Complete Practitioner's Guide for Indian Exporters
This guide covers everything an Indian exporter needs to know about the Registered Exporter (REX) system — the EU's self-certification mechanism for preferential origin under the EU GSP and the India-EU FTA. It covers registration, the statement of origin, record-keeping, verification, and practical tips for avoiding errors.
1. What Is REX and Why It Matters
The REX system replaces the Form A Certificate of Origin for exporters wishing to claim preferential tariff rates under the EU Generalised System of Preferences (GSP) and is the designated self-certification system for the India-EU FTA (once concluded). Under REX, a registered exporter makes a declaration of origin directly on a commercial document — no need for a government authority to certify the origin of each shipment.
Why REX matters for Indian exporters:
Cost saving: Eliminates the cost and time of obtaining a Form A from the Export Inspection Council (EIC) or Chamber of Commerce for each shipment.
Speed: The REX statement can be made on the invoice at the time of shipment — no waiting for a government certificate.
Competitive parity: EU buyers sourcing from other REX-registered countries (Vietnam, Bangladesh, Sri Lanka) already benefit from self-certification. Indian exporters without REX are at an administrative disadvantage.
FTA readiness: REX is the designated origin certification system for the India-EU FTA — being registered now means seamless transition when the FTA enters into force.
Commercial credibility: EU buyers increasingly prefer and require REX-certified suppliers as part of their sourcing due diligence.
2. REX Registration — Step by Step
2.1 Who Registers?
In India, REX registration is managed by the Directorate General of Foreign Trade (DGFT) through its regional offices (Regional Authorities for Advance Rulings — RA offices). The exporter applies to the RA in their jurisdiction.
2.2 Eligibility
Any Indian exporter who exports goods to the EU under the EU GSP (or who intends to export under the India-EU FTA once in force) and whose goods satisfy the applicable Rules of Origin may register as a REX exporter. There is no minimum turnover or export value requirement.
2.3 Registration Process
Visit the DGFT online portal (dgft.gov.in) and navigate to the REX registration section.
Complete Form REX/01 with the following information: exporter's full legal name and IEC; registered address; GSTIN; nature of business; list of products for which REX registration is sought (by HS code); and declaration of compliance with the applicable Rules of Origin.
Submit the application online along with supporting documents: copy of IEC; copy of GST registration; copies of export invoices or Shipping Bills demonstrating export activity.
The DGFT Regional Authority reviews the application. Processing time: typically 10–30 working days.
Upon approval, the exporter is assigned a REX number in the format: INREX[unique identifier]. This number is entered on the EU's REX database (maintained by OLAF/European Commission) and is publicly searchable.
Retain the REX registration certificate. There is no validity period — the REX number is valid indefinitely, subject to annual confirmation of continuing compliance (see section 6).
3. The REX Statement of Origin — Complete Requirements
3.1 Where to Place the Statement
The REX statement of origin must appear on a commercial document that accompanies or identifies the consignment. Acceptable documents include:
Commercial invoice (most common — recommended)
Packing list
Delivery note
A separate statement document (where the above are not practical)
The statement may be handwritten, typed, printed, or stamped on the document. It may appear anywhere on the document — no prescribed location — but must be clearly legible and distinct from the other content of the document.
3.2 Prescribed Text of the REX Statement
The REX Statement must contain the following prescribed text verbatim. For EU GSP Standard:
For India-EU FTA (once in force, the prescribed text may vary — refer to the Protocol on Rules of Origin in the FTA text for the exact wording required). The current EU GSP text above is used as a template.
3.3 Mandatory Fields
3.4 Value Threshold — Large and Small Consignments
The EUR 6,000 threshold applies as follows:
Consignments of EUR 6,000 or less (per shipment): Any exporter — whether REX-registered or not — may make a statement of origin. REX registration is not required below this threshold. However, for regular trading relationships, REX registration is still recommended to avoid the need to obtain Form A for larger shipments.
Consignments exceeding EUR 6,000: Only REX-registered exporters may make a statement of origin. Non-REX exporters must obtain a Form A from the EIC or a Chamber of Commerce for these consignments.
Note: The EUR 6,000 threshold applies per consignment (per shipment) — not per invoice or per order. Multiple invoices in a single shipment are aggregated.
4. Multiple Products in a Single Statement
A single REX statement may cover multiple products in the same consignment, provided all products in the consignment originate in India and satisfy the applicable Rules of Origin. Where different products in the same consignment have different origin determinations (e.g. some are wholly obtained; others satisfy CTC), each product line should be individually annotated if their origin status differs. Where a single product does not qualify for preference, that item should be clearly excluded from the statement.
