Customs and Compliance

What Is a Certificate of Origin, How Is It Obtained? Difference from EUR.1

Short answer

A certificate of origin proves in which country goods were produced, or underwent their last substantial working, and is a non-preferential origin document filled in by the exporter and approved by an authorised chamber. On its own it does not produce a customs duty reduction; it establishes origin so the importing country can apply the correct rate, anti-dumping duty and trade policy measures such as quotas. Origin is the country where the goods were produced, not the country from which they were shipped.

Updated: August 24, 202610 min read

In international trade, the identity of a product consists of two separate pieces of information: what it is and where it is from. The first is stated by the GTİP (Turkish HS/tariff code); the second, by origin. A certificate of origin is the document that proves this second piece of information.

What exactly a certificate of origin documents

A certificate of origin (menşe şahadetnamesi, also called CO) is a document declaring the country in which goods were produced, approved by an authorised body. The exporter fills it in, the chamber approves it, and it is presented to the customs administration of the destination country.

The document answers a single question: where is this product from? Which port the goods were shipped from, which country’s bonded warehouse they waited in, or which country’s company issued the invoice does not change this answer. Country of origin and country of dispatch (shipment) are two independent pieces of information. Goods of Chinese origin remain Chinese-origin even if shipped from a Rotterdam warehouse.

A second clarification: a standard certificate of origin is a non-preferential origin document and, on its own, produces no reduction or exemption in customs duty. Under some preferential agreements, the proof required is not EUR.1 but a form of certificate of origin specific to that agreement; that is a separate document. In addition, presentation of the document may be required for the correct rate to be applied on import.

What consequences origin information produces

Origin is one of the inputs that determines how the importing country treats the goods. In concrete terms, it affects:

  • The applicable duty rate. The rate is a value jointly determined by the GTİP and the origin. The same GTİP can produce a different rate for a different origin.
  • Anti-dumping and countervailing duties. As a rule, these duties apply to a product-origin pair, and often at rates that differ by exporting company. If the measure is being circumvented, the duty can also be extended to goods shipped through, or assembled in, third countries.
  • Tariff quotas and quantity restrictions. These are tracked on the basis of origin.
  • Safeguard measures and surveillance. As a rule, safeguard measures apply to all origins; only quota allocation may be split by country. Import surveillance in Türkiye is mostly tied not to origin but to a CIF unit-value threshold. In either case, verification of the declared origin may be requested.
  • Bans and restrictions. Import of goods of a certain origin may be restricted.
  • Public tenders and procurement specifications. In procurement requiring local content or a specific origin, the document becomes a direct eligibility factor.

For this reason, origin is not “a formality field,” but data that changes the amount of duty and whether the goods can even enter the country.

Preferential origin, non-preferential origin, and the difference from EUR.1

Origin rules operate as two separate families, and confusing this distinction leads to the wrong document being issued.

Non-preferential origin is determined according to general rules. It is the basis for the duty rate, trade policy measures and statistics. Its proof is the certificate of origin.

Preferential origin is determined according to rules specific to a free trade agreement or a preferential regime. Its purpose is to apply a reduced or zero duty rate. Its proof consists of documents such as EUR.1, EUR-MED, or an invoice/origin declaration.

The difference between EUR.1 and a certificate of origin comes down to four points:

  • Purpose. A certificate of origin establishes origin; EUR.1 activates the preferential tariff.
  • Rule. EUR.1 requires proof that the goods satisfy the agreement’s list rule (such as a change in tariff heading or a maximum foreign-input ratio); a certificate of origin applies the general rules.
  • Scope. EUR.1 only works for countries party to the agreement; if there is no agreement, or the list rule is not satisfied, it cannot be issued, whereas a certificate of origin can still be issued.
  • Outcome. The two determinations are made separately; the preferential and non-preferential origin of the same product can come out as different countries.

How origin is determined

Two basic criteria are used for non-preferential origin. In Türkiye their framework is set by the Customs Code and secondary legislation.

1. Wholly obtained goods. The case where production takes place entirely in one country: minerals extracted, crops grown, animals born and raised, products caught, and things obtained from these, all within that country. Origin is unquestionably that country.

2. The last substantial and economically justified working or processing. Where more than one country is involved in production, origin is the last country in which the goods underwent an operation of this nature. The criterion is that the operation results in the manufacture of a new product or constitutes an important stage of manufacture; either of these being satisfied is sufficient.

The legislation also separately lists operations that do not on their own confer origin. Packaging, bottling, labelling, sorting, classifying, simple mixing and simple assembly fall into this group. A product’s final assembly having taken place in Türkiye does not automatically make it Turkish-origin; what matters is the nature of the assembly and the new identity the product acquires.

Which document proves what

Document What it proves Provides a duty advantage Scope and condition of use
Certificate of origin Non-preferential origin No, does not on its own produce a reduction General trade; requested by the buyer or destination customs
EUR.1 / EUR-MED Preferential origin Yes, if the agreement’s list rule is satisfied Countries with a free trade agreement
Invoice declaration / origin declaration Preferential origin Yes, under the same condition No value limit for approved/registered exporters; below a per-shipment value threshold for others (EUR 6,000 under PEM)
Form A Preferential origin under GSP Yes, in the country accepting it Superseded in the EU and in Türkiye by the registered exporter (REX) declaration
A.TR Free circulation status Yes, for goods within customs union scope Türkiye–EU customs union

Table notes: A.TR is used for industrial products and the industrial component of processed agricultural products; agricultural products and coal-and-steel (ECSC) products require EUR.1 for exports to the EU. The invoice declaration threshold and the REX transition timetable are set by legislation and should be confirmed before shipment.

