Supplier's Declaration of Origin – Types, Template and Role in UK–EU Trade

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What is a supplier's declaration?

A supplier's declaration is a document in which the supplier of goods or material informs its customer (for example a manufacturer or exporter) about the origin status of the goods supplied – whether they originate in the European Union within the meaning of the rules of origin, or not. The supplier itself usually does not export the goods outside the EU, but its statement is an essential piece of the puzzle when the final exporter has to prove the origin of a product made up of many components. The rules for drawing up declarations are set out in Commission Implementing Regulation (EU) 2015/2447 (Articles 61–62 and Annexes 22-15 and 22-16).

Types of supplier's declaration

Single declaration

It is drawn up for a specific consignment of goods (Article 61 of Implementing Regulation (EU) 2015/2447) and attached to the invoice, delivery note or another commercial document relating to that delivery. It can also be issued after the delivery has been made. The template for goods with preferential origin status is in Annex 22-15.

Long-term declaration

Where a supplier regularly delivers goods of uniform, predictable origin status to a given customer, it may draw up one long-term declaration covering all successive consignments in a given period – covering a period of no more than 24 months from the starting date (Article 62 of Implementing Regulation (EU) 2015/2447). The starting date may fall up to 12 months before or up to 6 months after the date the declaration is issued. The template for goods with preferential origin status is set out in Annex 22-16. If the declaration ceases to be valid for some or all of the goods supplied, the supplier must inform the customer immediately.

Content of the declaration

A supplier's declaration should contain at least: the details of the supplier and the customer, a description of the goods that allows them to be identified, an indication of the origin status (originating or non-originating in the EU within the meaning of the specific preferential trade agreement), the place and date of issue and the signature of an authorised person (or its electronic equivalent, if permitted by the customs authority). The document is drawn up on the invoice, the delivery specification or as a separate attachment – the form does not have to be identical to the official template as long as it contains all the required elements.

Role in the UK–EU Trade and Cooperation Agreement (TCA)

The Trade and Cooperation Agreement between the EU and the United Kingdom (TCA) provides for zero tariffs and zero quotas on originating goods, provided that the rules of origin set out in the Protocol on rules of origin are met. Where a product exported to the UK is made up of components bought from different suppliers in the EU, the exporter needs a supplier's declaration from each of them in order to show what part of the value or which materials have originating status. Without these declarations the exporter cannot independently draw up a reliable statement on origin for the purposes of preferential clearance in the UK, and HMRC or an EU authority may challenge the preference applied during a post-clearance check. The separate template of a supplier's declaration provided for in the TCA itself (Annex ORIG-3) is used for cumulation, that is, taking into account materials or processing originating on the other side of the agreement.

Verification and retention

The recipient of the declaration (for example the exporter) should verify its completeness and consistency with the rest of the purchasing documentation, and then keep it together with the origin documentation. In UK–EU trade the exporter must keep documents proving origin for at least 4 years from the date the statement on origin was drawn up (TCA); national rules (for example the Tax Ordinance) may require longer retention of documents. The customs authorities of both parties to the TCA may ask to see a supplier's declaration as part of verifying the origin of goods.

A practical example

Suppose a Polish machinery manufacturer buys some of its components from a supplier in Germany and imports the rest from outside the EU. To show that the finished machine meets the EU rules of origin and can be exported to the UK at zero duty, the manufacturer must collect long-term supplier's declarations from the German counterparty confirming the EU origin status of the parts supplied. On that basis the manufacturer carries out its own calculation under the rule of origin (for example the change of tariff classification rule or the value-added rule, depending on the CN heading) and only then can issue a statement on origin for the British customer itself.

What are the consequences of a missing or incorrect supplier's declaration?

The absence of a supplier's declaration first of all makes it impossible to issue a reliable statement on origin. If the exporter nevertheless declares preferential origin without such documentation and a post-clearance check shows that the goods did not meet it, the customs authority of the importing country will refuse to apply the preference and require the importer to pay duty at the standard rate together with interest. In extreme cases, where the error resulted from deliberately misleading the authorities, the matter may be examined under criminal fiscal law.

Updates to templates and rules

Commission Implementing Regulation (EU) 2020/2254 introduced a transitional measure concerning supplier's declarations, which applied until 31 December 2021 and has expired – it should not be relied on for current deliveries. At present the templates of supplier's declarations for goods with preferential origin status are set out in Annexes 22-15 and 22-16 of Implementing Regulation (EU) 2015/2447. Businesses should check that the template they use complies with the current wording of those annexes.

Who is responsible for organising the flow of declarations in the company

In medium-sized and larger manufacturing companies the purchasing department is usually responsible for collecting and archiving supplier's declarations, in cooperation with the customs department or an external customs agency. It is good practice to include in contracts with key suppliers a clause obliging them to deliver a current long-term declaration automatically each time the contract is renewed and to inform you immediately of any change in the origin status of the components supplied. Without such a clause the company learns about a problem only when preparing export documentation – often under time pressure, just before shipment.

Supplier's declaration and a post-clearance audit in Poland

When the National Revenue Administration carries out a customs and fiscal inspection at an exporter, it may require all the supplier's declarations on the basis of which the origin of the exported goods was determined, together with purchasing documentation confirming that the goods described in the declaration actually went into production. Discrepancies between the quantity of goods stated in the supplier's declaration and the quantity actually used in the production of exported products are one of the typical findings of an inspection and may lead to the whole batch of statements on origin issued in a given period being challenged.

Supplier's declaration in the context of other EU preferential agreements

The supplier's declaration mechanism is not reserved for UK–EU relations alone – it operates on the same principles in trade with other partners with which the EU has preferential agreements, for example under the Pan-Euro-Mediterranean (PEM) system covering, among others, the EFTA countries, Türkiye and the Mediterranean region. Companies exporting to several regions covered by different agreements at the same time should remember that the rules of origin and the required documentation may differ slightly between agreements – a supplier's declaration prepared with one preferential agreement in mind is not always automatically sufficient to document origin for another.

Declarations in multi-stage chains

In longer supply chains, where goods pass through several intermediaries before reaching the final exporter, each supplier is responsible for the content of the declaration it issues itself. In practice it is worth keeping the full chain of source documents (declarations received from your own suppliers and purchase documents), not just the last declaration – this makes it easier to demonstrate origin during verification.

See also related guides

• Origin of goods – general rules
• UK–EU rules of origin: when they let you avoid duty
• Statement on origin and the REX system

If you are preparing origin documentation for exports to the UK, contact us.

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