Proof of Origin: EUR.1, EUR-MED, A.TR, REX and More

Origin, preference and proof: three separate questions

Preferential duty needs three things at once. The goods must be covered by an agreement or scheme. They must meet its rules of origin (wholly obtained, or sufficiently processed under the product-specific rule). And the importer must hold the proof that the agreement prescribes, issued correctly and on time.

Non-preferential origin is a different concept. It decides country-of-origin marking, anti-dumping duties and some sanctions, and it is proved with a certificate of origin from a chamber of commerce. That certificate never gives a preferential rate.

Movement certificates: EUR.1 and EUR-MED

EUR.1 is the classic movement certificate used in most EU agreements of the older generation, in the Pan-Euro-Mediterranean (PEM) zone and in the UK–Türkiye agreement. The exporter fills it in and the customs authority (or an authorised body) of the exporting country endorses it.

EUR-MED is the PEM variant. It shows whether diagonal cumulation was applied. The revised PEM Convention rules have applied since 1 January 2025; the transitional period in which operators could choose between the old and new rules ran until 31 December 2025.

Under PEM rules an invoice declaration can replace the certificate when the exporter is an approved exporter, or for consignments of originating products whose total value does not exceed €6,000.

A.TR: the EU–Türkiye customs union

The A.TR movement certificate is not a proof of origin. It proves that goods are in free circulation in the EU or in Türkiye, which is the condition for duty-free movement under the customs union (Decision 1/95 of the EC–Turkey Association Council).

Goods made in China and released for free circulation in Türkiye can therefore travel to the EU with an A.TR and pay no EU customs duty, provided all import duties were paid in Türkiye.

What A.TR covers and what it does not

• Covered: industrial products and the industrial component of processed agricultural products.
• Not covered: basic agricultural products, which fall under the 1998 EU–Türkiye agricultural preferences and need a EUR.1 or EUR-MED with origin rules.
• Not covered: coal and steel products (former ECSC goods), which have a separate free trade agreement with origin rules and EUR.1 or EUR-MED.
• Not a shield against trade remedies: EU anti-dumping duties on goods of a given origin still apply, and some measures are extended to goods consigned from Türkiye.
• No preference in third countries: an A.TR does not give Turkish goods access to EU FTA preferences with other partners.

Statements on origin and REX

Newer EU agreements (Canada, Japan, Vietnam, the UK, New Zealand and others) rely on self-certification: the exporter writes a statement on origin on the invoice or another commercial document. Above €6,000, an EU exporter must be registered in the Registered Exporter (REX) system and quote the REX number. Some agreements also allow the importer’s knowledge as a basis for the claim.

The EU GSP has used REX since 2017. Beneficiary-country exporters register with their authorities and write a statement on origin; consignments of originating products up to €6,000 can be covered by any exporter.

GSP Form A: history

Form A certificates were the GSP proof for decades. The EU phased them out for its GSP during the REX transition, which ended on 30 June 2020. Form A is no longer accepted for EU GSP imports. The current GSP Regulation (EU) No 978/2012 has been extended until 31 December 2027.

UK and Türkiye

The UK–Türkiye Trade Agreement has applied since 1 January 2021. It covers industrial goods and certain agricultural products, with origin rules in a protocol modelled on PEM rules. Proof is a EUR.1 movement certificate or an invoice declaration.

The agreement allows cumulation with EU materials and processing (except processing for textiles) in UK–Türkiye trade, as long as the processing in the exporting party goes beyond minimal operations. This matters because Turkish supply chains often contain EU inputs.

The UK and Türkiye are negotiating an enhanced agreement covering services, digital trade and investment. The fourth round took place in London in February 2026. Until a new agreement enters into force, the current protocol applies.

Cumulation in plain terms

Cumulation lets you count materials from another partner as originating, so that your product can qualify even if the local value is low.

• Bilateral: materials from the importing party count as originating.
• Diagonal: materials from other countries in the same zone count, if all of them have agreements with identical rules (the PEM zone; Türkiye has diagonal cumulation in 2026 with Serbia, Moldova, Egypt and Albania under the revised PEM rules).
• Full: processing done in several partners adds up even if no single stage confers origin (in the EEA, and between the EU and Algeria, Morocco and Tunisia).
• Extended: special cases allowing materials from a third country with which both parties have agreements.

How to claim preference after import

If the proof is missing at the time of the declaration, you can usually pay the full duty and claim a refund later. In the EU, repayment under Article 117 of the Union Customs Code is possible within three years of the notification of the customs debt.

A EUR.1 or EUR-MED can be issued retrospectively by the exporting country's authorities and must be marked as such. A statement on origin can usually be made after export, within the time limits of the agreement.

In the UK, you can reclaim overpaid duty through HMRC within three years, using the C285 process. In the US, a post-importation claim for FTA preference (for example under USMCA) is generally possible within one year of import.

• Keep the supplier’s long-term declarations and cost data: verification requests can come years later.
• Check the wording of the statement: agreements prescribe exact texts.
• Use supplier declarations, including long-term supplier declarations, to document the originating status of inputs bought from other producers.
• Train sales and logistics staff: an origin statement on an invoice is a legal declaration by the exporter, not a marketing line.
• Do not claim preference if you are unsure; a wrong claim leads to post-clearance recovery and possibly penalties.