In international trade practice, the Certificate of Origin is by no means just a "piece of paper." As the "economic passport" of goods, it directly relates to crucial matters such as tariff preferences, trade statistics, and anti-dumping investigations. According to the WTO's "Agreement on Rules of Origin," the determination of origin must adhere to the principle of "substantial transformation," which is also the key point we must grasp when dealing with mixed imported goods.
Origin determination standards for mixed imported goods
For imported goods mixed in tank areas, we need to consider different scenarios:
Simple packaging scenario: If only physical mixing or simple packaging is conducted without changing the essential characteristics of the product, the origin should be traced back to the source country of the raw materials
Substantial processing scenario: If processing procedures compliant with the Regulations of the Peoples Republic of China on the Origin of Goods (such as chemical reactions, tariff code changes, etc.) are conducted in China, the products can be recognized as originating from Chinaimport and exportMixed processing scenario
: When imported materials are processed with domestic materials, the value-added proportion needs to be calculated, typically requiring the China-added portion to exceed 40%: Compliance path in practical operations
Based on 20 years
of experience, I recommend the following compliant operation procedures:foreign tradeVerify processing technology
Verify processing techniques: Record in detail the process parameters such as temperature, pressure, and additives during mixed filling, as these may affect origin determination
Collect supporting documents: , foreign exchange verification and other procedures.Import Customs DeclarationComplete set of traceability documents including invoices, processing records, and quality inspection reports
Pre-review by professional institutions: It is recommended to obtain pre-confirmation through CCPIT (China Council for the Promotion of International Trade) or customs to avoid disputes later
Select certificate type: Regular CO certificate applies to general trade, while FORM A certificate can enjoy GSP preferential tariff rates
Common risk warnings and prevention measures
In practice, we have handled multiple dispute cases caused by origin issues, with special attention to:
Customs audit risks: A company was required to pay back taxes and fined for declaring Malaysian palm oil as Chinese origin after simple repackaging
Customer claim risks: A Middle Eastern client claimed demurrage fees and penalties from the exporter due to origin discrepancies during customs clearance
Trade remedy risks: Incorrect origin declarations may involve companies in anti-dumping investigations
If Chinese origin standards cannot be met, consider the following alternatives:
Negotiate with customers to adoptProcessing tradeManual management approach to resolve tariff issues
ApplicationRegional preferential certificates(e.g. RCEP certificates) may obtain partial tariff reductions
ExploreBonded zone processingModel, leveraging the policy advantage of "within the territory but outside the customs."
Remember:Compliance is always more important than short-term gainsWe once assisted a chemical company in successfully converting imported raw materials into products meeting Chinese origin standards through process improvements, not only resolving certificate issues but also obtaining an additional 13% tariff preference
Conclusion
Handling origin issues for mixed cargo requires the rigor of solving a chemical equation. Companies are advised to establish a completeOrigin management systemIncluding full-process control of raw material traceability, processing records, certificate management, etc. When encountering complex situations, it is advisable to consult professional customs brokers or law firms, as their advice can often help you avoid potential legal risks. After all, in international trade, compliant operation is the path to long-term success.