Deep dive 05 of 05

How to Avoid EU Tariffs on Chinese Goods: Rules of Origin and Light Assembly

How sufficient processing in a member state changes a product’s origin, what the thresholds actually require, and where the line sits between legitimate transformation and prohibited circumvention.

  • up to 45% peak EU tariff on affected goods
  • HS code determines the origin rule
  • 0% duty on qualifying EU-origin goods
  • case by-case assessment required

Draft. The copy below is placeholder structure in the brand voice. Replace with client-approved, source-cited content before publication.

The rule of origin

Under EU non-preferential rules of origin, goods that undergo their last substantial, economically justified working or processing in a member state acquire EU origin. Where that happens, the finished goods circulate as EU goods — no import duty, no anti-dumping exposure. [Expand: the legal basis, the "substantial transformation" test.]

What the thresholds require

The specific test is set per commodity code: a change of tariff heading, a value-added percentage, or a named manufacturing operation. Some products qualify with modest assembly; others require substantially more. [Expand with worked examples per product family.]

The circumvention line

Minimal operations — repackaging, simple assembly of a kit, affixing marks — do not confer origin, and anti-circumvention investigations specifically target them. The processing has to be real and economically justified. [Expand: what has been challenged, safe-harbour guidance.]

How we assess it

We take your commodity codes, identify the applicable origin rule for each, and tell you what a qualifying process would need to look like — before you plan a facility around it. [Link to the customs guidance service and the China persona page.]

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