Is it Indian enough for 0% UK duty? The CETA origin rule for 12 Indian export categories

What are the CETA product-specific rules of origin, and how do you read Annex 3A?

Under Article 3.2 of CETA Chapter 3, a good originates in India in one of three ways: it is wholly obtained there, it is made there only from originating materials, or it uses non-originating materials and meets the product-specific rule (PSR) for its code in Annex 3A. Final production must happen in the exporting country.

The second route is easy to miss. If every material is Indian or UK originating, the PSR does not apply. It matters only once something imported goes in.

Annex 3A sets one rule per HS chapter, heading or sub-heading, using the 2022 edition of the HS. A rule marked "ex" covers only part of a chapter or heading. Tests joined by "or" are alternatives; tests joined by "and" must all be met. For a code not covered below, open the commodity on the UK Trade Tariff, select India and open the rules of origin section. It lists the CETA rule and the rule for the UK's Developing Countries Trading Scheme (DCTS), so copy the CETA one.

Tariff-shift tests look only at non-originating materials. An Indian material whose origin cannot be proved counts as non-originating (Article 3.1). Because the rule follows the code, start with the guide to commodity codes for goods from India.

Which origin rule applies to Indian honey, spices, tea and other food?

Most unprocessed farm goods (chapters 1 to 12 and 14) must be wholly obtained, which suits a grower and catches a trader who blends or repacks bought-in stock. Processed foods (chapters 15 to 24) mostly need a tariff shift instead.

Honey. Article 3.3.1(d) treats goods from live animals raised in India as wholly obtained, so the test is where the bees are kept. Retail packaging is ignored for this test (Article 3.12). Qualifying honey (0409 00 00 90) now enters at 0%; before 15 July 2026 India paid the full 16%.

Spices. A spice mixture of 0910 91 must be wholly obtained, while a mixed seasoning of 2103 90 needs only a change of sub-heading, so check where your masala sits. A change of code is not enough on its own: Article 3.7.1(m) says simple mixing never confers origin, so a blend of imported spices qualifies only if the work in India goes beyond simple mixing. If it is borderline, get an advance ruling first.

Tea. The rule allows "blending" instead of a tariff shift, but the agreement does not define blending for tea. Article 3.7.1(m) says simple mixing never confers origin, and Article 3.7.2 calls an activity simple when it needs no special skills or specially installed equipment. No official text we found settles whether a commercial blend of Indian and imported tea passes. Repacking imported bulk tea (0902 40) into packs of 3 kg or less (0902 30) changes sub-heading on paper, but Article 3.7 says changes of packaging and simple packing never confer origin, so repacking alone does not qualify.

Chapter 20. Imported vinegar, oil or spices come from other headings and pass the CTH, but their value counts against the QVC.

Which origin rule applies to textiles, handicrafts, kitchenware and electricals?

Made goods can usually use imported materials. The test is whether the work in India changes the tariff classification and, for most chapters, whether enough value is originating.

Textiles. All 14 textile chapters, 50 to 63, share one rule, and there is no yarn-forward or fabric-forward requirement. business.gov.uk gives the example of tracksuits (6112) made from imported fabric (5512). The catch is value: expensive imported fabric can pull the originating share below 40% ex-works.

Steel. The "melt and pour" requirement in Annex 3A applies to chapter 72 iron and steel, not to chapter 73 kitchenware. Whether imported pressed blanks are chapter 72 steel or unfinished 7323 articles is a classification question, so confirm the code first.

Electricals. Chapter 85 has the most variants:

• Most of chapter 85, including irons, water heaters and ovens (8516) and torches (8513 10): CTSH and Standard QVC.
• Motors, generating sets and their parts (8501 to 8503), and switches, plugs and sockets (8536 to 8538): CTH or Standard QVC.
• Transformers (ex 8504), primary batteries (ex 8506), phones (ex 8517), lamps including LED lamps (ex 8539) and insulated cable (8544): CTSH or Standard QVC.
• Accumulators, including lithium-ion batteries (8507): CTH or a QVC of 40%.

Under an "or" rule, either test is enough. A motor built in India from imported parts of 8503 already meets the CTH, and one using an imported 8501 component can still qualify on Standard QVC alone, if the work is more than simple assembly. business.gov.uk describes the motor test as at least 40% of value: that is the ex-works build-down figure of the Standard QVC.

How do you calculate qualifying value content (QVC)?

