Proof of Origin from UK under TCA – EUR.1, REX and Statement on Origin step by step

Brexit changed the rules of trade between the UK and the EU, but it did not eliminate the possibility of zero duty. The Trade and Cooperation Agreement (TCA) between the UK and the EU maintains a 0% tariff rate on thousands of products — on one condition: the goods must have qualifying UK or EU origin and be supported by the correct document. Without a Proof of Origin you pay the full MFN (Most Favoured Nation) tariff rate, which can range from a few to several tens of percent of the value of the goods. This article explains how to correctly document the origin of goods from the UK.

What are the Rules of Origin under TCA and why do they matter?

The TCA is not a blanket agreement — not every product from the UK automatically qualifies for 0% duty. To benefit from tariff preferences, the goods must satisfy the Rules of Origin, which determine the extent to which goods must have been produced or processed in the UK or EU in order to have "qualifying origin" status.

The rules are set out in Annex ORIG to the TCA and contain Product Specific Rules (PSR) — dedicated requirements for each HS heading. The core criteria are:

• Wholly Obtained (WO) — the goods originate entirely from the UK (applies to, for example, natural raw materials, animals reared in the UK, and agricultural products).
• Sufficient Processing (SP) — the goods have undergone sufficient processing in the UK. Defined in two ways:
• Change of Tariff Classification (CTC) — a change of HS code as a result of processing (e.g. raw aluminium → aluminium profile — a change at chapter or heading level),
• Value Added Rule (VA) — the maximum share of non-originating materials in the value of the finished product — typically 50% or 70% depending on the PSR.
• No-drawback rule — important: you cannot simultaneously claim TCA preferences and a refund of duty paid on non-EU/non-UK raw materials used in production.

If the goods do not satisfy the PSR, they do not have qualifying origin and the TCA preference does not apply, regardless of what is stated in the certificate.

Methods of documenting UK origin — an overview

In UK–EU trade there are two methods of Proof of Origin:

1. Statement on Origin (SoO) — exporter's declaration

This is the primary and most commonly used method. The UK exporter places the origin statement directly on the commercial invoice, packing list or another commercial document. The wording of the statement is standardised (as set out in TCA Annex ORIG-4):

"The exporter of the products covered by this document declares that, except where otherwise clearly indicated, these products are of UK preferential origin."

Conditions for issuing a SoO:

Shipment value	Requirements
Up to £6,000	Any exporter may issue a SoO without additional registration
Above £6,000	The exporter must be a Registered Exporter (REX) in the UK system or hold Approved Exporter status

The statement must include: - the date of issue, - the exporter's name and address, - a description of the goods and HS codes (optional, but recommended), - the exporter's signature or electronic identification.

2. EUR.1 — movement certificate

EUR.1 is NOT used in UK–EU trade under the TCA. This is a key mistake that frequently appears in documentation.

EUR.1 is used in trade between the UK and countries with which the UK has bilateral trade agreements based on the Pan-Euro-Mediterranean protocol — e.g. Turkey, Switzerland, Norway (EFTA), Morocco, Israel. In trade with Poland (EU), the correct document is exclusively the Statement on Origin.

If your UK supplier sends a EUR.1 as Proof of Origin for an import into Poland, ask whether this is the correct document for the UK→EU route.

What is REX and who needs it?

REX (Registered Exporter System) is the registration system for exporters authorised to issue Statements on Origin for shipments with a value above £6,000.

In the UK, the REX system is administered by HMRC. The exporter applies online, receives a REX number (e.g. GB-REX-123456), and may include it on commercial documents as evidence of authorisation.

How to verify a UK supplier's REX number? The REX database is publicly available on the European Commission website (ROSA — Rules of Origin Self Assessment). Enter the supplier's REX number and check whether it is active.

If your supplier claims to have issued a SoO on a shipment worth more than £6,000 without a REX number, that statement is invalid. You will pay the full MFN duty.

What does a customs agent check in a Proof of Origin document?

A good customs agent verifies the Proof of Origin before submitting the import declaration. Here is the checklist:

• Presence of the statement — is the SoO on the invoice or another commercial document?
• Shipment value vs. REX number — if the value exceeds £6,000, is the REX number provided and active?
• Consistency of the goods description — does the description of goods in the SoO match the description on the invoice and CMR?
• HS codes — if provided, are they consistent with the classification in the import declaration?
• Date of issue — the SoO must be issued before or at the time of export, not retrospectively.
• Value consistency — if value thresholds are critical to the PSR (Value Added Rule), the agent may request a cost breakdown calculation.

PoO errors that HMRC may challenge: missing REX number for high-value shipments, inconsistent HS codes, issuance after the export date, missing exporter details.

What happens when a Proof of Origin is missing?

If an importer does not have a valid PoO at the time of the customs declaration, they can either:

1. Clear the goods at the MFN rate (full duty without TCA preference) — and then apply for a refund once the PoO is supplied within 12 months of the clearance date (retroactive claim). HMRC accepts such applications, but the process takes time.

2. Hold the clearance and demand the PoO from the supplier — if the supplier can send the missing document quickly. In practice: a few hours' delay versus the cost of the duty.

Example: Import of a machine from the UK, value £40,000, HS code with a 2.7% duty rate. - With a valid PoO: duty = £0 - Without PoO: duty = £1,080 + the cost of filing a retroactive claim

For regular importers, a missing PoO can cost tens of thousands of pounds per year.

How to require the correct document from your supplier?

This is a common issue: the importer knows a PoO is required, but the UK supplier is unaware of this or sends the wrong document. How to fix it?

Step 1: Notify the supplier in writing Send the supplier a clear instruction: "Please include a Statement on Origin on the invoice in accordance with Article ORIG-18 of the TCA. For values above £6,000 we require a REX number."

Step 2: Verify the supplier's REX status Check the ROSA database to confirm whether the supplier has an active REX number. If not, inform them that they can register with HMRC.

Step 3: Check whether the goods qualify under TCA Not every product manufactured in the UK has qualifying origin. If the supplier uses a significant proportion of imported raw materials (e.g. components from China), they must carry out a value-added or CTC calculation to confirm that the PSR are met.

Step 4: Include the PoO requirement in your purchase order (PO) Add a clause to the purchase order: "The supplier undertakes to provide a Statement on Origin (TCA ORIG-18) with every shipment. Failure to supply this document entitles the importer to charge the supplier for any MFN duty incurred."

Table: Proof of Origin methods in trade with the UK

Method	When to use	Who issues it	Value threshold	Applicable to UK–EU?
Statement on Origin (SoO)	Import from UK to EU under TCA	UK exporter	Up to £6,000 — no REX required; above — REX required	YES
EUR.1	Import from UK to EFTA countries, Morocco, Israel, etc.	UK Border Force / exporter	No threshold — application required	NO (does not apply to EU)
Form A / GSP	Import from developing countries to UK or EU	Exporter in the developing country	Various	NO (not UK)

[LINK: check our Proof of Origin verification services] [LINK: learn more about TCA rules for B2B importers]