Certificate of Origin, proof of where a product was made
- Marco van Hagen
- 26 Apr 2023
- Edited 1 Jan 2023
- 6 min
- Managing and growing
A Certificate of Origin serves as proof of the country in which a product was manufactured. If you export products, your client may ask for a Certificate of Origin if it is required in the country of destination. For example, a country might want to see proof of a product’s origin in order to protect its own economy or limit risks to public health.
A Certificate of Origin (Certificaat van Oorsprong or CVO in Dutch) serves as proof of a product’s origin. It contains a description of, and the origin of, your products, plus the name and address details of the seller and the buyer. In the Netherlands, KVK authenticates the origin of Certificates of Origin with a digital stamp and signature. This article explains why you need a Certificate of Origin, the definition of ‘origin’, and how to determine a product’s origin.
Some countries have chosen to bar products from certain countries for political, economic, or health reasons. If you deliver an order to one of these countries, the local authorities will want to know in what country these goods were produced. This way, they can keep out products originating from countries which are subject to a trade ban.
We explain the various political, economic, and health reasons below.
You might need a Certificate of Origin for health reasons, for example in cases where a country is concerned about animal or plant diseases in specific countries. In these cases, the authorities do not want to allow plant or animal products from the country in question, in order to prevent infection. We refer to this as veterinary (animal health) and phytosanitary (plant health) restrictions.
A quota system such as a tariff contingent (Belastingdienst, in Dutch). This is a reduction of import duties for specific quantities of products, such as an exemption from import duties for the import of beef from Turkey. For example, you can import up to 75,000 tonnes of beef without paying import duties; above this quantity, import duties of 40% apply.
Anti-dumping duties (Belastingdienst, in Dutch). This is where government authorities impose additional import duties if goods are launched in the market too inexpensively, causing the market to be disrupted. These types of measures are often aimed at specific products from a specific country, for example, anti-dumping duties in Brazil for deep-frozen chips (French fries) (HS code 2004 10), which are supplied by exporters from the Netherlands and other countries. In this case, the Brazilian importer pays an additional duty of between 6.3% and 78.9% on top of the standard import duties of 12.6%. A Certificate of Origin allows Customs to assess on import what anti-dumping duties apply to the relevant product.
Within the EU
In most cases, you will not require a Certificate of Origin in the EU. Customers who are based in the EU might ask you for a Certificate of Origin as confirmation of the origin of the product you supply. Many of these customers supply the full order or part of the order to a non-EU country. Your customer will then request a new Certificate of Origin and use your Certificate as underlying proof. In some cases, you may also be able to use other items of proof, including a Supplier's declaration of origin.
You can search the Access2Markets database of the European Commission to find out whether a Certificate of Origin is required for your particular consignment. The article titled Using the correct documents for export explains how Access2Markets works.
Goods are of non-preferential origin (Belastingdienst, in Dutch) if they are ‘wholly obtained’ in a country or territory or have undergone a ‘final substantial transformation’ in the country of manufacture.
‘Origin’ refers to the country where a product has been sourced, grown and harvested, caught, or born. This may include minerals, wood, crops, or animals. This is referred to as ‘wholly obtained’. For products which are wholly obtained, any processing of a product into an end product must not involve any foreign materials. This is how you can easily establish the origin of wholly obtained products.
Last substantial transformation
If you manufacture products in which you process ingredients and parts from a variety of countries, this means these products where not wholly obtained in the Netherlands. If your Netherlands-based business processes ingredients and parts such as semi-finished product sufficiently into a new product, the end product will be classified as being of Dutch origin. This is referred to as the ‘last substantial transformation’.
You import coniferous wood from Canada, which you saw, assemble, and mill at your production facility in the Netherlands. The end product is a picnic table, which will be classified as having Dutch origin. The picnic tables underwent a ‘last substantial transformation’ in the Netherlands. This transformation must be ‘sufficiently worked or processed’, which involves more than the process of basic assembly.
The regulations below explain when the transformation of a product is sufficiently worked or processed to change its origin, and how you change the origin of a product.
Regulations on origin
The Certificate of Origin states the non-preferential origin. The requirements for determining the non-preferential origin of goods are detailed in Section 61, subsection 3 of the Union Customs Code. Pursuant to Section 61, goods are assigned the origin of the country in which they were wholly obtained or underwent the last substantial transformation.
You can use the Eurochambres Guidelines as a tool for applying the customs regulations contained in Article 61. The key terms from the regulations on origin include:
Wholly obtained. This may include extracting minerals from the soil, harvesting fruit and vegetables, or milking cows.
Last substantial transformation.[Einde van tekstterugloop] This is subject to terms and conditions, for example that the last substantial transformation involves altering or modifying the product’s essential qualities, features, or functionality.
Minimal operations. This refers to minor changes which do not cause a product’s origin to change. Minimal operations might refer, for example, to packaging or refrigerating products during transport or basic assembly. The guidelines detail all the various types of minimal operations.
Special cases of qualification for origin. These are specific cases of determining the origin of a product. This may include determining the origin of enclosed or dispatched replacements parts, or determining the origin of composite products based on the major portion of the value. This qualifies as the main value ingredient.
You can apply for a Certificate of Origin electronically from KVK. You have two options for submitting your electronic application: You can organise this online through an intermediary or engage the services of a logistics services provider.
What do you need when submitting your application?
You must supply various items of proof to KVK through which you can demonstrate the origin of products. What you supply depends on your role as an applicant.
If you are a manufacturer
You must demonstrate that your product complies with the rules on origin. This requires that you provide a description of your production process, sometimes including additional information. You should contact KVK for this purpose.[Einde van tekstterugloop]Tip: make sure you have the correct commodities code for your product on hand.
If you are a trader
You can use one of the following options:
If your supplier is based within the EU, request a Long-term supplier’s declaration for products of non-preferential origin (LVO).
If your supplier is based outside the EU, request a Certificate of Origin (CVO) to demonstrate the origin. In addition, KVK will ask you to supply the purchase invoice and sales invoice.
There are other ways to demonstrate the origin of a product. Please contact KVK if you are unable to obtain a Long-term supplier’s declaration for products of non-preferential origin (LVO) or a Certificate of Origin (CVO).
If you are a logistics service provider
The burden of proof is the same as for the manufacturer or trader for whom you are handling the consignment. You should also demonstrate to KVK that, as a service provider, you are authorised to represent your client, for example by presenting a power of attorney.
The cost of a Certificate of Origin (CVO) breaks down into several components. Depending on the application method you choose, KVK will send you a monthly summary invoice. In addition, an intermediary or logistics services provider will charge a fee for their services. The following fees apply for 2022:
Certificate of Origin (CVO): €15.60.
Copy of Certificate of Origin (CVO): €1.05.