Operationalising Free Trade Agreement Benefits
for India-EU and India-Bilateral Trade
Organisation: _____________________________________________
FTA / Preference Scheme: _____________________________________________
Product(s) / HS Code(s): _____________________________________________
Trade Direction: [ ] India → EU Export [ ] EU → India Import [ ] Both
Responsible Person: _____________________________________________
Implementation Date: _____________________________________________
This checklist operationalises a Free Trade Agreement or preference scheme for a specific product and trade direction. It covers the steps from initial FTA benefit identification through to live commercial use — including tariff analysis, origin compliance, documentation, team training, and monitoring. Complete one checklist per FTA per product category.
PHASE 1 — FTA IDENTIFICATION AND BENEFIT ANALYSIS
PHASE 2 — RULES OF ORIGIN COMPLIANCE
PHASE 3 — ORIGIN CERTIFICATION SETUP
For EU GSP — REX Self-Certification
For India-EU FTA (When in Force)
For Other India Bilateral FTAs (UAE CEPA, UK FTA, ASEAN, Japan, South Korea, Australia)
PHASE 4 — INTERNAL SYSTEMS AND TEAM TRAINING
PHASE 5 — RECORD-KEEPING SYSTEM
PHASE 6 — MONITORING AND REVIEW
FTA IMPLEMENTATION SUMMARY
Doc 87 — FTA Implementation Checklist — Neutral Template
| Item | Done | Notes |
|---|---|---|
| Identify all applicable FTAs and preference schemes for the trade corridor and product: EU GSP (Standard / GSP+ / EBA), India-EU FTA (when in force), India-UAE CEPA, India-UK FTA, India-ASEAN AIFTA, India-Japan CEPA, India-South Korea CEPA, India-Australia ECTA, or bilateral. | [ ] | |
| Confirm the product's 8-digit HS code in each relevant tariff system: EU CN code (for EU import); India HSN code (for India import); destination country tariff code. | [ ] | |
| Look up the MFN duty rate for each applicable HS code in each applicable tariff system. | [ ] | |
| Look up the preferential rate under each applicable FTA for the same HS codes — using EU Access2Markets, EU TARIC, India Custom Tariff Schedule, or the relevant country's tariff portal. | [ ] | |
| Calculate the tariff saving per unit and per annual volume: (MFN rate − FTA rate) × CIF/FOB value per annum. | [ ] | |
| Confirm that India has not been graduated from GSP benefit for this specific CN heading (for EU GSP claims) — graduation check on EU TARIC. | [ ] | |
| Confirm no anti-dumping duty (ADD) applies to this product from India under the applicable CN code — ADD is separate from FTA preference and is not eliminated by FTA. | [ ] | |
| Confirm no safeguard TRQ cap applies, or that the annual import volume falls within available quota (for TRQ-covered products such as steel under EU safeguards). | [ ] | |
| CBAM check: For steel, aluminium, cement, fertilisers, hydrogen — confirm CBAM applicability and estimate CBAM cost even after FTA duty saving. | [ ] | |
| Net benefit calculation: FTA duty saving minus CBAM cost minus any compliance cost = net annual benefit of FTA implementation. | [ ] | |
| Decision: Is the net benefit sufficient to justify FTA implementation for this product? Threshold: typically worthwhile above EUR 5,000–10,000 annual saving. | [ ] |
| Item | Done | Notes |
|---|---|---|
| Identify the Product Specific Rule (PSR) for this HS code under the applicable FTA — Wholly Obtained (WO), Change of Tariff Classification (CTC), Regional Value Content (RVC), or Specific Manufacturing Process (SMP). | [ ] | |
| Complete the Rules of Origin Compliance Checklist (Doc 49) for this product under the applicable FTA's PSR. | [ ] | |
| Confirm the product satisfies the applicable PSR — written origin analysis documented. | [ ] | |
| Identify all non-originating inputs used in production — list by HS code and cost value. | [ ] | |
| RVC calculation (if RVC rule applies): (Ex-works value − non-originating input value) / Ex-works value × 100 = ____% (must meet or exceed minimum % required by the PSR). | [ ] | |
| CTC verification (if CTC rule applies): Confirm non-originating inputs are classified under a different HS heading / sub-heading from the finished product — per the applicable CTC rule level (Chapter / Heading / Sub-heading). | [ ] | |
| De minimis check: Non-originating inputs that fail the CTC rule — confirm they are within the 15% de minimis allowance (10% for textiles). | [ ] | |
| Cumulation check: Confirm whether bilateral cumulation is available under this FTA — inputs from the FTA partner country can count as originating. Document cumulation inputs separately. | [ ] | |
| Direct transport rule confirmed: Goods transported directly from India to the destination country, or transit through a third country under customs control without further processing. | [ ] | |
| Origin analysis documented and signed off by the responsible compliance officer. | [ ] | |
| Advance ruling obtained (optional but recommended for high-volume or borderline cases): India — Authority for Advance Rulings (Customs); EU — Binding Tariff Information (BTI) from national customs authority. | [ ] |
| Item | Done | Notes |
|---|---|---|
| REX registration obtained from DGFT Regional Authority — Form REX/01 submitted, INREX number received. | [ ] | |
| REX number validated on EU REX database (ec.europa.eu/taxation_customs/dds2/rex) — number is searchable and active. | [ ] | |
| REX Statement of Origin text added to export invoice template — prescribed text verbatim, REX number, date of declaration, signature field. | [ ] | |
| Export team trained on REX statement requirements — when to include, how to complete, EUR 6,000 threshold rule. | [ ] | |
