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Writer's pictureArne Mielken

EU-UK Trade and Cooperation Agreement: Suppliers' Declarations - How to complete correctly

Exporters may need to obtain Suppliers' Declarations to prove the origin of the products they export. Make sure you don't get it wrong, says Arne Mielken of Customs Manager Ltd.


When you need a suppliers’ declaration

The supplier declaration can be provided at any time, even after the goods have been delivered.


If you supply goods

If you’re the supplier, you may be asked to provide a suppliers’ declaration to your customer to prove either:

  • that the goods meet the rules of origin

  • that you’ve processed or added value to the goods (goods not having preferential origin status)

If you export goods

If you’re exporting goods you may need to need to get a suppliers’ declaration to prove the origin of materials used in the manufacturing process, or for finished products that you buy and re-export.


This includes when:

  • any materials do not change tariff heading

  • the value of materials is over the specified limit - you’ll need a suppliers’ declaration to cover the value of materials in excess of the limit

  • you manufacture using materials at a later stage of production than that specified

  • you only carry out minimal processes

  • you buy and export goods in the same state

When you do not need a suppliers’ declaration

If you’re a manufacturer, you will not need a suppliers’ declaration if:

  • all non-originating materials change tariff heading as set out in the origin rule

  • the value of any non-originating materials is within the limit of the percentage rule

  • the manufacture from materials happens at or before the stage of production set out in the origin rule

Types of suppliers’ declarations

Each consignment of goods can have a separate suppliers’ declaration, or a long-term supplier declaration can be used.


Long-term suppliers’ declarations

If your supplier regularly supplies you with consignments of goods, and all those goods are expected to have the same originating status, they may provide a single declaration covering multiple consignments of those goods (a long-term supplier declaration).

A long-term supplier declaration shall be made out for consignments dispatched during a set period of time and must state the:

  • the date on which the declaration is made out (date of issue)

  • date of commencement of the period (start date), which may not be more than 12 months before or more than 6 months after the date of issue

  • end of the period date (end-date), which may not be more than 24 months after the start date

Your supplier must inform you immediately where the long-term supplier declaration is not valid for some or all consignments of goods supplied and to be supplied.


Where to include suppliers’ declarations

You can make declarations on the invoices for the goods supplied, or on any other commercial document that fully identifies the goods. You should make long-term declarations on company headed notepaper.


What to include on a suppliers’ declaration

If you give an inaccurate declaration:

  • you may get a penalty

  • the overseas customer may have to pay the full rate of Customs Duty

Any declarations produced electronically do not need to be signed, so long as a responsible official in the supplying company is clearly identified.


All other suppliers’ declarations must have a physical signature put on the document.

You should use the wording below depending on if it’s a:

  • suppliers’ declarations for products having preferential origin status

  • long-term suppliers’ declarations for products having preferential origin status

  • suppliers’ declarations for goods not having preferential origin status

  • long term suppliers’ declarations for goods not having preferential origin status

Suppliers’ declarations for products having preferential origin status


Wording to use


I, the undersigned, declare that the goods listed on this document….…….…..…..(1) originate in…..…..…..…..(2) and satisfy the rules of origin governing preferential trade with…..…..…..…..(3): I declare that (4):

  • Cumulation applied with…………………….(name of the country/countries)

  • No cumulation applied

I undertake to make available to the Customs authorities any further supporting documents they require: …..…..…..…..……….(5) …..…..…..…..……….(6) …..…..…..…..……….(7)


Number


What to include


1 If only some of the goods listed on the document are concerned, they shall be clearly indicated or marked and this marking entered in the declaration as follows:


‘….. listed on this invoice and marked ….. originate in …..’.


2 The UK, EU, country, group of countries or territory, from which the goods originate.

3 Country, group of countries or territory concerned

4 To be completed only where goods are being exported to a country in the Pan-Euro-Med zone. Delete as appropriate.

5 Place and date.

6 Name and position in the company.

7 Signature.


Long-term suppliers’ declarations for products having preferential origin status

Wording to use


I, the undersigned, declare that the goods described below: ………………………………..…………………….… (1) ………………………………………………………………………….. (2) which are regularly supplied to …..…..…..…..(3), originate in.…..…..…..…..(4) and satisfy the rules of origin governing preferential trade with…..…..…..…….….…..(5). I declare that (6):

  • Cumulation applied with ………………..(name of the country/countries)

  • No cumulation applied

This declaration is valid for all shipments of these products dispatched from:…..…..…..….. to …….…..…..(7). I undertake to inform…..…..…..…..(3) immediately if this declaration is no longer valid. I undertake to make available to the Customs authorities any further supporting documents they require. …..…..…..…..…..…..…..…..(8) …..…..…..…..…..…..…..…..(9) …..…..…..…..…..…..…..…..(10)


What to include

1 Description.

2 Commercial designation as used on the invoices (for example, model number).

3 Name of company to which goods are supplied.

4 The EU, country, group of countries or territory, from which the goods originate.

5 Country, group of countries or territory concerned.

6 To be completed, where necessary, only for goods having preferential origin status in the context of preferential trade relations with one of the countries with which pan-Euro-Mediterranean cumulation of origin is applicable. Delete as appropriate.