The last row of the table is the most frequently confused: A.TR is not a certificate of origin. It provides duty exemption for goods within customs union scope; it does not show where the goods are from.

How the certificate is obtained: application, approval and responsibility

The document is filled in by the exporter; approval is given by the chamber of commerce and industry of which the exporter is a member. The sequence is:

  1. Determining origin and its basis. An exporter that does not manufacture the goods itself obtains a written manufacturer’s declaration of origin; this is the basis relied on in any subsequent verification.
  2. Preparing the content. Shipper, consignee, description of goods, quantity and country of origin are filled in consistently with the invoice and the transport document.
  3. Application to the chamber. Applications are largely made electronically; approval is granted through the system, and the printed copy is based on this. The chamber requests the invoice and the basis for origin.
  4. Approval and endorsement. For a certificate of origin, chamber approval is sufficient. For movement certificates such as A.TR and EUR.1, customs endorsement is also required after chamber approval.
  5. Further legalisation. Some destination countries require additional legalisation, such as consular approval; the requirement varies by country and may not be completable after the fact.

A fee is charged for the document according to the chamber’s tariff; the amount varies by chamber and year and should be confirmed from the current tariff. If the application is complete, approval is completed quickly; the original copy goes to the buyer, and a copy is kept on file.

An easily overlooked point: the chamber approves the declaration, it does not audit production. The exporter is responsible for the accuracy of the declaration.

Why the buyer and destination customs ask for the certificate

  • Because their own customs administration requires it. Many countries treat proof of origin as an import condition for certain product groups.
  • Because it is a letter-of-credit condition. If the document appears in the document list, the description of goods on the certificate of origin must not conflict with the description in the letter of credit; under UCP 600 Article 14(e), documents other than the invoice may use general wording, and an exact match is not required. However, if the issuing authority is specifically named in the letter of credit (such as a chamber of commerce or a consulate), that condition must be satisfied exactly.
  • Because it is a tender or contract condition.
  • To close off the risk of a trade policy measure. The buyer wants to see in advance that it will not face anti-dumping duty on import.
  • For compliance and sanctions screening. Companies checking restrictions related to certain origins keep this document on file.

The import side is also regulated. For goods subject to additional customs duty, an extra financial obligation, or a trade policy measure, presentation of a certificate of origin may be required under the Customs Regulation; if the document is not presented, the administration may apply the higher rate under the measure. Scope and procedure are set by legislation and may change, and should be confirmed before declaration. The administration may initiate post-clearance control (origin verification) after declaration; a manufacturer’s declaration, production records and input invoices may be requested. Origin that cannot be verified results in a duty shortfall and a penalty.

Pre-shipment checklist and points of attention

  1. Determine the origin. Were the goods wholly obtained, or in which country did they undergo their last substantial working? The GTİP tells you what the goods are, not where they are from.
  2. Obtain the manufacturer’s declaration in writing. Origin based on a verbal statement has no basis if verification is later requested.
  3. Separate the country of dispatch from origin. Shipment from a bonded warehouse, a free zone, or an intermediary country does not change origin; only the place of dispatch changes.
  4. If there is assembly, apply the criterion correctly. Simple assembly does not on its own confer origin; what matters is whether the operation creates a substantial change. If the list rule specifies a value-added or tariff-heading-change criterion, that must be checked separately.
  5. Choose the right document. If a duty reduction is the goal, EUR.1, EUR-MED, or an origin declaration (if the conditions are met) is required; a certificate of origin does not substitute for these.
  6. Ask about any further legalisation requirement before the goods depart.
  7. Cross-check the letter of credit’s document requirements. The required issuing authority and number of copies must be met exactly as stated in the letter of credit. Descriptions of goods across documents must not conflict with each other; under UCP 600 Article 14(d), the data need not be identical, but a conflicting description is grounds for a discrepancy.
  8. Apply to the chamber before loading. As a rule, the document can also be issued retrospectively, marked “issued retrospectively.” However, some destination countries do not accept a retrospectively issued document or require an additional explanation; delay produces storage and demurrage costs.
  9. Keep the file. Post-clearance control can come long afterward; the manufacturer’s declaration and production records are the document’s only basis.

This page is general information, not legal advice. Regulations change; confirm the current position before acting.

FAQ

  • If a EUR.1 already exists, is a certificate of origin still needed?

    It may be. EUR.1 proves preferential origin and activates the reduced duty rate; a certificate of origin shows non-preferential origin. If the buyer, the destination customs office or the letter of credit separately asks for proof of origin, both documents are issued together. If there is no agreement, or the goods do not satisfy the agreement's list rule, EUR.1 cannot be issued, whereas a certificate of origin still can be.

  • Can a certificate of origin be issued retrospectively after loading?

    As a rule, yes; the document is marked "issued retrospectively." However, some destination countries do not accept a retrospectively issued document or require an additional explanation, and a letter of credit may also carry a condition on the document date. Since delay results in waiting at customs and storage and demurrage costs, the application should be made before loading.

  • In which cases is a certificate of origin required on import?

    For goods subject to additional customs duty, an extra financial obligation or a trade policy measure, presentation of the document may be required under the Customs Regulation; without it, the administration may apply the higher rate under the measure. Scope and procedure are set by legislation and may change, and should be confirmed before declaration. The administration may verify origin through post-clearance control after the declaration.

  • Must the description of goods on the certificate of origin match the invoice word for word?

    No. Under UCP 600 Article 14(e), documents other than the invoice may describe the goods in general terms, provided they do not conflict with the letter of credit; under Article 14(d), data in documents need not be identical to each other. A conflicting description, however, is grounds for a discrepancy. If the letter of credit specifically names the issuing authority, that condition must be met exactly.

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