What Is a Certificate of Origin? The Difference Between Ordinary, Specific (EPA), and Preferential (Form A) Certificates

When a business partner tells you to "prepare a certificate of origin," and you start looking into it, the number of different documents can be bewildering. Some are obtained at a local chamber of commerce, some can only be obtained at the Japan Chamber of Commerce and Industry, and some cannot be issued in Japan at all. The names resemble one another, and it is hard to judge which one to request. In practice, this entrance is usually where people first get stuck.

This article sorts out what a certificate of origin is by dividing it into three types, ordinary (non-preferential), specific (EPA), and preferential (Form A / GSP), starting from the differences in issuing body, governing law, and tariff effect. Drawing on primary sources, it works through the distinction between first-type and second-type certificates and which agreements do not require a Japan Chamber of Commerce and Industry certificate. The goal is to help someone who has just taken on an export role learn to tell, on their own, which certificate their company needs.

Quick Reference: The Three Types of Certificate of Origin

Before getting into the details, let us grasp the whole picture on a single sheet. If the ordering of this table is in your head, it becomes much harder to get lost in the discussion that follows.

Item	Ordinary (non-preferential) certificate of origin	Specific certificate of origin (EPA)	Preferential certificate of origin (Form A / GSP)
Main purpose	Importing country's legal requirement, contract, L/C specification, etc. (other than tariff preference)	To receive the preferential (EPA) tariff rate in an EPA partner country	To apply the generalized preferential tariff to goods originating in developing countries (Japan as the importing side)
Issuing body	Local chambers of commerce and industry within Japan	Japan Chamber of Commerce and Industry (first type), approved exporters (second type), self-certification	Competent authority of the country of origin (exporting country). Cannot be issued in Japan
Governing law / treaty	Chamber of Commerce and Industry Act (Act No. 143 of 1953), Article 9, plus the 1923 Geneva Convention	Act on Issuance of Specific Certificates of Origin under Economic Partnership Agreements (Act No. 143 of 2004)	Temporary Tariff Measures Act (Act No. 36 of 1960), Article 8-2
Tariff effect	No direct reduction effect (certifies country of origin only)	Applies the EPA rate (lower than normal) in the partner country	A preferential rate lower than the ordinary tariff rate. Duty-free and quota-free for LDCs
Direction of issuance	On export from Japan, etc.	On export from Japan to an EPA partner country	On import from a developing country into Japan

The axes that separate the three types are "what it is issued for" and "who issues it." Get these wrong and a certificate you went to the trouble of obtaining may not clear the partner country's customs, or you may spend time hunting for a document that cannot be obtained at all. If you first want a picture of the full set of documents needed for customs clearance, reading the checklist of documents required for customs clearance alongside this article will make the position of the certificate of origin easier to grasp.

What Is an Ordinary (Non-Preferential) Certificate of Origin? The "Proof of Country of Origin" Issued by Chambers of Commerce

An ordinary certificate of origin is a document that certifies the country of origin of goods for a purpose other than a preferential tariff. It is also called a non-preferential certificate of origin. It is used when the importing country's law requires a declaration of the country of origin, or when a sales contract or letter of credit (L/C) specifies that it be submitted. Its character becomes clear if you think of it not as a document for lowering tariffs but as a document by which a third party certifies the fact of "which country is the origin of these goods."

It is issued by local chambers of commerce and industry within Japan. The exporter applies to the chamber of commerce and industry with jurisdiction over the location of its head office and receives the certificate after a review. The basis is Article 9 of the Chamber of Commerce and Industry Act (Act No. 143 of 1953), which sets out the issuance of trade-related certifications by chambers of commerce and industry. In addition, Article 11 of the International Convention Relating to the Simplification of Customs Formalities, the so-called 1923 Geneva Convention, recognizes the authority of chambers of commerce to issue certificates of origin. It helps to understand this as a system backed by both domestic law and an international treaty.

The point to hold onto here is that an ordinary certificate of origin has no effect of reducing or exempting tariffs. It merely certifies the country of origin, and it must be kept separate from preferences like the EPA and GSP explained later. The belief that "as long as you have a certificate of origin, tariffs go down" is a misunderstanding that tends to arise when this ordinary certificate is confused with the preferential certificates.

What Is a Specific Certificate of Origin (EPA)? Proof for Receiving a Preferential Tariff

A specific certificate of origin is a document certifying that a product satisfies the originating requirements under an economic partnership agreement (EPA), in other words, that it is an originating good under the agreement. It is used so that a product exported from Japan to an EPA partner country can receive the lower EPA preferential tariff rate at the partner country's customs. The biggest difference from an ordinary certificate of origin is that it actually has the effect of reducing tariffs.

