Key Takeaways

• A Certificate of Origin (C/O) is a document used to certify the country of origin of goods in accordance with the applicable Rules of Origin.
• The Country of Origin is not necessarily the same as the country from which the goods are exported.
• Certificates of Origin can be divided into two main categories: non-preferential certificates, which certify the origin of goods, and preferential certificates, which support claims for preferential tariff treatment under Free Trade Agreements (FTAs) or other trade arrangements.
• Having a C/O does not automatically reduce import duties to 0%. The HS Code, applicable Rules of Origin, and tariff rates under the relevant trade agreement must also be verified.
• Form D, Form E, and the RCEP Certificate of Origin are used under different trade agreements. The appropriate proof of origin must be selected based on the shipping route and the applicable FTA.

In import–export operations, Country of Origin is important information that can affect import duties, trade measures, and the documents required in the destination country.

One document that business operators commonly encounter is the Certificate of Origin (C/O), which is used to certify a product’s origin. However, in international trade, the question “Which country was this product made in?” is not determined solely by the place from which the goods are exported.

Some products may be made from materials sourced from multiple countries, undergo several stages of manufacturing, or be purchased in one country before being shipped onward to another. For this reason, Rules of Origin are used to determine a product’s origin.

What Is a Certificate of Origin (C/O)?

A Certificate of Origin, or C/O, is a document or form of evidence certifying the country in which goods originate according to the applicable criteria.

Information commonly included in a C/O may relate to:

• Exporter
• Consignee
• Country of Origin
• Country of Destination
• Product Description
• HS Code
• Quantity
• Package
• Invoice Number
• Origin Criterion
• Transport Information, as required by the applicable form

A C/O therefore does more than simply state “Made in Thailand.” When claiming preferential tariff treatment, it is also necessary to demonstrate that the goods actually satisfy the Rules of Origin under the relevant agreement.

What Is Country of Origin?

Country of Origin is the country in which goods are considered to originate under the applicable rules.

The key point is:

Country of Origin ≠ Country of Export in every case

For example, goods manufactured in China may be shipped to a warehouse in Singapore before being forwarded to Thailand.

If the goods do not undergo a manufacturing process in Singapore that changes their origin, their Country of Origin may remain China, even though the shipment is exported from Singapore.

Therefore, the Port of Loading or the country that issued the invoice should not be used as the sole basis for determining origin.

What Is a Certificate of Origin Used For?

A C/O may serve several purposes, depending on its type and the requirements of the destination country, such as:

• Confirming Country of Origin
• Supporting Customs Clearance
• Meeting Buyer Requirements
• Complying with import measures in the destination country
• Supporting a Letter of Credit
• Supporting an application for preferential tariff treatment
• Supporting checks related to certain trade measures

In particular, a Preferential C/O can directly affect import costs if it enables the Importer to use a lower tariff rate under an FTA than the standard rate.

How Many Types of Certificate of Origin Are There?

Broadly, C/Os can be divided into two main groups.

1. Non-Preferential Certificate of Origin

A Non-Preferential C/O, often called an Ordinary Certificate of Origin, certifies the origin of goods but is not primarily intended to claim preferential duty reductions under an FTA.

It may be used when:

• Requested by the Buyer
• Required by the destination country
• Needed as part of trade documentation
• Required to support an L/C
• Confirmation of Country of Origin is needed
• Trade measures are involved

Therefore, a C/O may still be required even when the shipment does not use an FTA.

2. Preferential Certificate of Origin

A Preferential C/O is evidence of origin used to claim preferential tariff treatment under an FTA or a trade preference scheme.

Examples commonly encountered by Thai business operators include:

• Form D
• Form E
• Form RCEP
• Other proofs of origin under FTAs to which Thailand is a party

However, do not choose a form based on the country name alone. Check which agreement applies to the trade transaction and whether the goods satisfy that agreement’s Rules of Origin.

What Is Form D?

Form D is a proof of origin used under the ASEAN Trade in Goods Agreement (ATIGA) for trade between ASEAN member countries, subject to the applicable conditions.

Examples of ASEAN countries include:

• Thailand
• Singapore
• Malaysia
• Indonesia
• Vietnam
• The Philippines
• Cambodia
• Laos
• Myanmar
• Brunei

If a Thai business exports goods to an ASEAN member country and the goods satisfy the applicable Rules of Origin, it may be possible to claim preferential tariff treatment under ATIGA.

The Form D process has increasingly adopted electronic systems. In Thailand, e-Form D is available through the DFT SMART C/O system.

However, having a Form D does not automatically mean that every product qualifies for a 0% duty rate. The tariff schedule for the relevant HS Code must also be checked.

