Proof of origin: trade continuity agreements and GSP

Rules of origin requirements for traders if the UK leaves the EU with no deal.


Read this guidance to understand how to continue to access preferences where the UK has agreed trade continuity arrangements with partner countries, or through the UK’s Generalised Scheme of Preferences (GSP).

Further advice will be published when the UK leaves the EU.

Trade agreements

Where this guidance applies

The UK is in the process of transitioning existing trade agreements which the UK participates in as a member of the EU. Where the UK and partner countries have brought continuity agreements into effect, you will continue to need proof of origin to access preferential market access opportunities.

Where the UK has not yet agreed continuity agreements on exit day, trade will take place on WTO terms. In these circumstances, formal proof of origin would only be required in limited circumstances.

Rules of origin

The rules of origin in transitioned agreements will enable businesses in the UK and the trading partner to continue to operate as much as possible through their established value and supply chains, including continuing to make use of EU content in their exports to one another.

The proof of origin required under transitioned agreements is as similar as possible to those used in the previous EU agreement. Different trade deals permit different types of proof to be submitted to demonstrate the origin of goods. This may include a certificate of origin in a particular format (such as EUR.1 or EUR-MED) or a declaration on an invoice.

Further detailed guidance on rules of origin will be published when the UK leaves the EU.

Certificates of origin

Where continuity agreements are in place, updated certificates of origin will be available immediately after the UK has left the EU from your usual provider, for example chambers of commerce. Certificates will look very similar to those currently in use, though will show the UK as the place of origin rather than the EU.

Goods in transit and retrospective certificates of origin

If you expect goods to be in transit when the UK leaves the EU, you may need to obtain a retrospective certificate of origin. This will be in the style of the updated certificate, showing that the goods originated in the UK and are eligible for preferential terms if your goods arrive on or after exit day. Retrospective certificates of origin will be available from your usual provider when the UK leaves the EU.

If you do you not have a retrospectively issued certificate of origin at the time that your goods arrive, an EU certificate might be accepted by the local customs authorities in the country of delivery as a transitional measure. However, until such confirmation is given, it is safer to assume that EU Certificates of Origin issued before exit will not be accepted.

Importing under continuity agreements

If you are importing to the UK under continuity agreements, the UK will continue to accept the same types of proof of origin from trading partners as today. However, there may be minor changes in how you complete proofs of origin.

We will publish further advice when the UK leaves the EU.

Generalised Scheme of Preferences

The UK will implement its own independent Generalised Scheme of Preferences (GSP) scheme from day one if we leave the EU with no deal. It will have its own administration arrangements, but aims to keep much of the existing administration arrangements as the EU.

To ease the transition, the UK will keep the same qualifying operations as the EU’s rules of origin, and will continue to use FORM A as proof of origin.

The UK will not be able to use the EU’s Registered Exporter Scheme (REX). To help transition goods arriving into the UK, up to 12 months after the date the UK leaves the EU, HMRC will allow GSP exporters to use the REX statement on origin as proof that goods originate from a GSP country. That statement on origin must hold the valid REX registration number of the exporter, and be dated no later than 12 months after the date the UK leaves the EU.

Published 10 April 2019