Question:
How do we determine the country of origin for finished goods that we export to non-EU/UK countries but which also have a Trade and Cooperation Agreement (TCA) with UK/EU, such as India and South Korea?
We do not actually manufacture one of the finished products that we export to these countries, but just dilute with water a component imported from Belgium and the commodity code doesn’t change.
Are we correct in thinking that this would not be deemed as sufficient processing in order for the product to become of UK origin?
Answer:
Currently, the UK does not have a preferential trade agreement with India. It is being discussed but isn’t yet in place. But the non-preference origin of the goods (place of manufacture) is still important and must be correctly stated on your paperwork.
You will need to check the commodity code of the original component to see if “dilution” is sufficient to change origin. Some product specific rules have a processing option to establish origin and/or preferential origin — it is generally linked to the process causing a chemical reaction, purification, mixing, change in particle size, etc. You need to check the definitions of these terms as used within each individual trade agreement.
more information:
Check your goods meet the rules of origin – GOV.UK (www.gov.uk)