The governing law is the Act on Issuance of Specific Certificates of Origin under Economic Partnership Agreements (Act No. 143 of 2004, promulgated on November 25, 2004). Article 1 sets out its purpose: to ensure the proper implementation of EPAs by carrying out the issuance of specific certificates of origin appropriately and reliably, thereby contributing to the sound development of Japan's export trade. It is easiest to understand this as the law that translates the international commitment of an EPA into domestic issuance practice.

Specific certificates of origin come in a first type and a second type. The first-type specific certificate of origin is issued by the Japan Chamber of Commerce and Industry (JCCI), the designated issuing body designated by the Minister of Economy, Trade and Industry under the Act. Because a third party other than the exporter confirms and certifies originating status, this is called the third-party certification system. There is one exception: only the Japan-Singapore agreement is handled by local chambers of commerce and industry.

The second-type specific certificate of origin is a certificate prepared by an "approved exporter" authorized by the Minister of Economy, Trade and Industry. Because the authorized exporter itself certifies originating status without going through a third party, this is called the approved exporter self-certification system. It is adopted in the Japan-Mexico, Japan-Switzerland, and Japan-Peru agreements. If your own company becomes an approved exporter, you gain the advantage of avoiding the need to apply to JCCI each time.

The Three Methods of EPA Origin Certification: Which Agreement Uses What

The way EPA origin is certified falls broadly into three categories. This is the point most easily confused in practice, so let us lay it out carefully.

The first is the third-party certification system. This corresponds to the first-type specific certificate of origin issued by JCCI, the designated issuing body. The second is the approved exporter self-certification system, the second-type specific certificate of origin prepared by an approved exporter. And the third is the self-certification system, a method in which the exporter, producer, or importer declares originating status themselves without receiving issuance from a third-party body.

Representative agreements that adopt the self-certification system are the CPTPP (TPP11), the Japan-EU EPA, the Japan-US Trade Agreement, and the Japan-UK EPA. Under these agreements the first-type specific certificate of origin issued by JCCI is not issued. Even if you try to apply to JCCI on the assumption that "any EPA requires a JCCI certificate," it is out of scope and no certificate will be issued. Conversely, if you settle for self-certification for an agreement that uses third-party certification, the preferential rate may be denied in the partner country. RCEP is different: it is covered by the JCCI-issued first-type specific certificate of origin (third-party certification), while self-certification is additionally available only for certain destinations such as Korea, Australia, and New Zealand. Do not mistake RCEP for a "self-certification-only" agreement.

Which method to use under which agreement is set by the rules of origin of each agreement. Among the agreements covered by the first-type certificate, the bilateral ones include India, Indonesia, Australia, Singapore, Switzerland, Thailand, Chile, the Philippines, Brunei, Vietnam, Peru, Malaysia, Mexico, and Mongolia, and the multilateral ones include the Japan-ASEAN agreement and RCEP (per the guidance of the Japan Chamber of Commerce and Industry). However, agreements can be amended, and some, like RCEP, involve country-specific operations or transitional measures. Before actually proceeding to the procedure, always confirm the matter individually against the rules of origin of the relevant agreement and the latest guidance from Customs and the Ministry of Economy, Trade and Industry.

What Is a Preferential Certificate of Origin (Form A / GSP)? Preference for Developing Countries When Japan Imports

The preferential certificate of origin, the so-called Form A, runs in the opposite direction from the previous two. That is because it is a document used when Japan is the importing side. Under the Generalized System of Preferences (GSP), it is used to apply a preferential rate lower than the ordinary tariff rate to products originating in developing countries.

The basis for GSP is the preferential tariff provisions of Article 8-2 of the Temporary Tariff Measures Act (Act No. 36 of 1960). Japan has operated this system since August 1971. Under paragraph 3 of the same article, certain goods originating in least developed countries (LDCs) qualify for generous special preference that is both duty-free and quota-free. Once you understand it as a system that supports the economic development of developing countries through tariffs, the structure of Japan using it on the importing side falls into place.

Form A is issued by the competent authority of the country of origin, that is, the exporting side. Depending on the country, this may be the customs authority or a chamber of commerce and industry. Because Japan is not a developing country, Form A is not issued within Japan. The understanding that "a Japanese exporter obtains Form A" is a typical misconception that gets this direction wrong. From the standpoint of a Japanese importer, the relationship is one of having the developing-country business partner obtain Form A in their own country.

GSP is a system that is reviewed each fiscal year. As of April 1, 2024, 126 countries and 4 territories were designated as preferential beneficiaries, of which 44 least developed countries were designated as special preferential beneficiaries. At the same time, there is also "graduation," in which countries are removed from coverage as they develop economically: China, Mexico, Thailand, Brazil, and Malaysia were excluded from preferential tariff coverage in fiscal 2019. Because beneficiary countries change by cabinet order or public notice, when you actually consider applying preference, always confirm against the latest materials from Customs and the Ministry of Finance current as of that time.

