UK DCTS origin declaration vs EU REX: what’s different for garment importers

The UK doesn’t use the EU’s REX system. Under the UK’s Developing Countries Trading Scheme (DCTS), the exporter writes an origin declaration on the invoice in the UK’s own wording and signs it, and the UK importer uses that, or a Form A, to claim preferential duty, which is 0% for Nepal-made garments. No REX number is required, no value threshold applies, and the declaration is valid for two years rather than the EU’s twelve months.

The two texts look alike, which is why they get mixed up. Here is what differs, and what we send for each market.

The UK origin declaration wording

GOV.UK’s guidance Using an origin declaration for the DCTS sets out the text:

The exporter of the products covered by this document (customs identification number …(1)) declares that, except where otherwise clearly indicated, these products are of …(2) preferential origin in accordance with the rules of origin of the Developing Countries Trading Scheme of the UK and that the origin criterion met is … …(3). (Place and date (4)) (Name and signature of the exporter)

The footnotes explain each gap:

1. Customs identification number: “if allocated”. The UK doesn’t prescribe a REX number here. We can quote our REX number in this bracket if you or your broker find it useful — it’s an identifier you can check on a public database — but the UK doesn’t require it.
2. Origin: the country of origin, e.g. Nepal.
3. Origin criterion: “P” for wholly obtained, or “W” followed by the HS heading for products sufficiently processed. The rule is the same as the EU’s, so garments from imported fabric are “W”, e.g. W 6109 for T-shirts.
4. Place and date: can be left out if the document already shows them.

The declaration must be in English, must bear the exporter’s signature (and be in ink if handwritten), and may be sent to the importer electronically.

The 18 data elements

This is the part EU-focused suppliers most often miss. GOV.UK requires the invoice or commercial document carrying a UK origin declaration to include:

exporter’s name and business address; date of direct shipment to the UK; other references such as the PO number; consignee’s name and business; purchaser’s name and address (if different); country of transhipment; country of origin; transport details; terms of sale; currency; number of packages; specification of commodities (marks, numbers, description); quantity; unit price; total price; net weight; gross weight; invoice total.

A normal export commercial invoice from us already carries these fields. For how a proper export invoice is built, see proforma vs commercial invoice.

Form A is still an option in the UK

HMRC’s page How to claim preferences under the DCTS lists two proofs of origin: an origin declaration, or Form A. It adds that the UK does not require Form A to be stamped by the exporting country’s customs authority. That is different from the EU, where Form A hasn’t been accepted for GSP since the REX changeover (for Nepal, after 30 June 2018). In practice the invoice declaration is simpler, and it’s what we supply.

EU REX vs UK DCTS, side by side

Record keeping

Exporter: HMRC’s DCTS guidance says exporters must keep production records for three years and be ready to produce invoices, accounts and suppliers’ declarations if the UK verifies a claim. The EU requires registered exporters to keep their records for at least three years from the end of the year the statement was made out.

UK importer: GOV.UK’s general rule is to keep import records, including proof of origin, for four years. See Archiving your trade documents. If you didn’t claim preference at import, HMRC can grant it retrospectively if you claim within two years of importation and hold a valid origin declaration.

One invoice for mixed EU and UK orders?

We don’t recommend it. EU and UK goods normally go as separate consignments to separate consignees, and the UK declaration asks for the date of direct shipment to the UK. Each invoice should carry the one text that applies at its destination. The mistake we see most often is an EU statement on a UK invoice, or the reverse. Both are easy to avoid if each invoice is prepared for its own market.

After Nepal’s LDC graduation

Nepal is scheduled to graduate from least-developed-country status on 24 November 2026, with a deferral request pending at the UN. The UK has confirmed a three-year DCTS transition for graduating countries. Since 1 January 2026, the UK’s Enhanced Preference tier has used the same garment rules of origin (Chapters 61 and 62) as LDCs, so single transformation still applies after a move between tiers. The origin declaration doesn’t change. Our duty status page tracks the current position, and UK buyers has the market-specific detail.

This is a practical comparison, not legal advice. Your customs broker can confirm how the claim is entered in the Customs Declaration Service.

What we supply

• UK shipments: a signed DCTS origin declaration on the commercial invoice, with all 18 data elements.
• EU shipments: the Annex 22-07 statement on origin with our REX number. You can see and check the number on our REX Trust Centre. More in EU buyers.

Shipping from Nepal is covered in shipping from Nepal (FOB Kolkata by sea, FCA Kathmandu by air). Tell us which market you’re importing into and we’ll send a sample invoice with the right text on it.