Does a trading firm exporting goods to the EU from an approved manufacturer without processing need an origin manager's training certificate or signature card for item-specific status, plus manufacturer's origin confirmation? Released

If you are a trading company that receives goods from a manufacturer that is an Approved Exporter and exports them to the EU without further processing, submitting the manufacturer's Confirmation of Origin is an essential part of applying for Item-specific Approved Exporter status. However, documents proving your company's own origin management capabilities—namely, the training certificate for the person in charge of origin management and the signature card, etc.—must naturally be submitted as well. This is based on a deep understanding of the purpose and operation of the Approved Exporter system.

The Approved Exporter system evaluates two main aspects. First is ‘whether the exported goods meet the rules of origin,’ and second is the ‘origin management capability and system of the exporting company.’ In your case, since the manufacturer is already an Approved Exporter, the Confirmation of Origin issued by them serves as a vital document proving the first aspect—that the origin of the exported goods meets the criteria set by the EU FTA agreement. Thanks to this Confirmation of Origin, you can significantly reduce the practical burden of directly preparing complex Statements of Origin or origin-proving documents (BOM, manufacturing process charts, etc.) for the goods.

However, the second aspect, ‘the exporting company’s origin management capability and system,’ is inherently related to your company’s own capabilities. Item-specific Approved Exporter status is a system where the customs office grants authority to individual exporting companies to autonomously issue Certificates of Origin for specific items. To ensure this authority is not abused or misused, the exporting company must demonstrate to customs that it has its own origin management system in place, through which accurate origin management can be achieved. The documents required in this process include the Application for Approved Exporter Certification, Signature Card (designating the person authorized to sign the Certificate of Origin), Certificate of Origin Issuance Ledger (management of issuance history), and the Training Certificate for the person in charge of origin management.

In particular, the Training Certificate for the person in charge of origin management is a key element in ensuring the accuracy and reliability of the issuance of Certificates of Origin by proving that the employee possesses basic knowledge of FTA origin-related laws and practices. Similarly, the Signature Card clarifies the responsibility for the act of signing the Certificate of Origin and serves as a procedure to confirm that the signer performs their duties within the scope of authority granted within the company, thereby guaranteeing the authenticity and legality of the Certificate of Origin.

Therefore, the manufacturer’s Confirmation of Origin only serves to reduce the burden of determining the origin of the goods. For your trading company to qualify and maintain its status as an Item-specific Approved Exporter, it is essential to meet the requirements for an independent origin management system and the necessary personnel to operate it, and to submit the relevant documents. Through this process, customs determines that your company accurately understands and complies with origin regulations and has the ability to manage them so that FTA benefits are applied correctly.

In conclusion, when applying for Item-specific Approved Exporter certification, you must submit the manufacturer's Confirmation of Origin along with all documents proving the exporting company's origin management capabilities, such as your company's own application for Approved Exporter certification, signature card, Certificate of Origin issuance ledger, and training certificate for the person in charge of origin management. It is important to understand that this is more than just a formality of providing documents; it is a vital process to enhance the accuracy of FTA utilization and your company's international credibility.

For a precise understanding and preparation of these complex procedures, the most efficient and safe method is to proceed by consulting with an expert, such as a customs broker. Customs brokers provide professional advice not only on preparing the documents but also on establishing an origin management system and post-management, helping to minimize the risks and maximize the benefits of FTA utilization.