QVC measures how much of a product's value is originating. Article 3.4 lets you use the ex-works price, which excludes transport and handling after the goods leave the factory, or the FOB value, which includes the cost of loading at the Indian port.

• Build-down: value of the good minus non-originating materials, divided by value of the good, times 100.
• Build-up: value of originating materials, divided by value of the good, times 100.

Under Article 3.5.2, an imported material is valued at the price paid at importation, including transport to India. A material bought locally is valued at what the producer paid, and one made in-house at its full production cost.

Freight, insurance, packing and non-recoverable duties can be deducted from non-originating materials, but Article 3.5.5 allows no adjustment without documentary evidence. Retail packaging counts in the QVC; shipping containers do not (Article 3.12). Under Article 3.6.1, an intermediate made in India that meets its own rule counts as originating in the next step. Article 3.6.2 also lets the value of processing a non-originating material in India count towards a QVC, so confirm how you apply it with a customs agent.

Is 40% Indian value addition enough to qualify?

Not always. "40% value addition" is only one of three Standard QVC options, and most rules add a tariff shift with "and". Reaching 40% does not help if an imported material shares the finished good's heading.

• Honey, spices and fresh produce must be wholly obtained, so value added to imported stock does not help.
• Ceramics need a change of chapter, and footwear (chapter 64) a change of heading, with no value test.
• Gold and silver jewellery need a change of sub-heading plus a QVC of 3.5% (plain), 6% (with gemstones) or 7% (with diamonds).

Does packing or labelling imported goods in India make them Indian?

No. Article 3.7 lists operations that never confer origin, notwithstanding anything else in the chapter, including:

• changes of packaging and simple packing into bottles, bags or boxes
• affixing marks, labels or logos
• sorting, grading, simple grinding or simple cutting
• simple painting and polishing, and for textiles ironing or attaching beads
• simple mixing, and simple assembly of parts into a complete article

Cumulation is bilateral only (Article 3.8), so Chinese, Vietnamese or Bangladeshi inputs are non-originating as imported. They count only once processed in India into a material that meets its own rule (Article 3.6). Goods may cross a third-country hub only under customs control, with nothing beyond unloading, splitting, storage, labelling or preservation (Article 3.14).

The Article 3.9 tolerance rescues a good that fails a tariff-shift or WO test because of a little non-originating material. It never relaxes a QVC.

A hypothetical terracotta wind chime with imported ceramic beads worth 8% of its ex-works price fails the CC rule, but the beads sit inside the 12.5% tolerance, so it can still qualify. Annex 3A switches the tolerance off for cereal and flour materials in several chapter 19 preparations. Honey in chapter 4 does carry a 12.5% tolerance, but Article 3.7.1(m) says simple mixing never confers origin, so do not rely on it to blend imported honey into an Indian lot without an advance ruling.

Do I need to prove origin if UK duty is already 0%?

Only where origin changes the rate. On the UK Trade Tariff, with India selected, compare the standard rate, the rate India actually paid before 15 July 2026 (often lower, under the UK's Developing Countries Trading Scheme, or DCTS) and the CETA rate.

Many lines are 0% for any origin, so CETA changes nothing on duty: fresh mango, black tea, turmeric, cumin, mango chutney (2001 90 10 00), copper cookware, brass ornaments, steel kitchenware, handmade paper, wooden furniture, LED lamps and wooden statuettes other than those of the listed tropical woods (4420 11 90 00, 4420 19 00 00). The India-UK FTA zero-duty products list shows which lines actually gained.

Watch a third group. Hand-made statuettes of teak, mahogany and the other tropical woods listed in additional note 2 to chapter 44 (4420 11 10 10), hand-made common-pottery ornaments (6913 90 10 10), electric irons, hairdryers and tea makers carry a 2% standard rate that India avoided under the DCTS. India leaves the DCTS on 15 July 2028, and the two schemes' proofs of origin are not interchangeable. After that date, on current rates, only CETA origin keeps these lines at 0%. Hand-made ornaments of earthenware or fine pottery (6913 90 93 10) or porcelain (6913 10 00 10) are different: 6% standard, 2.5% under the DCTS and 0% under CETA, so origin already saves duty.

How do I check whether my product qualifies?

Run this sequence for each product line before the first shipment.

1. 1

   Classify the finished good

   Agree the 6-digit HS code and the 10-digit UK commodity code with the UK importer or its customs agent.

2. 2

   Check what is at stake

   Compare the standard, DCTS and CETA rates. If the standard rate is 0%, there is no preference to claim.