The Practice of Obtaining a Certificate: Procedure, Turnaround, Validity, and Record-Keeping

The point of contact and the timeframe differ for each certificate. Here we focus on the specific certificate of origin (first type) to cover the points where people most often stumble.

A first-type specific certificate of origin is applied for electronically through the online issuance system of the Japan Chamber of Commerce and Industry. As a rule, the notification of the review result comes within two business days after JCCI accepts the application data. An issuance fee is then paid in exchange for the certificate. The specific fee amount is set by JCCI's fee schedule and may be revised, so confirm the latest guidance before applying.

Often overlooked is the record-keeping obligation. Application data for a specific certificate of origin, along with supporting documents such as slips, must be kept for five years from the date of issuance as a rule. However, the period differs by agreement: three years for each of the Japan-Brunei, Japan-Switzerland, Japan-Vietnam, Japan-ASEAN, and RCEP agreements. It is not finished once the certificate is issued; you need to keep the supporting materials in preparation for a later post-clearance verification, and this is a point worth putting in mind from the outset.

On the importing side, it is worth touching on the validity period of Form A. As a general matter of practice, a GSP Form A is valid for one year from the date of issuance. In addition, applying preference in principle requires satisfying the direct-transport rule, the so-called shipment criterion, of direct transport from the country of origin to Japan. Because the treatment of routing through a third country is set out in detail under the system, confirm it against the latest rules of origin from Customs at the time of clearance.

Another handy thing to remember in practice is the case where submission is not required. When the dutiable value per import declaration is 200,000 yen or less, submission of a certificate of origin, including a preferential one, is not required. For small-value imports, arranging the certificate itself may be unnecessary.

Corporate Export Control Frameworks and Using TRAFEED

In practice, the work around certificates of origin almost always arises in parallel with export control work such as classification screening and transaction screening. In addition to telling which certificate is needed, taking stock once of how far your company's export control framework is actually built out reduces later rework. If you want to grasp where you stand quickly, try the free export compliance self-assessment. In about three minutes, you will get a bead on your company's weak points.

As a means of lightening the burden of the screening and determination itself, there is TIMEWELL's TRAFEED (formerly ZEROCK ExCHECK). TRAFEED is an export control AI agent conforming to the standards of the Ministry of Economy, Trade and Industry; it supports multiple languages and has AI assist the processes of classification screening and transaction screening. The more an organization's destinations and items change frequently, the greater the effect of systematizing the work to prevent determinations from depending on particular individuals. If you would like to talk through an approach tailored to your own operations, you can work out the specifics through an individual consultation on TRAFEED.

Common Misconceptions

Several misconceptions around certificates of origin trip up even experienced practitioners. Let us clear them out first.

The understanding that "there is only one kind of certificate of origin" is inaccurate. In reality there are three types, ordinary (non-preferential), specific (EPA), and preferential (Form A / GSP), and their uses, issuing bodies, and governing laws are entirely different. The starting point is to tell which one your company's purpose corresponds to.

"If you have a specific certificate of origin, tariffs go down for any destination" is also wrong. The effect exists only for EPA partner countries, and moreover each agreement sets out item-by-item rules of origin. Without confirming the partner country and its agreement's rules, you cannot receive the benefit.

The assumption that "any EPA requires a Japan Chamber of Commerce and Industry certificate" also needs care. The CPTPP, the Japan-EU EPA, the Japan-US agreement, the Japan-UK agreement, and others use self-certification, and no JCCI first-type certificate is issued.

"If you have an ordinary certificate of origin, you can receive a preferential tariff" is mistaken as well. An ordinary certificate of origin has no tariff-reduction effect; to receive preference you need either an EPA specific certificate of origin or a GSP Form A.

Frequently Asked Questions

What is the difference between an ordinary certificate of origin and a specific certificate of origin?

They differ in purpose and governing law. An ordinary (non-preferential) certificate of origin certifies the country of origin in response to an importing country's legal requirement or a specification in a contract or letter of credit (L/C). It is issued by local chambers of commerce and industry under the Chamber of Commerce and Industry Act (Act No. 143 of 1953), and it has no effect of reducing tariffs on its own. A specific certificate of origin, by contrast, certifies that a product is an originating good under an economic partnership agreement (EPA), allowing it to receive the lower EPA preferential tariff rate in the partner country. It is grounded in the Act on Issuance of Specific Certificates of Origin under Economic Partnership Agreements (Act No. 143 of 2004), and the first-type certificate is issued by the Japan Chamber of Commerce and Industry, which is designated by the Minister of Economy, Trade and Industry.

Where, and in how many days and at what cost, can a specific certificate of origin be obtained?

