GSP and REX system: step point on the dematerialisation of FORM A

As part of the reform of the rules of origin of the EU Generalised System of Preferences (GSP) in 2010, the roll-out of the new Registered Exporter (REX) system to dematerialize evidence of preferential origin (Form A or C/O Form A certificates of origin) came into effect on January 1, 2017. It is a system of self-certification of the origin of the goods by the exporter himself (cf. REX 2018: the continuous deployment... questions remain!).

RECALL

The international deployment schedule of the REX system is set over 3 years: GSP beneficiary countries have until 2019 to integrate REX at national level. From the actual entry into force, a transition period of 1 year (extensible 6 months) is foreseen during which the two systems coexist (FORM A and REX). At the end of this maximum period, the use of FORM A to justify the preferential origin of goods exported to the EU is no longer possible (cf. EU import – GSP 2017: international deployment of REX system).

For those GSP beneficiary countries or territories that announced the implementation of REX on 1 January 2017, the transitional period has therefore been definitively over since 30 June 2018 (after 1 year and 6 months).

However, the effective application of the REX system is subject to compliance with two preconditions.* within the framework of administrative cooperation between the EU and the beneficiary country (cf.EU import – GSP 2017: international deployment of REX system).

As a result, only the following countries that have complied with the prerequisites effectively apply the REX system:

Angola, Armenia, Bhutan, Bolivia, Comoros, Cook Islands, Ethiopia, Guinea Bissau, India, Kenya, Kiribati, Laos, Malawi, Mali, Myanmar, Niue Island, Pakistan, Rwanda, Sao Tome and Principe. Sri Lanka, Solomon Islands, Swaziland, Tanzania, Yemen, Zambia.

On the other hand, the following countries that have not met EU requirements cannot claim the effective application of the REX system for their exporters:

• Central African Republic, Djibouti, Liberia, Micronesia, Nauru, Sierra Leone, Somalia, South Sudan, Timor-Leste, Tuvalu (due 31/12/2017)
• Burundi, Chad, Congo, Democratic Republic of the Congo (DRC), Equatorial Guinea, Nepal, Togo, Tonga (due 30/06/2018)

Other GSP beneficiary countries are likely to face the same problems in the coming months:

• Afghanistan, Eritrea, Gambia, Ghana, Guinea, Côte d'Ivoire, Mozambique, Niger, Sudan and Syria have until 31/12/2018 (extended until 30/06/2019) to deploy REX under EU requirements.
• Bangladesh, Benin, Burkina Faso, Cape Verde, Cambodia, the Kyrgyz Republic, Haiti, Indonesia, Lesotho, Madagascar, Mauritania, Mongolia, Nigeria, Paraguay, the Philippines, Samoa, Senegal, Tajikistan, Vanuatu, Vietnam, Uganda, Uzbekistan and Uzbekistan still have until 31/12/2019 (extended until 30/06/2020) to carry out their tasks.

* Articles 70 and 72 of Implementing Regulation (EU) 2015/2447

CAUTION!

Although these countries remain GSP beneficiaries, the Form A preferential origin certificate will be refused by the EU customs authorities, depriving European importers of preferential GSP duties. 

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