Certificate of origin for China: purpose and when it's required

A certificate of origin is a commercial document that attests to a good's country of origin, issued by an authorised third party, a chamber of commerce or competent authority, and not by the seller itself. According to the International Chamber of Commerce (ICC) guidelines on certificates of origin, this document confirms a product's economic "nationality" and serves as a declaration to meet the customs or commercial requirements of the destination country. It replaces neither the commercial invoice nor the bill of lading: it complements them when separate proof of origin is required.

There are two families of certificates. The non-preferential certificate, also called the ordinary certificate, attests to an origin without opening any tariff advantage. The preferential certificate is tied to a trade agreement or a preference scheme and serves as proof for a reduced duty rate. Since China and the European Union are bound by no bilateral free trade agreement, an ordinary Chinese import almost always falls into the first family: a non-preferential certificate of origin, which proves where the product comes from but lowers no duty.

The two answer different questions. Origin marking, the famous "made in", is a physical marking placed on the product or its packaging, decided by the manufacturer and checked by the importing country's customs during an inspection. The certificate of origin is, by contrast, a written document issued by a third-party body, which attests to the same origin independently of what the manufacturer states on the product.

A product can carry an accurate "made in China" marking without any certificate of origin ever having been issued: the vast majority of routine imports do not require one. Conversely, a properly issued certificate of origin does not exempt you from checking the product's physical marking, which remains subject to its own rules. The two obligations are checked separately, and the importer remains liable for both before customs, even when the Chinese factory drafted them both itself.

In customs terms, a good always has a non-preferential origin, used to apply the EU's trade policy measures, quotas, anti-dumping duties, and to compile foreign trade statistics and origin marking. It can, in addition, have a preferential origin if the trade falls under a free trade agreement, an economic partnership or a unilateral EU tariff concession. These two origins each follow their own body of rules, and they do not always coincide for the same product.

For non-preferential origin, the central rule is that of the last substantial transformation: when several countries take part in manufacturing, the origin used is that of the country where the last economically justified working or processing took place, carried out in a business equipped for that purpose and resulting in a new product or a significant stage of manufacture. Mere assembly, repackaging or labelling are never enough on their own to create a new origin.

This is the most widely misunderstood point. Proof of non-preferential origin is, in principle, not required on import into the European Union: such a document, issued in a third country under its own rules, does not bind the customs authorities of member states. The importer may prove origin by any usual commercial means, without having to produce a specific certificate.

The exception lies in a single article: under Article 57 of Implementing Regulation (EU) 2015/2447 of the Union Customs Code, a certificate of origin becomes required on import to benefit from special non-preferential import arrangements. This concerns products for which EU legislation opens a tariff quota and explicitly requires proof of origin in certificate form to access the reduced rate. This certificate is then issued by the competent authorities of the third country, using the standard form in Annex 22-14 of the same regulation.

Steel illustrates this mechanism: the reform of the EU safeguard measure, in force since 1 July 2026, cuts the annual volumes admitted duty-free by around 47% compared with 2024 and raises the out-of-quota duty to 50%. Access to the quota requires verifiable proof of the metal's origin, failing which the full rate applies. Agricultural products under tariff quota follow the same principle. Outside these arrangements, a certificate of origin remains useful on request: customs can ask for it to verify a declaration, as can a client or a bank under a documentary credit.

In China, the China Council for the Promotion of International Trade, the CCPIT, is the main body authorised to issue certificates of origin, both non-preferential ones and most preferential certificates tied to trade agreements signed by China. According to the ICC, the CCPIT is a member of its international accreditation network for certificates of origin, which commits it to applying transparent and accountable verification procedures, aligned with international trade standards.

The Chinese exporting company must first register with the CCPIT or its local branches before it can file an application, then processed online via the organisation's certificate of origin application system. Chinese customs, for their part, issue certain preferential certificates specific to particular free trade agreements. Neither of these two routes is automatic: it is the factory or its export agent that must initiate the process, at the explicit request of the buyer or its freight forwarder, well before the container departs.

The application is filed before shipment, never after: a certificate issued once the goods have left loses much of its usefulness, especially if it must accompany a customs clearance file. The document must describe the goods consistently with the commercial invoice, the packing list and the bill of lading, same quantities, same description, same consignee, since a discrepancy between these documents is the leading cause of holds during a check.

Issuance is moving towards digital. An implementing regulation of the European Commission, in effect since 1 July 2026, opens the possibility of using electronic certificates of origin exchanged via the ELAN system between issuing authorities in third countries and EU customs, for products under special import arrangements. Use of the electronic format remains voluntary during the transition, with paper documents still accepted, ahead of a gradual switch planned from 2028. For certificates issued under Annex 22-14, the validity period is set at twelve months from the date of issue: beyond that, a new document must be requested, even if the goods have not yet been shipped.

Sorva is a brokerage and sourcing house. Our Chinese-speaking team in Guangzhou identifies, as early as the regulatory compliance study, whether your product falls under a special import arrangement that makes the certificate of origin mandatory, and initiates the process directly with the factory or the CCPIT when needed, without waiting until the container is ready to leave.

In most cases you pay no fees: you open a file, we negotiate the merchandise on your behalf and we take a commission on its ex-works value. For a sensitive product, the "Produce and deliver" package includes full document tracking, from the specifications through to delivery, certificate of origin included when your file requires it.