Statement on origin wording, explained line by line

The EU GSP statement on origin is a fixed paragraph, set out in Annex 22-07 of Commission Implementing Regulation (EU) 2015/2447. The exporter types, prints or stamps it on the invoice or another commercial document, filling in three things: its REX number, the country of origin, and the origin criterion. For Nepal-made knitwear that means the exporter’s NPREX number, “Nepal”, and “W” followed by the HS heading, such as W 6109 for T-shirts. It doesn’t need a signature, and it is valid for 12 months.

Most refused preference claims we hear about come down to small errors in this paragraph, so here it is line by line.

The official text

This is the English version exactly as it appears in Annex 22-07 (Official Journal extract):

The exporter … (Number of Registered Exporter) of the products covered by this document declares that, except where otherwise clearly indicated, these products are of … preferential origin according to rules of origin of the Generalised System of Preferences of the European Union and that the origin criterion met is … …

The annex also gives official French (“L’exportateur … des produits couverts par le présent document déclare que…”) and Spanish (“El exportador … de los productos incluidos en el presente documento declara que…”) versions. Under Article 92 the statement must be made out in English, French or Spanish. A German or Dutch translation is not valid, however carefully it’s done.

The annex adds a line above the text: the statement is to be made out on a commercial document “showing the name and full address of the exporter and consignee as well as a description of the products and the date of issue”. Those details come from the invoice itself, so the invoice has to carry them.

Filling in the gaps

Here is how the three blanks would be completed on a Nepal-to-EU invoice for T-shirts:

Put together, the completed English text reads:

The exporter NPREX0000000000 of the products covered by this document declares that, except where otherwise clearly indicated, these products are of Nepal preferential origin according to rules of origin of the Generalised System of Preferences of the European Union and that the origin criterion met is W 6109.

The REX number

Once the originating goods in the consignment are worth more than €6,000, the exporter must be registered and the REX number must appear here. Below €6,000 any exporter can make out the statement, registered or not. You can check the number yourself. We explain how in how to verify a supplier’s REX number.

The country of origin

This is the country where the goods obtained origin under the GSP rules, not simply the country they shipped from. For garments cut and sewn in Nepal, that’s Nepal.

The origin criterion: “P” or “W”

Footnote 6 of the annex defines the two options:

• “P” is for products wholly obtained: nothing imported went into them (think minerals or crops grown locally).
• “W” is for products sufficiently worked or processed, followed by the Harmonised System heading, for which the annex gives the example “W” 9618.

A garment sewn from imported fabric is never “wholly obtained”, so it is always “W”. It qualifies because, for least developed countries, the EU’s product-specific rules in Annex 22-03 treat cutting and sewing fabric into garments as enough (the single-transformation rule; see single vs double transformation). The heading is the four-digit HS heading of the finished product: 6109 for T-shirts, 6105 for men’s knitted shirts including polos, 6110 for sweatshirts and hoodies. If you’re unsure of the code, see our HS code guide for knitwear.

Mixed invoices. If one invoice covers T-shirts and hoodies, the criterion differs by item. The Commission’s REX guidance suggests writing the criterion next to each line and putting “as indicated next to the items of the commercial document” in the statement.

Cumulation mentions

If the goods rely on cumulation, for example EU-origin fabric (“EU cumulation”) or regional cumulation with other South Asian beneficiaries (“regional cumulation”), the criterion is replaced with the matching indication from the annex. For Nepal-made knitwear from Chinese fabric, no cumulation mention applies. The garment originates through single transformation on its own.

Where and how it can appear

• Document: usually the commercial invoice. A proforma, delivery note or packing list is also acceptable if it identifies the exporter and describes the goods. Bills of lading and airway bills are not, because the carrier issues them.
• Method: typed, printed or stamped. A label is acceptable only if it’s clear the exporter or invoice issuer attached it.
• Pages: if the document runs to several pages, number each one and state the total.
• Signature: not required. Article 92(3) says the exporter “shall not be required to sign the statement on origin”.
• Date: the invoice’s date of issue is normally the statement’s date. If the statement is made out on a different date, for example retrospectively, show that date next to it.

Validity

A statement on origin is valid for 12 months from the date it was made out. If it wasn’t issued at export, it can be made out retrospectively, as long as it is presented to customs in the member state of import within two years of importation.

Mistakes that get preferences refused

• Using “P” for garments. Imported fabric means “W”.
• Missing or mistyped REX number on a consignment over €6,000.
• Old Form A wording, or wording that leaves out “of the European Union”.
• UK wording on an EU invoice, or the other way round. The UK text refers to the Developing Countries Trading Scheme. See UK DCTS vs EU REX.
• A translated statement in a language other than English, French or Spanish.
• Statement on the bill of lading instead of a commercial document.
• Non-originating items not marked, such as bought-in accessories sold as separate lines.
• Out-of-date statement, more than 12 months old at import.

This is practical guidance, not legal advice. Your customs broker can confirm how the claim is entered in your country. For the basics, start with what is a REX number, and see how the documents fit together in proforma vs commercial invoice.

Ours

We put the statement on origin on every EU commercial invoice, and on the proforma too if your broker wants to review it before shipment. You can see and check our REX number on the REX Trust Centre, or ask us for a sample invoice.