Issuance of RCEP Certificates of Origin for Products Using Raw Materials Imported Before the Agreement's Entry into Force Released

It is a common occurrence in international trade for manufacturers to produce goods using raw materials that were imported and stored in inventory before a Free Trade Agreement (FTA), such as the RCEP (Regional Comprehensive Economic Partnership), officially entered into force. Regarding your concerns about the eligibility of raw materials imported prior to the RCEP effective date, the answer is yes: you can issue a Certificate of Origin (C/O) provided that the materials can be proven to originate from an RCEP member state and the finished product satisfies the Product Specific Rules (PSR) defined in the agreement.

This is based on Article 10 of the Enforcement Rule of the "Act on Special Cases of the Customs Act for the Implementation of Free Trade Agreements (FTA Special Act)" in South Korea. While the regulations define the validity period of origin verification documents, they do not impose restrictions excluding raw materials based on their date of purchase or import. The critical factor is not when the materials were procured, but whether the agreement is in effect at the time the finished product is exported and whether the product meets the Origin Determination Criteria (PSR).

Application of RCEP Accumulation and Key Considerations for Origin Determination

One of the most significant features of RCEP is the broad application of Accumulation. If raw materials imported from RCEP Member Country A are processed in Korea and then exported to RCEP Member Country B, the materials from Country A are treated as originating in Korea. Even if the materials were imported before the agreement's effective date, if they can be verified as originating from an RCEP member (e.g., China, Japan, ASEAN, etc.), they can contribute to the Korean origin status of the finished product through the accumulation rule.

However, you must ensure that the Origin Supporting Documents for these materials are sufficient to prove RCEP origin requirements. Generally, the following documents must be maintained:

• Origin Confirmation: A valid certificate issued by the domestic supplier if purchased within Korea.
• Import Declaration and Invoice: Shipping documents that verify the origin if imported directly from abroad.
• Bill of Materials (BOM): Documentation proving how the raw materials were utilized in the production of the finished product.
• Manufacturing Process Chart: Evidence that the goods underwent sufficient processing.

Validity of Long-term Origin Declarations and Renewal Requirements

From a practical standpoint, the management of the Long-term Origin Declaration is the most critical area to monitor. Many companies use declarations from suppliers that are valid for up to 12 months. If the Validity Period of the declaration for your existing inventory has already expired, that document cannot be used as valid evidence for issuing a new Certificate of Origin today.

In such cases, you must contact the supplier to have a New Origin Confirmation reissued for those materials. Even if the physical import or purchase occurred in the past, valid documentary evidence must exist at the time the origin is determined for the current export. Since RCEP is subject to strict Origin Verification, it is vital to meticulously check formal requirements such as signatures, validity periods, and consistency of HS Codes.

In summary, raw materials held in stock before the agreement took effect can still qualify for an RCEP C/O, provided they meet the Origin Determination Criteria and are supported by current, valid Verification Documents. We recommend reviewing the validity periods of your supply chain documentation and updating them retroactively if necessary to ensure a compliant and secure issuance of your Certificate of Origin.