Preferential origin: a component made in Italy counts as European only if the supplier declares it
13 November 2026, 08:11
According to press reports on 12 November, not yet confirmed by Brussels, the European Commission is said to be consulting the car industry on postponing the rules, stricter than those in force today, that from 1 January 2027 would impose a 10% duty on electric cars traded between the Union and the United Kingdom without at least 55% European or British value; for battery cells and modules the threshold rises to 65%, for complete packs to 70%.
The origin that counts for duty is not the place of manufacture
The trade agreement between the European Union and the United Kingdom, in force since 2021, removes duty only from goods with preferential origin, that is, goods that meet the rules written in the agreement for that product. For some goods a processing step that changes the customs tariff heading is enough; for others, such as electric cars, the agreement sets a maximum share of materials coming from outside. The calculation is done on value: one takes the ex-works price of the finished product, adds up the components that do not have European or British origin and checks that they stay below the limit.
This is the decisive step. For the carmaker that exports, a component is European only if the supplier selling it proves its origin in writing. A part arriving from an Italian supplier without any declaration of its origin is counted, in the calculation, as non-originating material, just like one bought in Asia. The same applies at every stage of the supply chain: whoever produces that component can state its European origin only if it in turn knows the origin of the materials and semi-finished goods it has bought.
The proof is passed along the supply chain, from one company to the next
The instrument provided by the agreement is the supplier's declaration, whose template is in Annex ORIG-3: a document in which the seller states, for each item, whether and to what extent it is originating. When supplies are recurrent, the declaration can be long-term and cover all deliveries over a period. Whoever signs it must be able to show at any time, at the request of customs, the documents that support it, and must inform the customer immediately when it ceases to be valid, for instance because a different supplier of a raw material has been chosen.
The exporter is responsible for the statement on origin, a sentence whose wording is set by the agreement, written on the invoice or commercial document. For consignments worth more than €6,000 the statement must carry the REX number, which the exporter obtains by registering in the European register of exporters through the Italian Customs and Monopolies Agency. A copy of the statement and the documents on which it rests, suppliers' declarations included, are kept for at least four years.
The customs authority of the importing country can verify origin even after the goods have entered: if the proof does not hold, the importer pays the duty it had saved. That bill travels back up the supply chain, from the importer to the exporter and from the exporter to the supplier that signed the declaration, and how much each can recover depends on the contracts. For those who sell components to a company that exports, therefore, a wrong or missing declaration is an economic and commercial risk, not just a formality.
What to prepare in the company
The starting point is the bill of materials. For every product sold to customers who export to foreign markets with which the Union has a trade agreement, and therefore a reduced or zero rate of duty, whoever handles purchasing puts next to each material the supplier, the value and the declared origin. Where the declaration is missing, it is requested from the supplier in writing, preferably long-term; for materials bought from traders, who do not always know the origin of what they resell, it is worth knowing in advance that without a declaration they will remain non-originating.
The next step falls to the sales manager or to the office that handles shipments: preparing for the main customers a long-term declaration on the company's own items, before the customer asks for it urgently, and registering with REX if the company ships directly to the United Kingdom.
Then there are the contracts. The terms of supply should state who issues the declarations of origin, by when, and who bears the duty if a check disputes them: this last clause is the one that weighs most, because the customs check can come years after delivery.
The postponement under discussion in Brussels, if it comes, will move the date from which the 55%, 65% and 70% thresholds apply, but not the way they are calculated: the European value of an electric car, like that of any goods travelling at zero duty, is built on suppliers' declarations, and a part without paperwork does not count.
This article was prompted by a news item published in the Financial Times on 12 November 2026.