Evaluation of EU Rules of Origin

Rules of origin are used to determine the ‘nationality’ of imports for the purposes of trade and other policies. This evaluation is meant to assess whether the EU’s non-preferential rules of origin (for goods not entitled to tariff preferences) are still fit for purpose in light of current EU policies and decide whether they need to be modernised.

Filed in Italian · English published by the European Commission

Semiconductor companies operate in a global supply & manufacturing chain and worldwide markets, as such are heavily involved in international trade. Simple, clear and business-friendly international trade rules are critical to their competitiveness.The principle of the "last substantial transformation" as defined by WTO is suitable for determining non-preferential origin without requiring complex calculations.

The National Association of the Clothing, Confection and Mode Industries (ANIVEC) welcomes and considers this call for evidence process for an evaluation/fitness check of the rules of origin in force in the European Union (EU) to be of utmost strategic importance.

Filed in Portuguese · English published by the European Commission

The non preferential origin rules as they are written in the union customs code (UCC) are clear. The criteria are clear, the conditions are clear as are the restrictions and exceptions for both articles falling within the annexes as well as guidelines and the precedence set by the European Court of Justice in the past years.

Alcoa wishes to highlight the urgent need for stronger rules of origin in the aluminium industry as the current framework allows for circumvention practices that undermine fair competition, sanctions, environmental accountability and strategic resource tracking.

Shin-Etsu PVC b.v. supports the development of Made-in-Europe criteria; which can help our industry against the dual pressure caused by the current insufficient domestic demand and unfair competition from Chinese overcapacity. More details about the Union rules proposed are listed in the attached file.

EU Rules of Origin (RoO) define the country where a product has been made for customs, trade, and regulatory purposes. Given the high dependence on a single third country in the solar PV supply chain, we see this consultation is a good opportunity to propose changes to the RoO framework with the purpose of mitigating that dependency.

The two companies surveyed, from manufacturing and chemistry, expressed largely convergent concerns about EU rules of origin. Despite a different degree of experience in applying these rules on a regular basis, much less do they face similar difficulties and formulate common expectations. 1.

Filed in French · English published by the European Commission

To strengthen coherence across EU legislation, we recommend that the Unions rules of origin serve as a common reference point not only for origin marking in the context of customs and trade policy, but also for ecolabels, public procurement, and other instruments that will increasingly incorporate Made in Europe as European preference criteria in product legislation as well as purchasing and consumption decisions…

CIRFS is the association for Europes 12.3 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 70% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca.

SMA Solar Technology AG welcomes the opportunity to provide feedback regarding the evaluation of the EUs non-preferential Rules of Origin (RoO). Based on our 44 years of experience and recommendations that align with the objectives with the European and photovoltaic (PV) industry, we would like to highlight several key recommendations that align with the objectives of the Net Zero Industry Act (NZIA, EU 2024/1735).

Filed in German · English published by the European Commission

European Aluminium welcomes the opportunity to contribute to the European Commissions Call for Evidence on evaluating EU non-preferential Rules of Origin (RoO). Under the current non-preferential rules, it is impossible to determine where primary aluminium was originally smelted and cast, creating an information gap that facilitates circumvention of EU sanctions on Russian metal and of the Carbon Border Adjustment…

Today, rules of origin do not reflect the EU’s trade realities or industrial priorities. Overall, they are too complex and neglect the value added at the heart of competitiveness. This creates unnecessary legal and business uncertainty for the German confectionery industry.

Filed in German · English published by the European Commission

CAOBISCO welcomes the opportunity to contribute to the evaluation of EU Rules of Origin. Representing over 14,000 European chocolate, biscuit and confectionery manufacturers (99% SMEs) CAOBISCO stresses that clear, efficient, and future-proof Rules of Origin are essential for maintaining EU export competitiveness and jobs.

Fersa Group (FERSA) is a global industrial and technology group with more than 55 years of experience, specialized in the design and manufacture of advanced bearing solutions for the automotive, industrial, wind energy, rail, and agricultural sectors. The Group employs more than 1,000 people and has a commercial presence in over 100 countries.

As a multinational company with a global supply chain and significant trade flows across the EU and third countries, Inter IKEA Group welcomes the European Commissions initiative to evaluate and modernize the EUs Rules of Origin (RoO).

U.Di.Con. APS welcomes the European Commission’s assessment of the EU’s rules of origin, pointing out that these rules have a direct impact on consumers’ rights and choices. The EESC calls for the rules on the origin of goods to be clear, transparent and easily understandable, so that consumers can know the origin of the products, the traceability of the entire chain, particularly in the food sector, and the…

Filed in Italian · English published by the European Commission

1)Our company operates in the ICT and Energy sectors, specifically dealing among other products with Electrical Transformers (HS 8504) and Electric Accumulators (HS 8507). Currently, these headings are excluded from the specific list rules in Annex 22-01 of Delegated Regulation (EU) 2015/2446.

The Fraunhofer Institute for Solar Energy Systems ISE welcomes the opportunity to provide feedback regarding the evaluation of the EUs non-preferential Rules of Origin (RoO). The origin of PV products and components is a critical element in achieving the resilience goals outlined in the NZIA.

The assessment of the European Union's Rules of Origin framework is particularly important for India, given the depth and scale of economic ties between the two partners. India ranks among the EU's leading trading partners, with bilateral goods trade reaching 120 billion in 2024.

Türkiye and the European Union have maintained a Customs Union relationship since 1996. According to the Customs Union Decision No. 1/95, there is free movement of goods principle for industrial products. The Customs Union (CU) has formed the backbone of the current economic relations between Türkiye and the EU, facilitating mutual market access and contributing significantly to bilateral volumes.

Policy Contribution Improvement of EU Rules of Origin 1. Introduction The correct and consistent application of rules of origin is a key element of the Union Customs Code (UCC, Regulation (EU) No 952/2013) and of the Unions network of Free Trade Agreements (FTAs). Clear and binding provisions are essential to avoid legal uncertainty, reduce administrative burden, and ensure fair competition within the Single Market.

The Europe India Centre for Business and Industry (EICBI) works to strengthen Indias engagement with stakeholders in the European Union and represents the concerns of Indian organisations. Indias engagement with EU stakeholders and puts forth the concerns of Indian organisations.

The European Shippers' Council (ESC), established in 1963, is a non-profit European organization representing cargo ownersi.e. the freight transport interests of around 100,000 companies across Europe, including manufacturers, retailers, and wholesalers (importers and exporters, intercontinental).

Reform Ideas for Economic Benefit and Control Efficiency 1. Introduce Clear Positive Lists for Origin Criteria Instead of vague formulations, sector-specific positive lists with concrete processing steps could be introduced. This would: Increase legal clarity Make abuse more difficult, as criteria would be public and verifiable Reduce audit efforts, due to less interpretive ambiguity 2.