Key Takeaways

• Form A, Form D, and Form E are proofs of origin associated with different trade preference frameworks and cannot be used interchangeably.
• Form D is used for trade among ASEAN member states under ATIGA.
• Form E is used under the ASEAN–China Free Trade Area (ACFTA).
• Form A is associated with the GSP system, but its current use must be checked against the destination country's scheme, as some countries or programs no longer use Form A.
• Having a Form does not automatically mean a 0% duty rate applies. The product's HS Code, Tariff Rate, and Rules of Origin must be checked first.

For importers and exporters, the terms Form A, Form D, and Form E often come up when checking eligibility for tariff preferences, especially when a buyer or supplier says that goods may qualify for reduced import duties under an FTA or a trade preference program.

However, these three documents do not apply to every country or product in the same way.

The important thing is to establish the following first:

What is the product → What is its HS Code → Where does it originate → Which country is it traded with → Which agreement applies → Does it satisfy the Rules of Origin?

Only then can you determine which Form or other Proof of Origin is required.

What Are Form A, Form D, and Form E?

All three forms are related to a Certificate of Origin (C/O) or other proof of a product's origin for trade preference purposes.

Their main purpose is to help demonstrate that goods meet the origin requirements of a particular scheme or FTA, allowing the importer to claim a preferential tariff rate in the destination country.

However, each form belongs to a different framework.

Form A

Form A is associated with GSP benefits granted by a preference-giving country. You must check whether the current scheme still uses Form A or accepts another form of Proof of Origin.

Form D

Form D is used for trade within ASEAN under ATIGA.

Form E

Form E is used for trade between ASEAN and China under ACFTA.

Therefore, knowing only the supplier's country is not enough. The actual origin of the goods must also be verified.

Why Is a Certificate of Origin Important?

A Certificate of Origin, or C/O, certifies the origin of goods.

Origin can affect matters such as:

• Import Duty
• FTA eligibility
• Trade Preferences
• Customs Clearance
• Trade measures
• Buyer requirements

However, the Country of Origin is not necessarily the same as the Country of Export.

For example, goods may be manufactured in China, stored in a warehouse in Singapore, and then shipped to Thailand.

If the goods have not undergone a process that changes their origin, they may still be considered Chinese-origin goods even though the shipment is exported from Singapore.

Suggested Internal Link: What Is a Certificate of Origin? Types of C/O and Required Documents

What Is Form A?

Form A is a certificate of origin associated with the Generalized System of Preferences (GSP).

GSP is a system under which a preference-giving country grants tariff preferences to goods from eligible beneficiary countries, subject to the conditions of each scheme.

Historically, Form A was widely used as supporting evidence for claiming GSP benefits.

However, international trade requirements have changed in several areas, including:

• Preference-giving countries
• Beneficiary countries
• Eligible product lists
• Proof of Origin
• Electronic systems
• Self-certification

Therefore, you should not automatically rely on outdated information stating that “Form A is required when exporting to this country.”

Always check the destination country's current scheme before exporting.

Can Form A Be Used to Reduce Duties in Every Country?

No.

Form A is not a universal FTA document that can be used with any country.

At a minimum, check whether:

• The destination country has a relevant GSP scheme.
• Thailand or the product is eligible for the preference.
• The HS Code is included in the eligible product list.
• The goods satisfy the Rules of Origin.
• The scheme still uses Form A or has switched to another form of proof.

Exporters should not prepare Form A based on an old article or a previous shipment without checking the latest status.

What Is Form D?

Form D is a Proof of Origin used to claim tariff preferences under the ASEAN Trade in Goods Agreement (ATIGA).

It applies to trade among ASEAN member states, subject to the conditions of the agreement.

ASEAN member states include:

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

If Thai-origin goods are shipped to an ASEAN member state, or a Thai business imports goods originating in another ASEAN country, ATIGA eligibility can be checked.

However, this does not mean that every shipment between ASEAN countries automatically qualifies for Form D.

The goods must first satisfy the Rules of Origin.

Does Form D Reduce Duties to 0% for Every Product?

Not always.

