out in the list, should not be used
in the manufacture of a product may nevertheless be used,
provided that:
(a) their total value does not exceed 10 % of the ex-works price
of the product;
(b) any of the percentages given in the list for the maximum
value of non-originating materials are not exceeded through the
application of this paragraph.

2.3 VALUE CRITERION
obtained,
originating,
UK
Milk
Chap. 4
SPAIN
Pineapple
HS: 0804.30
BELGIUM
Sugar,
powder milk,
powder vanilla
EU
BEFORE THE BREXIT
SWITZERLAND
Cane sugar
BRAZIL
MEXICO
Yoghurt
HS : 04031012000
Art 5. Sufficient working:
Tolerance Max 10%
Ex Works Price yoghurt
Milk Chap. 4

2.3 VALUE CRITERION
obtained,
originating,
UK
SPAIN
Pineapple
HS: 0804.30
BELGIUM
Sugar,
powder milk,
powder vanilla
EU
AFTER THE BREXIT
SWITZERLAND
Cane sugar
BRAZIL
MEXICOYoghurt
HS : 04031012000
Art 5. Sufficient working: Tolerance Max
10% Ex Works Price yoghurt
Milk Chap. 4Milk Chap. 4

3. INSUFFICIENT WORKING OR PROCESSING
(PEM Regional Convention, Appendix 1, article 6)
Some operations shall be considered as insufficient working or
processing to confer the status of originating products, whether or
not the requirements (list rule) are satisfied.
A few examples:
-preserving operations to ensure that the products remain in good
condition during transport and storage,
-breaking-up and assembly of packages,
-washing, cleaning; removal of dust, oxide, oil, paint or other
coverings;
-sharpening, simple grinding or simple cutting;
-sifting, screening, sorting, classifying, grading, matching;
- ….

4. CUMULATION OF ORIGIN
Legal basis:
See the origin protocol of the different FTAs
Aim?
To increase trade exchanges between partners
How?
Facilitates exchanges of materials
The benefit?
It is easier to obtain the preferential origin.
In the cumulation context, the sufficient working is not needed
in order to obtain the preferential origin.
operation > minimal working or processing
You need to do something more elaborated than the
insufficient working or processing

REMARK :
The acquisition of a preferential origin through the
application of cumulation rules is always linked and
limited to some FTA(s) and its/their contracting parties.

EXAMPLE: BILATERAL CUMULATION
UK
EU
BEFORE THE BREXIT
Originating
synthetic yarns
Originating
synthetic fabrics
1
2
cumul with EU
(UK) materials
TUNISIAProof of origin
Proof of origin
BELGIUM

UK
Is not covered anymore
by the EU-Tunisia FTA
Is not a PEM partner
anymore !
AFTER THE BREXIT
Synthetic yarns
Synthetic fabrics
1
2
cumul with EU
(UK) materials
TUNISIA
If no FTA, no preferential
treatment
No preferential treatment
EXAMPLE: BILATERAL CUMULATION

Partner countriesCountry A
Originating
materials
Several countries are concerned
Country B
Country C
working
ORIGIN ?
DIAGONAL CUMULATION
Proof of origin
Originating
materials
Proof of origin

CASE 1 : WORKING IN COUNTRY C > MINIMAL
ORIGIN : COUNTRY C
CASE 2 : WORKING = SIMPLY MINIMAL
COUNTRY OF ORIGIN = C
only if the added value in country C > value of the materials
(originating in countries A and B) used.
COUNTRY OF ORIGIN = A OR B :
the country which accounts for the highest share of the customs
value of the materials used …
IF IT IS NOT THE CASE:
A
B
C
Working

TUNISIA
EU
ALGERIA
ITALY MOROCCO
DIAGONAL CUMULATION (CONTEXT PEM)
Olive oil
Originating
Crude olive oil
Chap.15
Originating
Crude olive oil
Chap.15
Refining = more than
minimal operations
listed in art. 6
A B
C
PREFERENTIAL ORIGIN: TUNISIA
CASE 1 : WORKING IN COUNTRY C > MINIMAL
Proof of origin
Proof of origin

