India-UK CETA: Simplifying Origin, Strengthening Compliance

Nupur Maheshwari and Siddhant Indrajit¹

Introduction

The India-UK Comprehensive Economic and Trade Agreement (‘CETA’), signed on 24.07.2025, marks an important step towards a more modern, efficient and trusted framework for bilateral trade. For Indian importers, one of its most significant innovations is the transition from authority-issued certificates of origin to exporter or producer self-certification. This shift is a welcome development for industry, as it places greater reliance on commercial documentation, supports faster trade flows and aligns origin procedures with contemporary supply-chain practices.

The Customs Tariff (Determination of Origin of Goods under the Comprehensive Economic and Trade Agreement between India and the United Kingdom of Great Britain and Northern Ireland) Rules 2026 (‘CETA Origin Rules’) came into force on 15 July 2026.² They prescribe the substantive rules for determining originating status.³ Depending on the product, the applicable product-specific rule may require a change in tariff classification, qualifying value content, specified manufacturing processes, or a combination of these requirements.⁴

The introduction of self-certification for goods exported from the United Kingdom to India is therefore both a procedural simplification and an opportunity for businesses to take greater ownership of origin.

From institutional certification to trusted self-certification

Under the conventional certificate-of-origin system, an exporter or producer would apply to a designated issuing authority in the exporting country, which would examine the application and issue the certificate. The self-certification model streamlines this process by allowing businesses closest to the transaction and production records to make the origin declaration directly.

Rule 16 of the CETA Origin Rules provides that the applicable proof of origin for an Indian importer is an Origin Declaration completed directly by the UK exporter or producer.⁵ The removal of a separate certification step by a designated issuing authority can reduce administrative touchpoints, shorten documentation timelines and facilitate more efficient preferential trade.

The exporter or producer certifies that the goods qualify as originating and that the information in the declaration is true and accurate. The prescribed declaration also records that the exporter or producer is responsible for demonstrating origin on the basis of information available to it, including supplier representations where appropriate.⁶ This framework appropriately places the origin assessment with the commercial participant best positioned to understand the product, materials and manufacturing process. Hence, the authors believe that self-certification is more than a documentation change. It is a trust-based trade facilitation measure supported by clear accountability.

Authentication and verification: complementary safeguards

The CETA Origin Rules also provide for authentication of the Origin Declaration. Circular No 33/2026-Cus dated 13.07.2026, titled ‘Implementation of Self-Certification of Origin Declarations under the India-United Kingdom Comprehensive Economic and Trade Agreement’, sets out a detailed procedure in this regard. Authentication confirms the source of the declaration, while substantive verification remains available to confirm that the goods satisfy the applicable origin rule.⁷ This distinction creates a balanced framework, i.e., legitimate trade benefits from a simplified process, while Customs retains the ability to examine origin where necessary.⁸ Where information is sought, the Indian importer may coordinate with the exporter or producer to provide the relevant supporting material.⁹

A simpler process supported by responsible compliance

Self-certification is a significant trade-facilitation measure. By removing the issuing authority from the transactional chain, it can reduce the time, cost and administrative effort associated with obtaining a conventional certificate of origin. The model encourages closer coordination among the importer, exporter and producer. Practical requirements, such as use of an email address registered against the exporter’s EORI number,¹⁰ the prescribed subject line, appropriate separation of the declaration and commercial documents, inclusion of mandatory particulars, and authentication before filing the Bill of Entry, provide businesses with a clear and standardized process.¹¹ As per authors, these requirements would help improve document quality and save time.

The record-keeping framework similarly promotes reliable and auditable origin claims. UK/Indian exporters and producers must retain origin-related documentation for at least five years.¹² UK/Indian importers must retain the relevant declaration and records necessary to demonstrate compliance for at least five years or as per the applicable laws.¹³ During verification, information may be sought concerning non-originating materials, tariff shifts, value calculations, production processes, tolerance, cumulation and non-alteration.¹⁴ Preferential treatment also can be denied only where sufficient information is not received or the relevant parties do not respond or comply with the Rules.¹⁵ Clear retention periods and verification parameters allow businesses to build predictable controls around their preferential claims, and in fact shortens the timeline for responding to the Customs queries.