The actual preference depends on:

• HS Code
• Country of Origin
• Destination country
• Tariff Schedule
• Rules of Origin
• Product-Specific Rules

Many products may qualify for a preferential duty rate of 0%, but this should not be assumed for every product without checking the tariff classification and applicable conditions.

Businesses should verify the Preferential Tariff Rate for the actual HS Code before calculating the Landed Cost.

Must Goods Contain 40% ASEAN Materials to Qualify for Form D?

The 40% criterion should not be treated as a universal rule for all products.

Goods under ATIGA are subject to Rules of Origin and Product-Specific Rules that vary by product.

Possible criteria include:

• Wholly Obtained
• Regional Value Content
• Change in Tariff Classification
• Product-Specific Rule
• Alternative criteria specified for particular products

Regional Value Content (RVC) of 40% is one criterion found in many cases, but it does not mean every HS Code must use this method exclusively.

Check the rule applicable to the specific product before applying for Form D.

What Is e-Form D?

Origin certification and the exchange of Form D information increasingly use electronic systems.

e-Form D allows origin information to be exchanged between the relevant authorities of ASEAN member states through connected systems, reducing reliance on paper documents in many parts of the process.

However, the underlying requirements remain unchanged. The goods must still:

• Have a valid origin
• Satisfy the Rules of Origin
• Use the correct HS Code
• Have accurate invoice information
• Meet ATIGA requirements

An electronic form streamlines the process; it does not make goods that fail the origin rules eligible for preferences.

Which Businesses Can Benefit from Form D?

For example:

A Thai company exports goods to Vietnam.

If the goods originate in Thailand and satisfy ATIGA rules, the company can check whether they qualify for preferential tariffs using Form D or the applicable Proof of Origin.

Similarly, a Thai company importing goods from Malaysia can check ATIGA eligibility.

Form D is therefore important for businesses with supply chains in ASEAN, including:

• Consumer Goods
• Industrial Parts
• Raw Materials
• Machinery
• Food
• Packaging
• Automotive Parts

Product regulations must still be checked separately from tariff preferences.

Suggested Internal Link: Exploring CLMV Import–Export Markets and Essential Shipping Procedures

What Is Form E?

Form E is a Certificate of Origin used to claim tariff preferences under the ASEAN–China Free Trade Area (ACFTA).

It is commonly encountered by Thai businesses that:

• Import goods from China
• Export Thai goods to China

If the goods satisfy ACFTA Rules of Origin and the HS Code has an applicable preferential tariff, the importer may use Form E to claim the preference subject to the relevant conditions.

Is Form E Required for Every Shipment Imported from China?

No.

The cost-benefit should be checked first.

For example, a product under a particular HS Code may already have a normal import duty rate of 0%.

In that case, obtaining Form E may not provide any additional import-duty savings.

Alternatively, some goods may:

• Fail to satisfy the Rules of Origin
• Be ineligible for the preference being considered
• Qualify under another FTA
• Be subject to different document requirements

Therefore, check the tariff before requesting the Form.

Does Shipping from China Always Mean Form E Can Be Used?

No.

Country of Export and Country of Origin are two different things.

For example, a Chinese supplier may purchase finished goods manufactured in a third country and export them from China without carrying out a manufacturing process that changes their origin.

The goods do not become Chinese-origin goods simply because:

• The supplier is based in China
• The invoice is issued by a Chinese company
• The Port of Loading is in China

To use Form E, the goods must be shown to satisfy the ACFTA Rules of Origin.

How Can Form E Reduce Import Duties on Goods from China?

Example for illustration:

Customs Value = THB 500,000

Normal duty rate = 10%

The normal Import Duty would be:

500,000 × 10% = THB 50,000

Assume the goods qualify under ACFTA and the preferential rate is 0%.

The Import Duty may then decrease from:

THB 50,000 → THB 0

However, the following must still be considered:

• VAT
• Other product-specific taxes
• Customs requirements
• Permits

Therefore, a 0% duty rate does not mean that the import is free of all taxes or costs.

Suggested Internal Link: What Is Customs Value (CIF)? 4 Steps to Calculate Import Duties

What Are the Differences Between Form A, Form D, and Form E?