5. Retroactive Statements
In exceptional circumstances (e.g. where the statement was inadvertently omitted), a retroactive statement of origin may be made after the date of shipment. The statement must clearly indicate it is retroactive and state the reason. The EU customs authority may require additional documentation to accept a retroactive statement. Retroactive statements should be the exception, not the norm — disciplined process ensures the statement is always included on the invoice before shipment.
6. Annual Confirmation and Ongoing Obligations
Annual confirmation: REX-registered exporters must confirm to the DGFT annually that they continue to export goods qualifying for preferential origin. Failure to confirm may result in suspension or cancellation of the REX registration.
Notification of changes: The exporter must notify the DGFT immediately of any material change affecting the REX registration — including change of IEC, change of address, change of product range, or any change in the production process that may affect origin status.
Record-keeping: The exporter must retain all records supporting each statement of origin for a minimum of three (3) years from the date of the statement (or longer if required by the applicable scheme or Indian law). Records must include: purchase invoices for inputs; Bills of Materials; production records; cost breakdown; and copies of statements of origin made.
Suspension / revocation: The DGFT may suspend or revoke a REX registration if the exporter fails to meet origin requirements, fails to maintain records, or makes a false statement of origin. A false statement of origin may also constitute an offence under the Customs Act and the FEMA.
7. EU Verification of REX Statements
The EU customs authority or the customs authority of any EU member state may request verification of a REX statement of origin. Verification is conducted through:
Administrative cooperation: The EU customs authority sends a verification request to the DGFT (or Indian Customs). The DGFT must respond within ten (10) months.
Onsite verification: In exceptional cases, EU officials may visit the exporter's premises in India to verify production processes and origin documentation.
If verification reveals that the goods did not qualify for preferential origin, the EU importer will be required to pay the full MFN duty plus interest, and may face penalties. The Indian exporter may also face consequences under Indian export control and customs law. It is therefore essential that every REX statement is backed by a complete and accurate origin analysis and records.
8. REX Registration Checklist
Doc 50 — REX Self-Certification: Complete Practitioner's Guide — Neutral Template
| STATEMENT ON ORIGIN (EU GSP) The exporter of the products covered by this document (Exporter Reference No.: [INSERT REX NUMBER]) declares that, except where otherwise clearly indicated, these products are of [INSERT COUNTRY OF ORIGIN] preferential origin. Place and Date of Declaration: [INSERT PLACE], [INSERT DATE] Signature of the exporter or authorised representative: ___________________________ Full name of signatory: ___________________________ |
|---|
| Field | Requirement |
|---|---|
| REX Number | The exporter's full REX number (e.g. INREX12345678). Must match the number in the EU REX database. Incorrect REX numbers will cause the preference claim to be rejected. |
| Country of Origin | Must state "India" or "IN" as the country of preferential origin. Must not state a transit country or processing country. |
| Place of Declaration | The city in India where the declaration is made — typically the exporter's place of business. |
| Date of Declaration | The date on which the statement is made. Must be on or before the date of shipment. A statement dated after the B/L on-board date is invalid. |
| Signature | Signed by the exporter or an authorised representative. An electronic signature or digitally printed signature is acceptable in most EU member states — confirm with your buyer's customs agent. |
| Action | Done |
|---|---|
| Confirm all products intended for EU export are covered by Rules of Origin analysis (see Doc 49). | [ ] |
| Access DGFT portal (dgft.gov.in) and locate REX registration section. | [ ] |
| Complete Form REX/01 with IEC, GSTIN, address, and product HS codes. | [ ] |
| Upload required documents: IEC copy, GST registration, sample Shipping Bills. | [ ] |
| Submit application and note the application reference number. | [ ] |
| Follow up with DGFT RA office if no response within 30 working days. | [ ] |
| Receive REX number — record it in company letterhead, invoice template, and trade documents. | [ ] |
| Verify REX number is searchable on EU REX database (ec.europa.eu/taxation_customs/dds2/rex). | [ ] |
| Update invoice template to include REX statement of origin (prescribed text — see section 3). | [ ] |
| Brief export team on where and how to include REX statement on every EU-bound invoice. | [ ] |
| Set up annual confirmation reminder in compliance calendar. | [ ] |
| Establish record-keeping file for REX-related documents (BOM, input invoices, production records). | [ ] |