3. 3

   Copy the Annex 3A rule exactly

   Use the row for the chapter, heading or sub-heading, including any "ex" row, and note every "and" or "or".

4. 4

   Try the simple routes first

   A good wholly obtained in India, or made only from materials proved to be Indian or UK originating, needs no PSR.

5. 5

   Build the bill of materials

   List each material's HS code, origin and value, with written origin statements from Indian suppliers.

6. 6

   Apply the tariff-shift test

   Test only non-originating materials, and check the Article 3.9 tolerance for any that fail.

7. 7

   Run the QVC if required

   Pick ex-works or FOB and build-down or build-up, use only documented adjustments and save the calculation.

8. 8

   Check the work and the route

   Confirm the processing goes beyond Article 3.7 and any transit meets Article 3.14.

9. 9

   Issue the proof and file the evidence

   Complete the Annex 3B origin declaration with your IEC as the reference number and the origin criterion ticked (WO, PE for goods made only from originating materials, or PSR with the Annex 3A rule named; tick box 9 if you rely on Article 3.6), or get a certificate of origin on DGFT's Trade Connect. Keep the file for five years.

The UK importer claims with a 300-series preference code and proof code 9001 (origin declaration), N954 (certificate of origin) or U112 (importer's knowledge). Agree with the UK customs agent which code fits a DGFT self-declared certificate. The CETA certificate of origin guide and the overview of UK-India rules of origin cover the paperwork.

What evidence should I keep, and can I get a ruling in advance?

Under Article 3.24, the exporter or producer keeps origin records for five years and the UK importer for at least four. HMRC checks the importer first and, for claims based on an origin declaration or certificate, can then ask India's Department of Commerce, normally within two years of the claim (Article 3.25). Later requests are possible under the UK-India customs assistance agreement. The guide to CETA origin verification has the detail.

A merchant exporter may complete the declaration relying on the producer's information (Article 3.16.3). If you supply a merchant exporter, expect to be asked for the bill of materials, supplier statements and costings before it signs.

• HS and UK commodity codes agreed with the UK importer
• Annex 3A rule copied exactly, with any "and", "or" or "ex"
• Bill of materials: HS code, origin and value of every material
• Written origin statements from Indian suppliers
• Bills of entry and invoices for imported materials
• Ex-works or FOB price evidence
• QVC calculation, with documents for every adjustment
• Process description showing more than Article 3.7 operations
• Segregation or inventory-management records where Indian and imported stock of the same material are held together (Article 3.10)
• Copy of the origin declaration or certificate

Where the rule is unclear, get a ruling before shipping. Article 5.8 of CETA lets an exporter, importer or producer apply and requires a ruling on origin within three months of receiving the application and all necessary information, with no UK fee. HMRC's Advance Origin Ruling page, last updated in July 2023 before CETA, needs a GB EORI number, says a ruling lasts three years and still gives a 120-day target. Your UK importer can apply.

Good candidates for an origin ruling are tea blends and electrical kits. Whether a masala sits in 0910 91 or 2103 90, or whether imported steel blanks are chapter 72 or 7323, is a classification question, so use HMRC's separate Advance Tariff Ruling instead; Article 5.8 covers classification too. This guide explains the rules and is not legal advice: confirm your product with a customs agent.

Questions exporters ask

Sources

1. UK Government: CETA Annex 3A, Product-specific rules of origin (24 July 2025)
2. UK Government: CETA Chapter 3, Rules of origin (24 July 2025)
3. UK Government: CETA Annex 3B, Origin declaration template (24 July 2025)
4. UK Government: CETA Chapter 5, Customs and trade facilitation (24 July 2025)
5. HMRC: UK Trade Tariff, honey 0409 00 00 90, India (30 October 2026)
6. HMRC: UK Trade Tariff, cotton bed linen 6302 31 00 00, India (30 October 2026)
7. HMRC: UK Trade Tariff, steel kitchenware 7323 93 00 90, India (30 October 2026)
8. HMRC: UK Trade Tariff, other codes quoted, India (30 October 2026)
9. HMRC: Apply for an Advance Origin Ruling (4 July 2023)
10. HMRC: Apply for an Advance Tariff Ruling (2 June 2026)
11. DBT: Rules of origin in India, business.gov.uk (accessed 30 October 2026)
12. FCDO and DBT: Country graduation from the DCTS, India (4 September 2026)

Last reviewed 30 October 2026. Border, tariff and plant-health rules change. Check the sources above before relying on this guide for a specific consignment.