A simple way to remember them is:

Form A

• Framework: GSP
• Applicable countries: Depends on the preference-giving country's scheme
• Key point: Check whether Form A is still used or has been replaced by another form of Proof of Origin

Form D

• Framework: ATIGA
• Applicable countries: Trade within ASEAN
• Key point: Check the Rules of Origin and tariff under ATIGA

Form E

• Framework: ACFTA
• Applicable countries: ASEAN ↔ China
• Key point: Commonly encountered when importing goods from China, but the goods must qualify as originating under ACFTA

These three documents cannot be used interchangeably.

Why Must You Know the HS Code Before Choosing a Form?

The HS Code connects several important pieces of information, including:

• Duty Rate
• Preferential Rate
• Product-Specific Rules
• Permits
• Customs Declaration
• FTA

For example, a business imports goods from China and the supplier says, “We can provide Form E.”

That information alone is not sufficient.

The importer must also check:

1. What is the product's HS Code?
2. What is the normal duty rate?
3. What is the ACFTA rate?
4. Do the goods satisfy the Rules of Origin?
5. Does Form E correctly state the HS Code and product information?

If the HS Code is incorrect, the entire duty calculation may also be incorrect.

Suggested Internal Link: Why Is the HS Code Important?

Rules of Origin Are the Key to Using a Form

FTA eligibility is not determined solely by the country from which the goods are shipped.

You must check the Rules of Origin.

Common criteria include:

Wholly Obtained

The goods are wholly obtained or produced in a member country, in accordance with the applicable requirements.

Regional Value Content

A specified proportion of the value must originate in the country or region.

Change in Tariff Classification

Imported materials must undergo manufacturing that changes their tariff classification to the level specified by the applicable rule.

Product-Specific Rules

Each HS Code may have its own specific rule.

Therefore, the question “If a product is manufactured in Thailand, can it use Form D?” cannot be answered without first reviewing the actual production process and materials.

Can Repacking Goods Change Their Origin?

In general, you should not assume that any of the following automatically changes a product's Country of Origin:

• Changing the box
• Applying a new label
• Splitting packages
• Sorting goods
• Moving goods through a warehouse

A change of origin must be assessed under the Rules of Origin of the relevant agreement.

For example, goods of Chinese origin are imported into Thailand, repacked, and then shipped to Vietnam.

This does not mean the goods become Thai-origin goods and can immediately qualify for Form D.

Will Customs Always Grant Preferential Tariffs if a Form Is Provided?

Not always.

Customs may verify supporting conditions, including:

• Whether the Form is valid
• HS Code
• Product Description
• Invoice
• Origin Criterion
• Country of Origin
• Route
• Third-Country Invoice, where applicable
• Transport conditions
• The validity period or time limits for using the proof under the agreement's rules

If the information is inconsistent, further checks may be required before preferential treatment is granted.

How Must the Form Match the Invoice?

Key information should be consistent across the documents, including:

• Exporter
• Consignee, as required
• Invoice Number
• Invoice Date
• Product Description
• HS Code
• Quantity
• Origin

If the Form refers to a different invoice, or the product details and quantity cannot be reconciled with the shipment, problems may arise when claiming the preference.

Always check the Form against the Final Commercial Invoice before shipment.

How Is a Form Related to the Customs Declaration?

When an importer wants to claim a Preferential Tariff, the relevant information must be declared as part of the Customs process.

The information in the Proof of Origin should therefore correspond with:

• Customs Declaration
• Commercial Invoice
• Packing List
• Transport Document

If any information is incorrect, check and correct it before using the documents for customs clearance.

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

Must the Form Be Issued Before the Goods Leave the Origin Country?

The procedures and timing for issuing a Proof of Origin vary by agreement.

Some cases allow for retrospective issuance or correction procedures, but businesses should not plan to wait intentionally until the goods arrive at the destination.

Before shipment, confirm:

• Which Form is required
• Who is responsible for arranging it
• What information is needed
• Whether the goods satisfy the Rules of Origin
• Whether the buyer requires an original document or a particular form of electronic data
• The applicable document submission deadlines

This helps reduce the risk of the importer having to pay the normal duty rate because the documents are not ready.

Who Applies for the Form?