A first-type specific certificate of origin is applied for electronically through the online issuance system of the Japan Chamber of Commerce and Industry. As a rule, the notification of the review result comes within two business days after JCCI accepts the application data. An issuance fee is paid in exchange for the certificate. Note that only the Japan-Singapore agreement is handled by local chambers of commerce and industry. Application data and supporting documents must be kept for five years from the date of issuance as a rule, or three years for the Japan-Brunei, Japan-Switzerland, Japan-Vietnam, Japan-ASEAN, and RCEP agreements.

Is a Japan Chamber of Commerce and Industry certificate required for the CPTPP or the Japan-EU EPA as well?

No. The CPTPP (TPP11), the Japan-EU EPA, the Japan-US Trade Agreement, the Japan-UK EPA, and similar agreements adopt a self-certification system in which the exporter, producer, or importer declares originating status themselves. In these cases, the first-type specific certificate of origin issued by JCCI is not issued. Third-party certification (JCCI issuance) is used only where the method set out in the specific agreement calls for it, so always confirm which system applies against the rules of origin of the relevant agreement.

Is Form A (the preferential certificate of origin under GSP) something a Japanese exporter obtains?

No. Form A is a document used under the Generalized System of Preferences (GSP) to apply preferential tariffs to products originating in developing countries when Japan imports them. It is issued by the competent authority of the country of origin (the exporting country); because Japan is not a developing country, Form A is not issued within Japan. GSP is grounded in Article 8-2 of the Temporary Tariff Measures Act, and as of April 1, 2024, 126 countries and 4 territories were beneficiaries, of which 44 LDCs receive special preference. China, Mexico, Thailand, Brazil, and Malaysia graduated in fiscal 2019.

Is a certificate of origin the same as an export control (classification screening) document?

They are different things. A certificate of origin is a document for tariff and customs purposes that shows which country is the origin. Export control classification screening, by contrast, is a procedure under the Foreign Exchange and Foreign Trade Act to determine whether goods or technology fall under the controlled items of the Export Trade Control Order; the purpose and the governing law are entirely different. Because the two are often needed in parallel in export practice, it is important to keep the management of them separate so they are not confused.

Summary

There is not just one kind of certificate of origin. The first thing an export practitioner should internalize is the fact that the three types, ordinary (non-preferential), specific (EPA), and preferential (Form A / GSP), differ in purpose, issuing body, and governing law alike. The ordinary type only certifies the country of origin and does not lower tariffs; the specific type is for receiving a preferential rate in an EPA partner country, and it comes in a first type issued by JCCI and a second type prepared by an approved exporter; Form A is used when Japan is the importing side and cannot be issued in Japan. If you hold these three coordinate axes, you can usually tell which one your company needs.

As a practical procedure for telling them apart, first separate out "do you want to lower tariffs, or only certify the country of origin," then confirm "are you exporting from Japan, or importing into Japan." If you are using an EPA, be sure to check its rules of origin for whether the agreement uses third-party certification, an approved exporter, or self-certification. And do not forget that origin certification is strictly a matter of tariffs and customs, a procedure separate from classification screening under the Foreign Exchange and Foreign Trade Act. If you can draw this line, you will greatly reduce the risk of mixing up documents.

References (Primary Sources)

• Certificate of Origin System under Economic Partnership Agreements (EPA) (Ministry of Economy, Trade and Industry)
• Issuance of Certificates of Origin at the Japan Chamber of Commerce and Industry (First-Type Specific Certificate of Origin) (Ministry of Economy, Trade and Industry)
• Frequently Asked Questions (Q&A) on Certificates of Origin (Ministry of Economy, Trade and Industry)
• What Is a Specific Certificate of Origin? EPA-Based Specific Certificate of Origin Issuance Program (Japan Chamber of Commerce and Industry)
• Applying for Issuance of a Specific Certificate of Origin, EPA-Based Specific Certificate of Origin Issuance Program (Japan Chamber of Commerce and Industry)
• Act on Issuance of Specific Certificates of Origin under Economic Partnership Agreements (Act No. 143 of 2004) (e-Gov Law Search)
• Temporary Tariff Measures Act (Act No. 36 of 1960), Article 8-2 (e-Gov Law Search)
• 1502 About Preferential Certificates of Origin (Japan Customs, Customs Answer)
• 1501 Overview of the Preferential Tariff System (Japan Customs, Customs Answer)
• Generalized System of Preferences (GSP) (Japan Customs)
• Rules of Origin and Certification Procedures (Japan Customs)
• Overview of Certificates of Origin (Tokyo Chamber of Commerce and Industry)
• Types of Certificates of Origin, Trade and Investment Consultation Q&A (JETRO)
• Preferential Tariff System (Ministry of Foreign Affairs)