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RULES OF ORIGIN COMPLIANCE CHECKLIST

576 words · 46 sections · 8 data table(s)

IndiaEU Trade (FTA and GSP)

Exporter Name: _____________________________________________

Product Description: _____________________________________________

HS Code (6-digit): _____________________________________________

Country of Origin Claim: India

Destination Market: _____________________________________________

Preferential Scheme: India-EU FTA / EU GSP / EU GSP+ / Other: _____________

Checklist Completed By: _____________________________________________

Date: _____________________________________________

This checklist is to be completed for each product for which an Indian exporter intends to claim preferential tariff treatment or country of origin certification. Retain this completed checklist with all supporting documentation for a minimum of five (5) years.

PART 1 — UNDERSTANDING THE APPLICABLE RULES OF ORIGIN

Step 1: Identify the applicable preferential scheme and its Rules of Origin (ROO). The ROO differ between the India-EU FTA (when in force), the EU Generalised Scheme of Preferences (GSP), and other preferential arrangements. Confirm which scheme applies to this shipment.

Step 2: Look up the specific product rule for your HS code in the applicable scheme's Product Specific Rules (PSR) annex. The PSR will state one or more of the following criteria:

Wholly Obtained (WO): All inputs must be produced entirely within India. No imported inputs permitted.

Change in Tariff Classification (CTC): The finished product must be classified under a different HS heading or subheading than its non-originating inputs. The PSR will specify whether a change at chapter (CC), heading (CTH), or subheading (CTSH) level is required.

Regional Value Content (RVC): A minimum percentage of the product's value must originate in India. The PSR will state the required percentage and the calculation method (build-up or build-down).

Specific Process Rule: The product must undergo a specific manufacturing or processing operation in India as described in the PSR.

Combination Rule: The product must satisfy two or more of the above criteria simultaneously.

Applicable Product Specific Rule for this HS code: _____________________________________________

Source / Reference (PSR Annex, Rule Number): _____________________________________________

PART 2 — WHOLLY OBTAINED GOODS

Complete this section only if the product is claimed as Wholly Obtained. Wholly Obtained goods must satisfy all applicable criteria below.

PART 3 — CHANGE IN TARIFF CLASSIFICATION (CTC)

Complete this section if the product rule requires a CTC. List all non-originating (imported) inputs used in the production of the finished product.

PART 4 — REGIONAL VALUE CONTENT (RVC)

Complete this section if the product rule requires a minimum RVC threshold. State the required percentage and confirm that the calculation has been performed and documented.

Required RVC Threshold: _____%

Calculation Method: Build-Up / Build-Down (circle one)

Calculated RVC: _____%

RVC Satisfied: Yes / No

PART 5 — INSUFFICIENT PROCESSING (MINIMAL OPERATIONS)

The following operations are considered insufficient processing under most preferential schemes and will not confer originating status on the product regardless of where they are performed. Confirm that the processing undergone in India goes beyond these minimal operations.

PART 6 — DIRECT TRANSPORT / NON-MANIPULATION

Preferential origin may be lost if goods are transported through a third country and substantially processed or manipulated there. Confirm the following:

PART 7 — PROOF OF ORIGIN DOCUMENT

Select the appropriate proof of origin document for the applicable preferential scheme:

PART 8 — RECORD-KEEPING CONFIRMATION

DECLARATION

I confirm that this checklist has been completed in good faith, that the information provided is accurate to the best of my knowledge, and that the goods described above qualify for preferential tariff treatment under the scheme indicated.

Authorised Signatory: _____________________________________________

Full Name: _____________________________________________

Title: _____________________________________________

Entity Name: _____________________________________________

Date: _____________________________________________

Doc 25 — Rules of Origin Compliance Checklist (India–EU) — Neutral Template

Checklist ItemYes / No / N-ANotes / Evidence
The product is a mineral product extracted from Indian soil or territorial waters
The product is a vegetable product harvested in India
The product is a live animal born and raised in India
The product is derived from live animals raised in India (e.g. milk, eggs, honey)
The product is obtained by hunting, trapping, or fishing conducted in India or in Indian territorial waters
The product is obtained from aquaculture operations in India
The product is a waste or scrap product derived entirely from Indian manufacturing operations
No non-originating materials of any kind have been used in the production of this product
Documentary evidence of wholly obtained status has been obtained and retained
Non-Originating InputHS Code of InputHS Code of OutputCTC Satisfied?Source Country
Checklist ItemYes / No / N-ANotes / Evidence
All non-originating inputs have been identified and their HS codes confirmed
The HS code of the finished product differs from all non-originating inputs at the required level (CC / CTH / CTSH as specified in the PSR)
Bills of materials and supplier invoices confirming input HS codes have been obtained and retained
No non-qualifying operations (insufficient processing) have been applied — see Part 5
Checklist ItemYes / No / N-ANotes / Evidence
The value of all non-originating materials has been calculated at CIF price or ex-works, as required by the applicable scheme
The value of originating materials and processing costs in India has been calculated and documented
The RVC calculation worksheet has been prepared and retained
Supporting evidence (supplier invoices, factory cost records) has been obtained and filed
The RVC percentage meets or exceeds the threshold specified in the PSR
Checklist ItemYes / No / N-ANotes / Evidence
The processing in India is NOT limited to: preservation operations (e.g. drying, freezing, salting)
The processing in India is NOT limited to: simple assembly or disassembly of products
The processing in India is NOT limited to: washing, cleaning, or removal of dust / paint
The processing in India is NOT limited to: simple cutting, slicing, or repacking
The processing in India is NOT limited to: application of marks, labels, or logos
The processing in India is NOT limited to: simple mixing of products
The processing in India involves substantive transformation consistent with the applicable PSR
Checklist ItemYes / No / N-ANotes / Evidence
The goods will be transported directly from India to the EU destination without transshipment, OR
If transshipment occurs, it is through a third country under customs control with no further processing
If transshipment occurs, documentary evidence of non-manipulation (e.g. through bill of lading, customs authority certificate) will be obtained
The goods will not be entered into free circulation in any third country during transit
Evidence of the transport route (bill of lading, freight documents) has been obtained or is available
Checklist ItemYes / No / N-ANotes / Evidence
EU GSP: REX (Registered Exporter) Statement on Origin — exporter must hold a valid REX registration number
EU GSP: EUR.1 Movement Certificate — issued by Indian Customs for consignments above EUR 6,000
EU GSP: Origin Declaration on invoice for consignments below EUR 6,000 (approved exporter or REX holder)
India-EU FTA (when applicable): Origin Declaration as specified in the FTA text
The REX registration number of the exporter is: _____________________________________________
The EUR.1 certificate number is (if applicable): _____________________________________________
The statement on origin has been placed on the invoice / packing list / other commercial document
The statement on origin includes all required elements as per the applicable scheme
A copy of the proof of origin document has been retained in the export file
Checklist ItemYes / No / N-ANotes / Evidence
Bills of materials (BOM) for this product are available and retained
Supplier invoices and certificates of origin for all non-originating inputs are retained
Production records demonstrating transformation in India are retained
RVC calculation worksheet (if applicable) is retained
Proof of origin document (REX statement / EUR.1) copy is retained
All records will be retained for a minimum of five (5) years from the date of export
Records are accessible to customs authorities on request

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