| Retroactive statement procedure established — in case of inadvertent omission. | [ ] |
| Item | Done | Notes |
|---|---|---|
| REX system confirmed as the designated origin certification mechanism for the FTA (or Form A if FTA specifies — verify FTA Protocol on Rules of Origin). | [ ] | |
| REX registration confirmed as current — same INREX number applies to FTA origin declarations. | [ ] | |
| FTA-specific origin declaration text prepared — verify prescribed text from the FTA Protocol (may differ from GSP text). | [ ] | |
| FTA preference code for EU customs entry identified — European Commission will publish the applicable preference code on FTA entry into force. | [ ] |
| Item | Done | Notes |
|---|---|---|
| Certificate of Origin (CoO) issuing body identified for this FTA — EIC, FIEO, or designated Chamber of Commerce. | [ ] | |
| FTA-specific CoO format obtained — CEPA / FTA CoO is distinct from Form A and REX. Correct form used. | [ ] | |
| CoO application process established with the issuing body — required supporting documents, fees, and turnaround time confirmed. | [ ] | |
| Direct transport documentation requirement confirmed for each FTA — through B/L or transit manifest available for transshipped consignments. | [ ] |
| Item | Done | Notes |
|---|---|---|
| ERP / invoicing system updated: FTA applicable HS codes, preferential rates, and origin certification requirements mapped in the system. | [ ] | |
| Invoice template updated: REX Statement of Origin on invoice, HS code field, country of origin field — all mandatory for FTA claim. | [ ] | |
| Customs entry instructions updated: Customs agent / broker briefed on FTA preference claim procedure, preference code, REX number, and supporting documentation. | [ ] | |
| Bill of Materials (BOM) documented for FTA-covered products — linked to origin analysis for each product. | [ ] | |
| Production records system updated: Each production batch to capture: input HS codes, input values, non-originating input identification — for RVC and CTC verification. | [ ] | |
| Export team trained: FTA rules of origin, REX statement preparation, direct transport requirement, record-keeping obligations. | [ ] | |
| Finance team trained: FTA duty saving quantified and tracked — separate FTA benefit reporting line in management accounts. | [ ] | |
| Customer communication prepared: EU buyers briefed that goods are REX-certified / FTA-eligible — preference claim procedure explained. | [ ] | |
| EU buyer's customs agent briefed: Preference code, REX number, and documentation requirements for EU import entry. | [ ] |
| Item | Done | Notes |
|---|---|---|
| Origin records retention policy established: Minimum 3 years from date of REX statement (EU GSP); 4 years for EU customs entry records; verify FTA-specific retention periods. | [ ] | |
| Record-keeping system designated: Physical or electronic archive. Access controls in place. Backup confirmed. | [ ] | |
| Records to be retained per shipment: REX statement (copy), Commercial invoice, Packing list, Bill of Lading, Production records (BOM, RVC calculation), Input purchase invoices, Supplier declarations for originating inputs, Direct transport documents (if transshipped). | [ ] | |
| Supplier declarations obtained from all input suppliers: Each supplier confirms the originating / non-originating status of their materials — updated annually or upon any change. | [ ] | |
| Annual origin self-audit: Process established to review all REX statements made in the prior year against actual production records — any discrepancies identified and corrected. | [ ] | |
| DGFT annual REX confirmation: Annual confirmation to DGFT that export activity continues and goods continue to qualify for preferential origin — filed to maintain REX registration. | [ ] |
| Item | Done | Notes |
|---|---|---|
| FTA benefit tracking: Monthly report on FTA duty savings generated — actual vs. budgeted. | [ ] | |
| PSR change monitoring: FTA product-specific rules may be amended — annual review of applicable PSR for each covered HS code. | [ ] | |
| Graduation monitoring (GSP): DGFT / EU Commission graduation list reviewed annually each October — any graduation of India for covered HS codes flagged immediately. | [ ] | |
| ADD monitoring: EU anti-dumping investigation alerts monitored for new investigations affecting covered products — trade press and EC DG Trade alerts subscribed. | [ ] | |
| FTA news monitoring: India-EU FTA negotiation progress tracked — entry into force date will trigger transition from GSP to FTA preference code. | [ ] | |
| Exchange rate monitoring: FTA RVC calculations use ex-works values — significant EUR/INR exchange rate movements may affect the RVC percentage. Quarterly recalculation if rate moves more than 5%. | [ ] | |
| New HS code classification: Any product development or specification change reviewed for potential HS code reclassification impact on applicable PSR. | [ ] | |
| Verification response readiness: Internal procedure for responding to EU customs or Indian customs verification requests — designated response coordinator, 10-month timeline understood. | [ ] |
| FTA / Scheme: | |
|---|---|
| Product / HS Code: | |
| MFN Rate: | _____% |
| FTA Preferential Rate: | _____% |
| Annual Duty Saving (est.): | EUR _____________ |
| PSR Type: | WO / CTC / RVC / SMP |
| Origin Certification Method: | REX / Form A / CEPA CoO |
| REX Number (if applicable): | |
| Implementation Date: | |
| Responsible Person: | |
| Next Review Date: |