What are the Origin Determination Standards for Processing and Re-export Trade in 2026?
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I am the business manager of a trading company specializing in re-exporting raw materials from Southeast Asia to Europe. Recently, when handling a batch of natural rubber from Malaysia re-exported to Germany, the Form A Certificate of Origin submitted by our customs broker was deemed "origin information inconsistent with logistics track" by the customs.
We completed simple processing (only cutting and grading) in the Shanghai Free Trade Zone, but the customs system prompted us to fill in the "processing location" instead of the "raw material origin", resulting in 3 days of port detention and a container detention fee of 20,000 yuan. Now our finance department requires strict consistency of four flows, and we have the following questions: Does the origin of processing and re-export trade refer to the country of raw material production or the place where processing is completed?
Are there new origin rules under the RCEP framework in 2026? How to avoid the risk of customs detention caused by incorrect origin declaration?
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
In 2026，origin determination for processing and re-export trade follows the dual-track standard of "substantial transformation + digital verification"，with the full workflow breakdown as follows:
1. Pre-document Verification Details: Enterprises must focus on verifying the filling specifications of Certificates of Origin (CO/Form A/Form R). In 2026，the General Administration of Customs issued the new，requiring enterprises to independently declare origin data via the "Single Window". Form A must include the "processing value-added rate" (a value-added rate of ≥30% in free trade zones qualifies as "Made in China")，and must fully align with the processing procedures filed in the .
2. Core Node Coordination: Origin data must form a closed loop with logistics tracks. If only simple repackaging (without altering the goods' form) is conducted at a transshipment port (e.g。Singapore)，the origin is still based on the processing location. However，the 2026 new requires transshipment ports to mark "no substantial processing" on bills of lading，otherwise，the goods may be deemed "originating from a third country". It is recommended that enterprises apply for the simultaneously during transshipment to clarify the division of rights and responsibilities between the processing location and transshipment port.
3. Emergency Response Plan: If customs detention occurs due to incorrect origin declaration，immediately activate the "Green Channel for Origin Correction" and submit the along with processing records (including raw material import declarations and processing procedure records) via the Single Window. Customs will complete review within 48 hours. In emergency cases，a "Temporary Certificate of Origin" can be applied for，but official documents must be supplemented within 7 working days to avoid additional fines from prolonged port detention.
4. Compliance Implementation: Enterprises need to establish an origin information management system，synchronize in real time with the General Administration of Customs' "Origin Rules Database"，and conduct monthly self-inspections on the matching degree between HS codes and Certificates of Origin. Focus on verifying whether the "processing value-added rate" and "origin standards" meet the "tariff classification change" or "regional value content" requirements under RCEP，ensuring full consistency with export tax refund audit data.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Chief Customs Declaration Expert: Special attention should be paid to the "consistency between HS codes and Certificates of Origin" in processing re-export origin declaration. In 2026, the customs document review system added an intelligent verification module for "HS Code - Origin Rules".
If a enterprise declares rubber products under HS code 4001 (natural rubber) while the Certificate of Origin shows "processed in China", the system will automatically check whether the processing value-added rate exceeds 30%. It is recommended that enterprises use the "Customs Classification Pre-determination System" to confirm the matching between HS codes and origin rules before declaration.。
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Senior Logistics Expert: Logistics tracks are key evidence for origin determination. If goods are shipped from Malaysia to Shanghai for processing then re-exported to Europe, ensure that the "transshipment port" on the bill of lading matches the. In 2026, RCEP added the "Direct Transshipment Port Exemption Clause": if the transshipment port is within ≤150 nautical miles of the processing location and no deconsolidation or reorganization is conducted, the origin can be directly proven by the ocean bill of lading; otherwise, an additional is required.。
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
Senior Tax Consultant: VAT deferral for processing and re-export trade must be based on the Certificate of Origin. Incorrect origin determination leading to failed VAT deferral may result in a tax difference loss of 20%-25%.
In 2026, the "Origin VAT Compliance Self-inspection Tool" was launched, allowing enterprises to calculate VAT differences under different origin rules. It is recommended to prioritize "originating from processing location" to enjoy the 13% tax rate preference, instead of the 17% tax rate for "originating from raw material location".。
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
Trade Compliance Expert: Strict implementation of the three-document matching of "Certificate of Origin - Foreign Exchange Collection - Tax Refund" is required in foreign exchange settlement and payment. In 2026, the State Administration of Foreign Exchange requires banks to verify the QR code information on Certificates of Origin during settlement. If foreign exchange collection is suspended due to incorrect origin declaration, enterprises must submit the within 5 working days, otherwise they may be included in the foreign exchange bureau's "Key Monitoring List".。
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
Foreign Trade Legal Expert: The Certificate of Origin serves as the legal basis for transfer of goods ownership. Failure to clearly mark the processing location may lead to ownership disputes. In 2026, the added the "Endorsement Clause for Certificate of Origin": enterprises must stamp "Originating from Processing Location" in Column 5 "Endorsement Column" of the Certificate of Origin, otherwise third parties cannot claim ownership based on it.。
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
On-site Inspection Expert: Customs will focus on verifying "processing procedure records" during inspections. It is recommended that enterprises prepare the (marking raw material import time, processing duration, and value-added procedures) in advance. In 2026, "Blockchain-based Storage of Processing Procedures" was introduced, allowing enterprises to retrieve stored data in real time to avoid inspection delays caused by inability to provide processing records.。
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
Special Packaging Engineer: For dangerous goods (e.g., chemical raw materials), both the "hazard category" and "origin" must be marked on packaging.
The 2026 UN 38.3 packaging standard requires dangerous goods packaging to be consistent with information on the Certificate of Origin; otherwise, it may be deemed "non-compliant packaging". It is recommended to use dual marking of "origin + processing location" on packaging.。
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
Export Tax Refund Audit: When applying for tax refunds, ensure the origin information of "export declaration - Certificate of Origin - VAT invoice" is fully consistent. In 2026, the State Taxation Administration added intelligent verification for "consistency of four flows". If the Certificate of Origin shows "processed in China" but the invoice shows "originating from Malaysia", the system will automatically trigger a tax refund doubt inspection, and enterprises must submit the within 15 working days.。