EU-UK Trade and Cooperation Agreement (TCA): 15 Minimal Processing Operations
Businesses often forget that their manufacture needs to go beyond minimal processing operations to qualify for lower or zero duty, says Arne Mielken of Customs Manager Ltd.
Prior to looking at the product-specific rules, a set of general rules, often forgotten, also need to be met, or preferential trade is not available.
Where a business uses non-originating materials, your production process needs to go beyond minimal operations, even if your product complies with the product-specific rules. Such operations include simple packaging operations, simple assembly, ironing or pressing of textiles, painting or polishing operations, let's take a closer look at the 15 operations types which disqualify a company from claiming preference under the EU-UK TCA.
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Article ORIG.7: Insufficient Production
1. Notwithstanding point (c) of Article ORIG.3(1) [General requirements], a product shall not be considered as originating in a Party if the production of the product in a Party consists only of one or more of the following operations conducted on non-originating materials:
1. Preserving Operations
(a) preserving operations such as drying, freezing, keeping in brine and other similar operations where their sole purpose is to ensure that the products remain in good condition during transport and storage. (Preserving operations such as chilling, freezing or ventilating are considered insufficient within the meaning of point (a), whereas operations such as pickling, drying or smoking that are intended to give a product special or different characteristics are not considered insufficient).
2. Breaking Up
(b) breaking-up or assembly of packages;
3. Washing
(c) washing, cleaning; removal of dust, oxide, oil, paint or other coverings;
4. Ironing
(d) ironing or pressing of textiles and textile articles; (e) simple painting and polishing operations;
5. Husking, milling etc (Rice)
(f) husking and partial or total milling of rice; polishing and glazing of cereals and rice; bleaching of rice;
6. Colouring
(g) operations to colour or flavour sugar or form sugar lumps; partial or total milling of sugar in solid form;
7. Peeling, stoning, shelling
(h) peeling, stoning and shelling, of fruits, nuts and vegetables;
8. Sharpening, grinding or cutting
(i) sharpening, simple grinding or simple cutting;
9. Sifting, sorting etc.
(j) sifting, screening, sorting, classifying, grading, matching including the making-up of sets of articles;
10. Simple packaging operations
(k) simple placing in bottles, cans, flasks, bags, cases, boxes, fixing on cards or boards and all other simple packaging operations;
11. Affixing logos
(l) affixing or printing marks, labels, logos and other like distinguishing signs on products or their packaging;
12. Simple mixing
(m) simple mixing of products, whether or not of different kinds; mixing of sugar with any material;
13. Simple dilution
(n) simple addition of water or dilution with water or another substance that does not materially alter the characteristics of the product, or dehydration or denaturation of products;
14. Simple assembly
(o) simple assembly of parts of articles to constitute a complete article or disassembly of products into parts;
15. Slaughter of animals
(p) slaughter of animals.
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