Suggested Internal Link: What Are Form A, Form D, and Form E? How Are They Used to Reduce Import and Export Duties?

What Is Form E?

Form E is a Certificate of Origin associated with the ASEAN–China Free Trade Area (ACFTA).

It is therefore commonly encountered in businesses that:

• Import goods from China into Thailand
• Export goods from Thailand to China

However, the fact that goods are “shipped from China” does not mean that Form E can be used for every shipment.

The goods must satisfy the Rules of Origin under ACFTA, and the documents must comply with the agreement’s conditions.

For example, if goods from a third country are brought into China, stored there, and then shipped to Thailand without undergoing manufacturing that confers Chinese origin, it should not be assumed that Form E can be used solely because China is the exporting country.

What Is Form RCEP?

Form RCEP is one type of proof of origin used under the Regional Comprehensive Economic Partnership (RCEP).

RCEP covers multiple countries in the Asia-Pacific region, including:

• ASEAN member countries
• China
• Japan
• South Korea
• Australia
• New Zealand

Businesses can consider RCEP as another option for claiming preferential tariff treatment. However, they must check the applicable treatment for the product’s HS Code and whether the goods satisfy the Product Specific Rules.

On some trade routes, more than one FTA may be available. It is therefore advisable to compare the agreements to determine which offers the most suitable benefits and origin requirements for the product.

What Is Form A?

Form A is a Certificate of Origin associated with GSP benefits under certain schemes.

However, GSP schemes and the countries granting preferences can change, and the conditions may differ from one country to another.

Therefore, do not automatically rely on the assumption that:

Exporting goods to a developed country = using Form A

Before using it, check whether the destination country still grants GSP preferences to Thailand or to the relevant product category, and which form of origin evidence is currently required.

How Are C/O and FTAs Related?

An FTA, or Free Trade Agreement, is an agreement between countries that may provide preferential duty treatment for goods originating under the agreement’s conditions.

To use an FTA, at least three things should be checked:

• HS Code
• Tariff Rate under the FTA
• Rules of Origin

Then, determine which form of Proof of Origin is required.

Instead of starting with the question:

“Which form do I need?”

Start with:

What product is it? → What is its HS Code? → Where does it originate? → Which FTA applies? → Does it satisfy the Rules of Origin? → What proof is required?

What Are Rules of Origin?

Rules of Origin are the criteria used to determine the country in which goods originate.

Many modern products are not made entirely from materials sourced from a single country.

For example, a Thai company may manufacture electrical appliances using:

• Electronic Components from China
• Motors from Japan
• Plastic Parts from Thailand

The company then assembles and manufactures the products in Thailand.

It is therefore necessary to check whether the manufacturing process is sufficient for the goods to qualify as Thai-originating under the FTA being used.

Rules of Origin can differ between agreements.

What Are the Common Origin Criteria?

Common criteria include the following.

Wholly Obtained (WO)

Goods that are wholly obtained or produced in a party country under the applicable conditions, such as certain agricultural products or natural resources.

Regional Value Content (RVC)

This criterion considers the proportion of value generated within a country or region, according to the formula specified in the relevant agreement.

Change in Tariff Classification (CTC)

This criterion considers whether the HS classification of the finished product changes from that of the materials used, at the level required by the applicable rule.

Terms that may be encountered include:

• CC – Change in Chapter
• CTH – Change in Tariff Heading
• CTSH – Change in Tariff Subheading

Product Specific Rules (PSR)

Each HS Code may have its own origin rule. For example, a product may need to satisfy RVC or CTH, or it may be eligible under more than one criterion.

Therefore, do not apply the rule for Product A to Product B simply because they belong to the same industry.

Can Every Product Made in Thailand Use a Thai C/O?

This cannot be determined solely from the statement “Made in Thailand,” especially when applying for a Preferential C/O.

The following must be checked:

• Which countries supplied the materials
• The HS Codes of the materials
• The HS Code of the finished product
• Where the manufacturing process took place
• The value of foreign materials
• The applicable Product Specific Rule

Processes such as repacking, sorting, or changing labels alone may not be sufficient to change a product’s Country of Origin under the Rules of Origin of the relevant agreement.

Can Re-exported Goods Use a C/O from the Country They Are Re-exported From?

This should not be assumed.

For example, if goods originating in China are imported into Thailand and then exported again without undergoing a manufacturing process that changes their origin, they do not become Thai-originating goods simply because they are exported from Thailand.

For re-exports or goods routed through a third country, check the following before claiming preferential tariff treatment:

• Original Origin
• FTA Rule
• Direct Consignment / Transport Rule
• Required Documents
• Processes carried out during transit

Can Every Certificate of Origin Be Used to Reduce Duties?

No.