7 Give the dates. The period shall not exceed 24 months or 12 months if the declaration was issued retrospectively.

8 Place and date.

9 Name and position, name and address of the company.

10 Signature


Suppliers’ declarations for goods not having preferential origin status

Wording to use


I, the undersigned, supplier of the goods covered by the annexed document, declare that: (1) the following materials which do not have a preferential originating status have been used in the EU to produce these goods: Description of the goods supplied

(1)Description of non-originating materials used HS heading of non-originating materials used

(2)Value of non-originating materials used (3)……………….……………….……………….……………….……………….……………….……………….……………….……………….……………….……………….Total(2) All the other materials used in the EU to produce these goods originate in …………..(4) and satisfy the rules of origin governing preferential trade with…………..(5), and: I declare that (6):

  • Cumulation applied with ………………..(name of the country/countries)

  • No cumulation applied

I undertake to make available to the Customs authorities any further supporting documents they require. …..…..…..…..…..…..…..…..(7) …..…..…..…..…..…..…..…..(8) …..…..…..…..…..…..…..…..(9)


What to include

1 When the invoice, delivery note or another commercial document to which the declaration is annexed relates to a variety of goods, or goods not incorporating the same proportion of non-originating materials, the supplier must clearly differentiate between them.


Example

the document covers different models of electric motor of heading 8501 to be used in the manufacture of washing machines of heading 8450. the nature and value of the non-originating materials used in the manufacture of the motors carry from one model to another. The models must be listed separately in the ‘Description of the goods supplied‘ column and the information in the other columns must be given for each, so that the manufacturer of the washing machines can correctly assess the originating status of each of their products depending on the type of motor it incorporates.


2 To be completed only when relevant.


Example

The rule for garments of ex Chapter 62 allows the use of non-originating yarn. this if s French garment manufacturer uses fabric woven in Portugal from non-originating yarn, the Portuguese supplier and only enter ‘yarn’ as non-originating materials in the ‘Description of non-originating materials used‘ column of their declaration - the HS heading and value of the yarn are irrelevant.


A firm manufacturing wire of HS heading 7217 from non-originating iron bars must enter ‘iron bars’ in the ‘Description of non-originating materials used‘ column. If the wire is to be incorporated in a machine for which the rule of origin sets a percentage limit on the value of non-originating materials used, the value of the bars must be entered in the ‘Value of non-originating materials used’ column.


3 Value means the customs value of the materials at the time of import or, if this is not known and cannot be ascertained, the first ascertainable price paid for the materials in the UK or EU. For each type of non-originating material used, specify the exact value per unit of the goods shown in the ‘Description of the goods supplied‘ column.


4 The UK, EU, country, group of countries or territory, from which the goods originate.

5 Country, group of countries or territory concerned.

6 To be completed, where necessary, only for goods having preferential origin status in the context of preferential trade relations with one of the countries with which pan-Euro-Mediterranean cumulation of origin is applicable. Delete as appropriate.

7 Place and date.

8 Name and function, name and address of the company.

9 Signature.


Long term suppliers’ declarations for goods not having preferential origin status


Wording to use


I, the undersigned, supplier of the goods covered by the annexed document, which are regularly sent to …………..(1) declare that: (1) the following materials which do not have a preferential originating status have been used in the UK or EU to produce these goods: Description of the goods supplied


(2)Description of non-originating materials used HS heading of non-originating materials used

(3)Value of non-originating materials used (4)……………….……………….……………….……………….……………….……………….……………….……………….……………….……………….……………….Total(2) All the other materials used in the UK or EU to produce these goods originate in …………..(5) and satisfy the rules of origin governing preferential trade with…………..(6), and: I declare that (7):

  • Cumulation applied with ………………..(name of the country/countries)

  • No cumulation applied

This declaration is valid for all further shipments of these products dispatched from:…..…..…..….. to …….…..…..(8). I undertake to inform…..…..…..….. immediately if this declaration is no longer valid. I undertake to make available to the Customs authorities any further supporting documents they require. …..…..…..…..…..…..…..…..(9) …..…..…..…..…..…..…..…..(10) …..…..…..…..…..…..…..…..(11)

Number


What to include

1 Customer’s name and address.


2 When the invoice, delivery note or another commercial document to which the declaration is annexed relates to a variety of goods, or goods not incorporating the same proportion of non-originating materials, the supplier must clearly differentiate between them.


Example

The document covers different models of electric motor of heading 8501 to be used in the manufacture of washing machines of heading 8450. the nature and value of the non-originating materials used in the manufacture of the motors carry from one model to another. The models must be listed separately in the ‘Description of the goods supplied’ column and the information in the other columns must be given for each, so that the manufacturer of the washing machines can correctly assess the originating status of each of their products depending on the type of motor it incorporates.


3 To be completed only when relevant.


Example

The rule for garments of ex Chapter 62 allows the use of non-originating yarn. this if s French garment manufacturer uses fabric woven in Portugal from no-originating yarn, the Portuguese supplier and only enter ‘yarn’ as non-originating materials in the ‘Description of non-originating materials used’ column of their declaration - the HS heading and value of the yarn are irrelevant. A firm manufacturing wire of HS heading 7217 from non-originating iron bars must enter ‘iron bars’ in the ‘Description of non-originating materials used‘ column. If the wire is to be incorporated in a machine for which the rule of origin sets a percentage limit on the value of non-originating materials used, the value of the bars must be entered in the ‘Value of non-originating materials used’ column.


4 ‘Value’ means the customs value of the materials at the time of import or, if this is not known and cannot be ascertained, the first ascertainable price paid for the materials in the UK or EU. For each type of non-originating material used, specify the exact value per unit of the goods shown in the ‘Description of the goods supplied‘ column.


5 The UK, EU, country, group of countries or territory, from which the goods originate.


6 Country, group of countries or territory concerned


7 To be completed, where necessary, only for goods having preferential origin status in the context of preferential trade relations with one of the countries with which pan-Euro-Mediterranean cumulation of origin is applicable. Delete as appropriate.


8Give the dates. The period should not exceed 24 months.


9Place and date.


10Name and function, name and address of the company.


11Signature.


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