The framework therefore creates a strong incentive for importers/exporters in India and their UK business partners to establish dependable information-sharing and record-retention arrangements. With appropriate contractual and operational safeguards, self-certification can make preferential trade both faster and more resilient.

Industry readiness: converting facilitation into lasting value

To fully realize the benefits of self-certification, Indian importers and exporters may consider strengthening existing supply agreements through provisions addressing:

• responsibility for determining and documenting origin;
• completion and timely transmission of the Origin Declaration;
• maintenance of EORI and registered-email particulars;
• preservation and production of origin records;
• cooperation during customs verification or visits;
• notification and correction of errors;
• appropriate allocation of duty, interest, penalty and clearance costs arising from an incorrect declaration; and
• post-termination access to records.

Importers may also undertake proportionate due diligence on the origin information provided by the exporter or producer, including through independent advisers where commercially appropriate. This can be particularly useful where sensitive production information cannot be shared directly with the importer. A transaction-specific standard operating procedure can further support implementation process. The ICEGATE Advisory itself encourages importers to coordinate with UK suppliers to avoid authentication failures and clearance delays.¹⁶ Recent digitisation initiatives also point in the same direction. Trade Notice No. 25/2026-27 dated 07.09.2026, introducing Open API enables exporters to integrate their ERP systems with DGFT CoO system through Open Application Programming Interface facility. The initiative aims to enable electronic transmission and verification of origin data, reducing reliance on manual submissions and facilitating faster processing of preferential trade claims.¹⁷

At the same time, the effectiveness of such systems will depend on exporters and importers maintaining robust origin-supporting records, including cost, sourcing and production data, and being able to promptly furnish such information when sought by the authorities. In this regard, exporters may consider maintaining contemporaneous origin substantiation records on lines similar to the documentation framework contemplated under CAROTAR (akin to FORM-I) for a period of five years from date of export. This would enable faster responses to importing country’s queries.

Thus, the future of preferential trade under CETA will belong to businesses that can certify with confidence and substantiate with speed. Done right, self-certification can make preferential trade not only faster, but more predictable, resilient and business-led.

Footnotes

^{1 Nupur Maheshwari, Executive Partner, LKS (nupur.m@lakshmisri.com) and Siddhant Indrajit, Principal Associate, LKS (siddhant.indrajit@lakshmisri.com)}

^{2 Notification No. 62/2026-Customs (N.T.) dated 03.07.2026}

^{3 Ibid., rule 3 to 14}

^{4 bid Annex A.}

^{5 Ibid, rule 16(1)(b)}

^{6 Ibid, Annex B, box 12}

^{7 Circular No 33/2026-Cus dated 13 July 2026, titled ‘Implementation of Self-Certification of Origin Declarations under the India-United Kingdom Comprehensive Economic and Trade Agreement’, para 4}

^{8 Notification No. 62/2026-Customs (N.T.) dated 03.07.2026, CETA Origin Rules, rule 26}

^{9Ibid., rule 26(3) r/w rule 26(4)}

^{10 Economic Operators Registration and Identification Number. Unique identification number given by the Customs Authorities in UK for business and individuals involved in international trade.}

^{11 ICEGATE Advisory dated 13 July 2026, titled ‘India-UK Comprehensive Economic and Trade Agreement (CETA), para 8.}

^{12 Notification No. 62/2026-Customs (N.T.) dated 03.07.2026, rule 25(1).}

^{13  Ibid, rule 25(2) read with Rule 4, CAROTAR, 2020.}

^{14 Ibid, rule 26(6).}

^{15 Ibid, rule 20(2).}

^{16 ICEGATE Advisory dated 13 July 2026, titled ‘India-UK Comprehensive Economic and Trade Agreement (CETA)’, paras 3 to 5}

^{17  The registration, authentication and technical integration process is available on the Trade Connect e-Platform. A step-by-step help manual has also been annexed to the Trade Notice.}

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