In general, the exporter prepares the information and arranges the Proof of Origin for exported goods in accordance with the relevant system and agreement.

However, the importer also has an important responsibility because it is the party using the Proof of Origin to claim preferences in the importing country.

The buyer and seller should therefore agree before issuing the Purchase Order on:

• Whether an FTA will be used
• Which Form is required
• Who will prepare the documents
• Who will bear the costs
• When the documents must be provided

Do not wait until the goods are in transit to ask the supplier, “Can you provide the Form?”

How Much Can a Form Reduce the Cost of Goods?

The actual duty savings must be calculated.

Example:

Customs Value = THB 1,000,000

Normal duty rate = 10%

Normal Duty = THB 100,000

If the FTA rate is 5%:

Duty after applying the preference = THB 50,000

Savings = THB 50,000

However, if the normal duty rate is already 0%, the Form will not provide additional savings on import duty in this respect.

Check the tariff before deciding whether the process of obtaining the Form is worthwhile.

Is Form D Better Than Form E?

It is not appropriate to say that one Form is better than the other because they apply to different trade agreements.

For example:

Thai goods → Malaysia

Check ATIGA and Form D.

Chinese-origin goods → Thailand

Check ACFTA and Form E.

For some Chinese-origin goods imported into Thailand, another FTA framework, such as RCEP, may also be worth considering.

Therefore, choose the FTA for which the goods qualify and that offers the most suitable benefit, rather than selecting a Form simply because it is familiar.

How Is RCEP Related to Form D and Form E?

RCEP is another trade agreement involving Thailand, China, Japan, South Korea, Australia, New Zealand, and ASEAN countries.

As a result, some trade routes may offer more than one FTA framework to consider.

For example, imports from China into Thailand may require a comparison between:

• ACFTA
• RCEP

The comparison should consider:

• Tariff Rate
• Rules of Origin
• Product-Specific Rules
• Supply Chain
• Documents that can be prepared

Do not assume that Form E is the best option for every shipment simply because the goods come from China.

Checklist Before Using Form A, Form D, or Form E

Before proceeding, check the following in order:

• What is the product?
• Is the HS Code correct?
• What is the Country of Origin?
• What is the Country of Export?
• What is the Country of Import?
• Which FTA or GSP scheme is available?
• What is the normal Tariff Rate?
• What is the Preferential Rate?
• What are the Rules of Origin?
• Do the goods satisfy the origin rules?
• Which Form or type of Proof of Origin is required?
• Is the invoice correct?
• Do the quantity and description match?
• Are the documents ready before Customs Clearance?

Following this sequence helps reduce the risk of applying for the wrong Form or obtaining a document that does not actually reduce costs.

Frequently Asked Questions About Form A, Form D, and Form E (FAQ)

Is Form E required every time goods are imported from China?

No. Check the HS Code, duty rate, and Rules of Origin first to determine whether the goods benefit from ACFTA. Other FTAs may also be available for consideration.

Which countries use Form D?

Form D is used for trade among ASEAN member states under ATIGA, subject to the product requirements and Rules of Origin.

Does having Form D mean every product has a 0% duty rate?

No. Check the Preferential Tariff for the HS Code and the product's origin requirements first.

Is Form A still in use?

Form A is associated with GSP, but its current use depends on the preference-giving country and its scheme. Some systems may have switched to another form of Proof of Origin or self-certification. Check the latest requirements before exporting.

If a supplier can issue Form E, does that guarantee the goods qualify for the preference?

No. The importer should verify the HS Code, origin, tariff, and supporting documents before claiming the preference with Customs.

Are the Country of Origin and the country from which goods are exported the same?

Not always. The Country of Origin is determined under the Rules of Origin, while the Country of Export is the country from which the shipment is exported.

International Shipping and Documentation Services with CPL INTER

CPL INTER provides international freight services by air, sea, and road, together with shipping documentation and customs clearance services according to the scope of each shipment.

If you need to check the use of Form D, Form E, or another relevant Proof of Origin, prepare the product name, HS Code, product specifications, Country of Origin, origin and destination countries, Commercial Invoice, and relevant production information. These details can help assess the applicable FTA and plan customs clearance before shipment.

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.