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“Indirect Tax I Indirect Tax Litigation I Customs & FTP I Central Licensing I Arbitration I Advisory”

Dated: 20.03.2025

Navigating the Changes in India’s Rules of Origin

Introduction

Customs regulations in India have been evolving to enhance trade facilitation and compliance. Two key notifications, Notification No. 81/2020-Customs (N.T.) and Notification No. 14/2025-Customs (N.T.), relate to the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020. The 2025 amendment refines the provisions of the 2020 rules. This blog provides an in-depth comparison of the two notifications, highlighting key differences and implications for traders.

Background

Notification No. 81/2020-Customs (N.T.), issued on August 21, 2020, introduced the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020. These rules established the framework for importers to claim preferential tariff rates under trade agreements by providing a Certificate of Origin (CoO).

Notification No. 14/2025-Customs (N.T.), issued on March 18, 2025, amends the 2020 rules, primarily by replacing the term “Certificate of Origin” with “Proof of Origin”, signaling a shift towards a broader verification system.

Key Differences and Amendments

Aspect	Notification No. 81/2020	Notification No. 14/2025	Key Change
Terminology Change	Used “Certificate of Origin (CoO)” throughout.	Replaces “Certificate of Origin” with “Proof of Origin”.	Expands the definition of documentation required for preferential tariffs.
Scope of Application	Applied to importers claiming preferential tariffs under trade agreements.	Retains the same scope.	No fundamental change.
Verification Process	Required submission of a CoO for verification.	Requires “Proof of Origin,” which may include digital or alternative documentation. Some examples are given for illustration only: Manufacturing Process flow, list of inputs with their CTH & sources/origin, resultant Finished goods, statutory registration documents from the country of Origin	Expands options for proving compliance.
Form I Amendments	Required a CoO reference.	Updates references from “CoO” to “Proof of Origin”.	Ensures consistency with revised terminology.

Implications of the Changes

1. Greater Flexibility for Importers: By broadening the requirement from “Certificate of Origin” to “Proof of Origin,” the amendment allows importers to submit alternative forms of documentation beyond just a CoO.
2. Enhanced Verification Measures: The shift in terminology suggests a move towards a more comprehensive and adaptable verification process.
3. Alignment with Global Trade Practices: Many international trade frameworks are moving away from rigid CoO requirements, favoring a more flexible proof-based system.
4. Potential Reduction in Trade Disruptions: Importers may experience fewer delays due to documentary mismatches, as “Proof of Origin” allows for a wider range of evidence.

Supporting Documents Used as Proof of Origin

The amendment broadens the scope of acceptable documentation. Some key documents that can now be submitted include:

• Commercial Invoices with Supplier Declarations
• Bill of Lading & Shipping Documents
• Manufacturer’s Production Records
• Exporter’s Declaration or Affidavit
• Auditor-Certified Statements on Regional Value Content (RVC)
• Digital Certificates of Origin issued under blockchain-based trade platforms

Conclusion

The 2025 amendment to the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020 marks a significant shift towards a more flexible, streamlined, and globally aligned trade compliance process. Businesses engaged in international trade should update their documentation practices to comply with these changes and ensure continued access to preferential trade benefits.

For further details, stakeholders are encouraged to review the full text of Notification No. 14/2025-Customs (N.T.) and Notification No. 81/2020-Customs (N.T.) as published in the Gazette of India.

In case you face any issues related to Indirect Tax-Customs, GST, Foreign Trade Policy (FTP), Arbitration matters and Central Licensing and related advisory matters in India then please feel free to get in touch with SJ EXIM Services.

We offer Legal advice and litigation support in matters related to Indirect Tax-Customs, FTP, other Indirect Tax matters & Arbitration law, all sorts of Central licensing and related matters. Come and explore the new way of doing business with us!

Source: CBIC, Ministry of Finance, Govt. of India

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