UKFT held a member surgery on 23 February offering an opportunity to learn more about the strict new rules of origin requirements introduced by the UK-EU Trade and Cooperation Agreement (TCA), which determine whether or not tariffs are payable on import and exports to/from the EU.

Members joined from large high street retailers, leading ecommerce businesses, fashion brands and textile manufacturers to ask questions on specific product lines, supply chains and circumstances.

“The Rules of Origin seminar was really useful. Thank you.”

“Really enjoyed the webinar, a lot to get our heads around but very useful.”

“Thanks for the today webinar – as always was really helpful.”

“Thank you for today’s seminar, it was really interesting and I took away some really useful information.”

“Are we able to access this again as a recording? – there were so many good points made that it would be great to listen a second time.”

UKFT has also published a new Guide to Rules of Origin for UK fashion and textile companies trading with the EU, available to members. Find out more here.

UKFT members can watch the surgery back on demand – just contact us at info@ukft.org for the password.

Some of the questions and issues covered during the webinar included:

• Which section (reference number, page number) is the specific chapter in the agreement?
• Are tariff levels consistent at 4% for yarn, 8% for fabric and 12% for garments across every member state in the EU or are their local differences ?
• We produce in the EU and import to the UK, but then re-export to the EU for wholesale and retail. How can we avoid duties in these cases?
• Are the ROO the same as labelling on a garment? So could I have a product labelled as Made in England or Made in Scotland which does not meet the Rules of Origin for the UK if it was physically made in the UK?
• What would the duties be on garments imported from the EU to UK using Japanese fabric, purchased on a fully factored basis?
• Labelling – if material comes from China on roll, I print and cut into singles in the UK, can this be classed as “made in UK”?
• Regarding free circulation: We use a warehouse/ goods out facility in The Netherlands. For product that originates (fabric and making) in Portugal or Turkey, shipped direct to the NL warehouse and from there is shipped to both trade and direct customers, would duty still be chargeable?
• What are the rules of origin requirements for embroidery?
• How will customs police country of origin – in terms of checking whether declaration of preferential origin is valid or not? Will this be done from tariff code? If so how will they trace compliance with all the rules?
• Our Company is being charged duties on goods made in the EU which we are re-importing from the UK to our EU stores. We were told that to avoid duties we can use the Goods Return relief procedure, please can you explain how this works and the practicalities?
• If a Portuguese supplier provides an invoice/declaration stating COO Portugal for the finished goods, what proof/information regarding origin of raw materials will be needed? Is the liability with the supplier?
• If shipping from a UK Bonded warehouse, do the goods have to be transported to the EU clients via a bonded transport operative?
• My company buys silk from India, we ship to Italy to be dyed and then shipped to our CMT factory in Romania. We also ship the greige silk to the CMT factory. What origin should the garments obtain?
• How would the origin of the components need to be declared on documentation? Fabric from India, made in China for example?
• Do the rules of cumulation apply in reverse? i.e. If a German company imports Indian fabric, makes up a garment in Germany and then exports to the UK, do the rules of origin also apply and therefore tariffs fall due upon arrival in the UK?
• We are a UK screen printer, we buy blank shirts from Bangladesh, design, screen print and add various labels, then re-ship to the EU. Would you mind expanding on the rules/stipulation about printing?
• If we are producing all items in Turkey and shipping them directly to EU customers with their certificate of origin Turkey, do we need to pay custom duty?
• If we ship some Italian fabric on a roll to Romania to be made into garments, directly from Italy – but the yarn of that fabric is of non-preferential origin – will we incur duties?
• Our EU stores are due to return old season stock to our UK warehouse, the stock was sent to the EU stores last year before the end of the transition period, am I right in thinking that we are exempted from paying duties as the items were in free circulation before the 1st of January 2021?
• I have a question regarding the samples with no commercial value. Once we shipped from EU to UK for the final approval before the production am I paying any duties on them? Even if the value of these samples is higher than £200? (value of the sample that we actually pay to the supplier but can’t be re-sold)?
• Would garment dyeing and then manufacture in the EU of a non EU/UK fabric count as double transformation?