Certificate of Origin for Steel

What Is a Certificate of Origin for Steel?

A Certificate of Origin (CO) is an official document that certifies the country in which the goods were manufactured or substantially processed. For reinforcing steel, it declares that the rebar was produced in Germany (or, more broadly, within the European Union) — a statement that carries significant weight in international trade because it determines which tariff rate, trade agreement, or anti-dumping regime applies when the goods are imported.

The Certificate of Origin is distinct from the Mill Test Certificate. The MTC (EN 10204 Type 3.1) is a quality document — it certifies the chemical composition and mechanical test results of the steel. The CO is a trade document — it certifies where the steel was made. Both are typically required in the export documentation package for a rebar shipment; they serve different purposes and are issued by different authorities.

Types of Certificate of Origin for Steel Exports

There are two main categories of Certificate of Origin relevant to steel exports from Germany:

1. Non-Preferential Certificate of Origin

A non-preferential CO (also called an ordinary or general CO) simply states the country of origin without claiming any preferential tariff treatment. It is the standard document for export shipments where no free-trade agreement applies between the exporting country (Germany / EU) and the importing country. In Germany, non-preferential COs for export are typically issued by the competent Chamber of Commerce (Industrie- und Handelskammer, IHK) upon application by the exporter, who declares the origin of the goods and provides supporting production evidence.

Non-preferential COs are required by many importing countries as a standard customs formality, independently of tariff preferences.

2. Preferential Certificate of Origin (EUR.1 / Form A / REX)

A preferential CO enables the importer to claim a reduced import duty rate under a trade agreement between the EU and the destination country. The EU has preferential trade agreements with a large number of countries worldwide. For steel exports, this can translate into meaningfully lower import tariffs for buyers in countries covered by EU trade agreements — making EU-origin rebar competitively more attractive than equivalent material from countries without preferential access.

The main instruments for preferential origin in EU exports include:

• EUR.1 Movement Certificate: The traditional preferential origin certificate, stamped by the exporting country’s customs authority. Used for export to countries covered by specific EU trade agreements (e.g. many Middle East, North Africa, and developing-country partners).
• Form A (GSP): Used for exports to countries that grant the EU preferential access under their Generalised System of Preferences (GSP).
• REX (Registered Exporter System): The modern replacement for some EUR.1 and Form A documents. A registered exporter makes a Statement on Origin directly on the commercial invoice or packing list, without needing a separate paper certificate. REX is increasingly used for EU trade agreement exports.

Why the Certificate of Origin Matters for Rebar Buyers

The financial impact of a valid preferential CO can be substantial for large tonnage rebar shipments. Import duty rates on HS 7214.10 deformed reinforcing bar vary widely — from 0% in free-trade markets to 10–25% or more in others, applied to the CIF (Cost, Insurance, Freight) value of the shipment. On a 1,000-tonne shipment with a CIF value of, for example, EUR 600,000, a 10% duty represents EUR 60,000. If a valid preferential CO reduces that duty to 0% or 5%, the saving is directly material to the buyer’s landed cost.

Beyond duties, a CO may also be required for:

• Anti-dumping and countervailing duty determination — to confirm the steel is EU-origin and therefore excluded from third-country anti-dumping orders
• Import licensing — some countries require a CO as part of the import permit application process for steel
• Letter of Credit compliance — LC terms often require a CO as one of the stipulated documents for payment
• Pre-shipment inspection clearance — PSI agencies may require the CO to confirm origin claims in the export documentation

Rules of Origin for Steel: What Qualifies as German/EU Origin?

For a product to claim preferential EU origin, it must satisfy the relevant “rules of origin” defined in the applicable trade agreement. For reinforcing steel produced in Germany from EU-sourced billets or scrap, the manufacturing process — hot-rolling into final bar or coil — typically constitutes sufficient “substantial transformation” to qualify as EU origin under most agreements. The precise test depends on the specific trade agreement and the HS heading of the product (for rebar: HS Chapter 72).

Exporters are responsible for correctly assessing and declaring origin. Where the supply chain involves non-EU origin billets, the origin determination must be reviewed carefully. An incorrect origin declaration — including on an invoice statement or REX statement — can result in customs penalties for the importer and disqualification of the preferential claim.

Certificate of Origin in the Export Documentation Package

For a complete rebar export shipment, the CO sits alongside the following documents:

See our guides to export and delivery documentation, pre-shipment inspection of steel, and HS codes for steel rebar for more detail on each component of the export document set.

Practical Steps for Buyers Requiring a Certificate of Origin

When placing an order for German rebar, buyers should:

• Confirm whether a CO is required by their country’s customs authority and, if so, which type (non-preferential ordinary CO, EUR.1, or invoice/REX statement)
• State the CO requirement clearly in the purchase order so the exporter can arrange it from the outset
• Verify with their customs broker whether their country of import has an EU trade agreement that grants preferential tariff access, and at what rate
• Ensure the CO information (description of goods, HS code, exporter details) is consistent with the commercial invoice and packing list — inconsistencies are a common cause of customs query