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Posted Fri, 24 Mar 2023 16:14:22 GMT by LL
Are the first 2 initials from a REX Number sufficient to show that's the country of origin?
Posted Sat, 25 Mar 2023 14:07:43 GMT by Customs oldtimer
Hi LL No - the first two initials show which EU country issued the REX number to the exporter. The commercial document must have the required statement on EU origin containing the REX number. There is also still a requirement to actually state the country of origin against item lines on the commercial invoice. In practice as an example a Company with a German REX number could declare goods of Spanish, French , Dutch origin etc.
Posted Mon, 27 Mar 2023 08:13:07 GMT by LL
Thanks Customs oldtimer........ I am in agreement with what you have said. However, if someone (and importer or carrier) were to suggest that the REX number were indeed sufficient to show country of origin when questioned, which guidance could I direct them / me to?
Posted Mon, 27 Mar 2023 14:10:01 GMT by HMRC Admin 17

Hi,
 
The number must start with two uppercase letters (the ISO code of the country) followed by 'REX' fixed string and
a maximum of 30 alphanumeric uppercase characters (minimum 1 character)  .

Thank you.
Posted Mon, 27 Mar 2023 14:14:41 GMT by LL
Yes thank you - I am aware of this. If a REX number is not sufficient to prove origin (First 2 letters) then please direct me to the guidance that shows that an actual country of origin is required to be stated, thank you
Posted Mon, 27 Mar 2023 19:44:40 GMT by Customs oldtimer
You do need the REX number quoting in the statement on EU preferential origin. It is however not physically possible (since Feb2023) to declare EU as a country of origin. To quote from HMRC guidance on proving preferential origin - DE 5/16 Must be completed with the country of preferential origin. There are however some notes to DE5/16 in volume 3 of the tariff suggesting that in the absence of specific country of origin the EU country of origin could be the one that issued the REX could be used which I assume your original question stems from. This is not reflected in any part of the TCA or UK legislation I am aware of. Perhaps HMRC can shed some light on this. As the responsibility of claiming of the preferential duty rate falls to the importer it is for them to decide whether the declaration on origin and other import details provided by the supplier are sufficient at the time of import. It is also a standard commercial invoice requirement to include the correct country of origin of the goods. The non preferential origin of goods is also declared in DE 5/15. Try looking on the Europa website for the EU definition of the REX registration purpose and use.
Posted Tue, 28 Mar 2023 08:17:17 GMT by LL
Thanks Customs Oldtimer. I agree with everything you are saying. I have had it put to me that the COO is not required on an invoice and that the REX initials are sufficient from a customs entry point of view. I am just looking for guidance to support that this is or is not correct, but as you say, the responsibility is on the importer to support this as their claim for preference. I was also unaware of this so thankyou - " in the absence of specific country of origin the EU country of origin could be the one that issued the REX could be used". I can see that the REX system can be used by producers or traders which leads me to believe that the first 2 initials of the REX will, in some cases, not relate to the COO at all - which then contradicts the ability to use the first 2 inititals as the COO.
Posted Tue, 28 Mar 2023 10:25:28 GMT by Customs oldtimer
Hi LL I would agree that using the REX registration initials for a purpose other than intended is a high risk approach. It is clear that the first two initials are there only to indicate the country that issued the registration. The same approach applies to all customs authorisations such as an Inward processing or Outward processing, which no one would consider as having any bearing on goods origin. Whilst the EU- UK agreement is new the principles are not, nor are the basic requirements for a commercial invoice, which includes country of origin. Items on an invoice may have different countries of origin whereas the REX statement only refers to general EU origin that may or may not apply to the individual items. It therefore has no logic that the REX country of issue could possibly confer any specific origin. The . Gov website did have something on the content of a commercial invoice but as is typical I cannot locate it at the moment . Something similar is on the Europa website. https://trade.ec.europa.eu/access-to-markets/en/content/customs-clearance-documents-and-procedures
Posted Tue, 28 Mar 2023 10:36:39 GMT by LL
Thanks - I will take a look :)
Posted Wed, 29 Mar 2023 09:25:02 GMT by LL
Hi Customs oldtimer - I found this this morning which clears up any confusion (I think) : https://www.gov.uk/government/publications/cds-uk-trade-tariff-volume-3-import-declaration-completion-guide/group-5-dates-times-periods-places-countries-and-regions#data-element-5-15 For All Declaration Categories: For imports originating from EU Member States, where the individual Member State is unknown, it is acceptable to enter any Member State involved in the production of the goods. The Member State may be identified through the accompanying commercial documentation or the Registered Exporter system (REX) code on a ‘statement on origin’. Please note, this only applies to entries on UK custom declarations: the origin stated on the proof of origin must be at the group of country level. For example, a ‘statement on origin’ made out under the UK-EU Trade Cooperation Agreement should be completed in accordance with Annex 7 of that agreement and refer to ‘the Union’ as the preferential origin of the goods.
Posted Wed, 29 Mar 2023 10:43:34 GMT by Customs oldtimer
Hi LL Yes that was the guidance I was referring to but was unable to add the link.

no question.
Posted Thu, 30 Mar 2023 13:29:15 GMT by HMRC Admin 10
Hi LL
I would review :
DE 5/15 Country of Origin (Box 34(a): Country of Origin Code)
Thankyou.
Posted Fri, 14 Apr 2023 05:48:57 GMT by lisa Stewered
For imports originating from EU Member States, where the individual Member State is unknown, it is acceptable to enter any Member State involved in the production of the goods. The Member State may be identified through the accompanying commercial documentation or the Registered Exporter system (REX) code on a ‘statement on origin’. Please note, this only applies to entries on UK custom declarations: the origin stated on the proof of origin must be at the group of country level. For example, a ‘statement on origin’ made out under the UK-EU Trade Cooperation Agreement should be completed in accordance with Annex 7 of that agreement and refer to ‘the Union’ as the preferential origin of the goods. [link removed by admin]

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