EU
ALGERIA
BELGIUM TUNISIA
Olive oil
Originating
Aromatic
herbs
Originating
olive oil
A B
C
PREFERENTIAL ORIGIN ?
PEM Protocol
Art.6 Insufficient working or processing
(k) simple placing in bottles
simple bottling =
minimal operation
MOROCCO
EUR.MED
EUR.MED
Remark:
PEM cumulation
=>proof of origin : EUR.MED

EU
ALGERIA
BELGIUM TUNISIA
Originating
aromatic herbs
1,75 euro / 30gr
=> 30gr / l
Originating
olive oil
4,13 euros / l
A B
C
PREFERENTIAL ORIGIN TUNISIA
where the highest Value Added
MOROCCO
Bottling + stickers
+ leaflet
Value added = 3,11 euros
Olive oil (bottle 1 litre)
8,99 euros ex works price

EUR-MED
DIAGONAL CUMULATION – EXAMPLE 2
UK
BELGIUM
EU
BEFORE THE BREXIT
Originating
synthetic yarns
Synthetic fabrics
1
2
blouses
3
cumul with EU
(UK) materials
Synthetic fabrics
4
TUNISIA
cumul with
Tunisian
materials
JORDAN
EUR-MED
Supplier declaration
Preferential treatment

DIAGONAL CUMULATION : EXAMPLE 2
UK
BELGIUM
EU
AFTER THE BREXIT
Non originating
synthetic yarns
Synthetic fabrics
1
2
blouses
3
cumul with EU
(UK) materials
4
TUNISIA
JORDAN
No preferential treatment
Only one transformation while
a « double transformation rule ».
=> No preferential treatment
Duties to pay
Non originating synthetic fabrics
Duties to pay
Weaving

FULL CUMULATION
UK
BELGIUM
EU
AFTER THE BREXIT
1
blouses 3
TUNISIA
MOROCCO
Duties to pay
preferential treatment
Non originating synthetic yarns
Weaving
Synthetic fabrics
2
Making garment

final
product
Remark: 2 industrial sites of the same company
- one in Iceland & one in Norway
first ‘complex’
mix of paint
SH 3209
FULL CUMULATION
INDIA CHINA CANADA
Pigments
HS: 3212
Solvents
HS: 3817
Paint
HS: 3209
ICELAND NORWAY
BELGIUM
EU
PREFERENTIAL
ORIGIN ?

final
Product
Invoice total
€310
first ‘complex’
mix of paint
SH 3209
Costs €180
FULL CUMULATION
INDIA CHINA CANADA
Pigments
HS: 3212
€50
Solvents
HS: 3817
€20
Paint
HS: 3209
€50
ICELAND NORWAY BELGIUM
EU
Supplier
declaration
PREFERENTIAL
ORIGIN EEA
European Economic Area (EEA)
Origin rule in the EEA :
EUR1
Full cumulation : all non-originating materials
represent less than 40% of the EX-W price

This speaker is
the origin of my headache !
…deep sighs…
(the audience)
I should think about
his presentation …
… so that my profit
marge is likely to grow !
Le penseur
(Rodin)
Thank you for your attention !!!

Le penseur
(Rodin)
Contacts :
Federal Public Service Economy
DE PRINS Jens
Jens.deprins@economie.fgov.be
WEGNEZ Marc
marc.wegnez@economie.fgov.be
Federal Public Service Finances (Customs)
DEPREZ Ivo
ivo.deprez@minfin.fed.be
VAN KERKHOVEN Sam
sam1.vankerkhoven@minfin.fed.be

Le Brexit, quel impact pour votre business? 2/3 - Règles d'origine, Marc Wegnez

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