An Ordinary C/O certifies origin but does not, by itself, grant preferential tariff treatment.

A Preferential C/O or Proof of Origin under an FTA can support a claim for a Preferential Tariff.

However, the level of preference available to the Importer still depends on:

• HS Code
• Trading Partner Country
• FTA
• Tariff Schedule
• Origin Criterion
• Other conditions under the agreement

Some HS Codes may qualify for a 0% rate, while others may still be subject to duties.

Why Is the HS Code Important for a C/O?

The HS Code is an important starting point when checking a C/O because it is linked to:

• Tariff Rate
• Product Specific Rule
• Origin Criterion
• Customs Declaration
• Details used in the C/O

If the HS Code stated in the C/O does not correspond to the actual goods, problems may arise when the Importer claims FTA benefits.

The classification should therefore be checked carefully before applying for a C/O.

Suggested Internal Link: Why Is the HS Code Important?

Must the C/O Match the Commercial Invoice?

Key information should be consistent across the documents, including:

• Exporter
• Consignee, as required
• Invoice Number
• Invoice Date
• Product Description
• Quantity
• Weight, where applicable
• HS Code
• Country of Origin

This does not mean every field must match character for character, because document formats differ. However, the information must not conflict to the extent that the documents can no longer be linked to the same shipment.

What Documents Are Required to Apply for a Certificate of Origin?

The documents actually required depend on the type of C/O and the relevant agreement. Basic information and documents to prepare may include:

• Commercial Invoice
• Packing List
• Product Description
• HS Code
• Shipping Information
• Bill of Lading or Air Waybill, as applicable
• Exporter Details
• Consignee Details
• Country of Destination
• Origin Information
• Manufacturing Information
• Materials Used
• Cost Evidence or supporting origin documents, where applicable

For a Preferential C/O, the business may need to complete an origin qualification review under the applicable conditions before applying for the form.

It is therefore advisable to prepare Origin Data before the shipment, rather than waiting until the goods have left Thailand.

What Are the General Steps for Applying for a Preferential C/O?

The process varies by FTA and system, but the general steps are as follows.

1. Check the Product’s HS Code

The classification must be known first so that the applicable tariff and Rules of Origin can be checked.

2. Select the FTA to Use

Check the destination country and the relevant agreement, such as ATIGA, ACFTA, or RCEP.

3. Check the Rules of Origin

Review the Product Specific Rule to determine whether the goods must satisfy WO, RVC, CTC, or another criterion.

4. Prepare Origin Evidence

Gather information about the materials, manufacturing process, and related documents required.

5. Apply for Proof of Origin

Submit the application through the system or agency responsible for the relevant type of C/O.

6. Check the Details Before Using It for the Shipment

Ensure that the Invoice, Quantity, HS Code, Origin Criterion, and other details are consistent with the goods.

7. Send the Proof to the Importer

The Importer uses the Proof of Origin to claim Preferential Tariff treatment during import clearance, in accordance with the destination country’s rules.

What Is e-Form D?

e-Form D is the electronic version of Form D used to certify origin under ATIGA.

In Thailand, the Department of Foreign Trade has provided e-Form D through the DFT SMART C/O system since 2025.

The use of electronic systems helps reduce reliance on paper documents and supports the exchange of information between ASEAN member countries.

However, exporters must still check Origin Qualification and ensure that the information in the form is correct. Using an electronic form does not reduce the Rules of Origin requirements.

How Should a C/O Relate to the Customs Declaration?

When a Preferential C/O is used for Customs Clearance, key details must be traceable to the customs declaration.

For example:

• HS Code
• Invoice
• Product Description
• Quantity
• Origin
• Importer / Exporter, as required
• Proof of Origin Reference

If the information is inconsistent, Customs may request further verification or may not allow the preferential treatment until the information has been substantiated.

Suggested Internal Link: What Are Import and Export Customs Declarations? Procedures and Documents Importers and Exporters Should Know

Are C/O and Incoterms Related?

Incoterms and Certificates of Origin serve different purposes.

Incoterms define responsibilities, costs, and risks between the Seller and the Buyer.

A C/O concerns the origin of the goods.

In practice, however, both can affect shipment planning because the trading parties need to agree on who will prepare the documents and whether the Buyer needs a C/O to claim preferential tariff treatment in the destination country.

Before confirming an order, the C/O requirements should therefore be agreed upon clearly, especially if the Buyer calculates Landed Cost based on Preferential Duty.

How Is a C/O Related to a Letter of Credit?

When a transaction uses a Letter of Credit (L/C), the bank may specify a Certificate of Origin as one of the required documents.

In this case, check the details stated in the L/C, such as:

• Document Name
• Authorized Issuer
• Number of Originals / Copies
• Consignee
• Description
• Certification Requirements

Even if the C/O is correct in terms of origin, a document that does not meet the L/C conditions may result in a Documentary Discrepancy.

Suggested Internal Link: What Is a Letter of Credit (L/C)? Types and Benefits in Import–Export Transactions

Common Mistakes When Using a Certificate of Origin

Issues to watch out for include:

• Selecting a form that does not correspond to the FTA
• Incorrect HS Code
• Incorrect Invoice Number
• Product Description inconsistent with other documents
• Origin Criterion that does not match the goods
• Confusing Country of Export with Country of Origin
• Goods that do not satisfy the Product Specific Rule
• Using a C/O after its validity has expired or in a way that does not comply with the FTA conditions
• Inconsistent Quantity or Package details
• Using documents for one shipment with another shipment
• Failing to check requirements for Third-Country Invoices
• Failing to check transport conditions for shipments routed through a third country

These issues may prevent the Importer from obtaining the planned Preferential Tariff and may require payment of the standard duty rate or further corrective action.

Why Should a C/O Be Checked Before the Shipment Departs?

Although some types of C/O may be issued retrospectively under specified conditions, this should not be the primary plan.

Before shipping the goods, check:

• Whether the Buyer requires a C/O
• Whether an Ordinary or Preferential C/O is needed
• Which FTA will be used
• Whether the HS Code is correct
• Whether the goods satisfy the Rules of Origin
• Whether cost or material information must be prepared
• What information must appear on the Invoice
• Whether the route involves a Third Country

If the checks are carried out only after the goods have departed, the documents or Origin Evidence may prove insufficient to obtain the intended preferential treatment.

If Several FTAs Are Available, Which One Should Be Used?

A single trade route may qualify under more than one FTA.

For example, trade between Thailand and certain RCEP member countries may be covered by more than one of the following:

• ASEAN+1 FTA
• Bilateral FTA
• RCEP

Businesses should not choose solely based on the name of a familiar form. Instead, compare:

• Tariff Rate
• Rules of Origin
• Product Specific Rule
• Documentation
• The product’s Supply Chain
• The ability to substantiate Origin

An FTA offering a 0% rate may not be a practical option if the goods cannot satisfy its Origin Rule.

Certificate of Origin Checklist

Before applying for or using a C/O, check at least the following:

• HS Code is correct
• Country of Origin is correct
• The correct FTA has been selected
• Tariff Rate has been checked
• Product Specific Rule has been checked
• Goods satisfy the Origin Criterion
• Invoice Number and Date are correct
• Product Description is correct
• Quantity and Package details are consistent
• Exporter / Consignee details are correct
• Route and Transport Conditions meet the requirements
• Supporting documents are ready
• The C/O or Proof of Origin is in a format accepted under the agreement

Completing these checks before shipment helps reduce the risk of the Importer losing preferential tariff benefits when the goods arrive in the destination country.

Frequently Asked Questions About Certificates of Origin (FAQ)

Is a Certificate of Origin required for every shipment?

No. It depends on the destination country, product type, Buyer requirements, and whether preferential treatment under an FTA is being claimed.

Does having a C/O automatically make import duty 0%?

Not always. Check the tariff rate for the HS Code under the FTA, along with the Rules of Origin and other applicable conditions.

If I buy goods from China, does that mean their origin is always China?

No. Country of Origin is determined by the origin and manufacturing process of the goods, not simply by the country where they were purchased or from which they were shipped.

Which countries use Form D?

Form D is used under ATIGA for trade between ASEAN member countries, subject to the agreement’s conditions.

Can Form E be used for every product imported from China?

No. The goods must satisfy the Rules of Origin under ACFTA, and preferential treatment must be available for the relevant HS Code under the applicable conditions.

Are a C/O and “Made in Thailand” the same thing?

Not exactly. “Made in Thailand” is a statement of origin shown on a product, whereas a C/O is a document or form of evidence used to certify origin under the applicable requirements, particularly when claiming trade preferences.

Import–Export Documentation Services with CPL INTER

CPL INTER provides international freight services by air, sea, and road, along with Shipping Documents and customs clearance services within the service scope of each shipment.

If you plan to use a Certificate of Origin or claim FTA benefits, prepare the product name, HS Code, Product Specification, Country of Origin, Commercial Invoice, Packing List, origin and destination countries, and relevant manufacturing information. This helps the shipment requirements be reviewed before booking.

Tel: 02-519-4426 / 091-519-4426
LINE: @cplinter

Written by: CPL Inter Logistics Operations Team, specialists in international freight transportation and customs procedures, with more than 15 years of experience and an internationally recognized ISO 9001:2015 quality management system.