India–UAE CEPA in practice: how to claim preferential duty and avoid certificate-of-origin rejections

The India–UAE Comprehensive Economic Partnership Agreement (CEPA) entered into force on 1 May 2022. According to India's Department of Commerce, the UAE committed to eliminate duties on 97% of its tariff lines, covering 99% of Indian exports by value, while India gave preferential access to a large share of UAE goods.

Preferential duty is not automatic. The importer must claim it, the goods must meet the agreement's rules of origin, and the certificate of origin must be correct. Many problems arise from small errors in this process. This article explains the practical steps for exporters and importers on both sides.

Step 1: check that your goods qualify

Under Chapter 3 of the CEPA, a product is originating if it is wholly obtained in India or the UAE (for example, crops grown and harvested there), or if it has been sufficiently processed there according to the product-specific rules in Annex 3B.

For many manufactured goods, the general rule combines a minimum value addition of 40% of the FOB value with a change in tariff classification of the non-originating inputs. Some sectors have different rules. Steel products require 'melt and pour' in the exporting country, and some agricultural goods must be wholly obtained. Always check the specific rule for your HS code.

A worked value-addition example

Suppose an Indian manufacturer exports a product with an FOB value of USD 10,000. Imported components from a third country cost USD 5,500, and all other materials, labour and overheads are Indian. Value addition is (10,000 minus 5,500) divided by 10,000, which is 45%. This passes a 40% threshold, provided the change-in-classification condition is also met.

If the imported components rose to USD 6,500, value addition would fall to 35% and the goods would not qualify, even if they were assembled in India. Note that inputs bought from a local trader are not automatically originating; if the trader imported them, they count as non-originating.

Rules that often cause problems

• Minimal operations: preservation during transport, repacking, washing, simple labelling or simple assembly do not confer origin on their own (Article 3.5).
• Direct consignment: goods must be transported directly between India and the UAE. Transit through a third country is allowed only under customs control, with no processing other than unloading, reloading or storage (Article 3.12).
• Third-party invoicing: an invoice issued by a company in another country does not by itself prevent a claim, but the certificate must indicate third-party invoicing (Article 3.15).
• De minimis: non-originating materials that do not meet the change-in-classification rule may still be allowed up to 10% of the FOB value, with different limits for textiles (Article 3.4).

Step 2: obtain the certificate of origin

Indian exporters apply on the DGFT common digital platform for certificates of origin (coo.dgft.gov.in), using a Class III digital signature certificate. The application is processed by a designated issuing agency. You will usually need the commercial invoice and a minimum information statement showing the cost breakdown, origin calculation and manufacturing process. Certificates carry a QR code that customs can use to verify them.

UAE exporters apply to the Ministry of Economy through its online service for a certificate of origin for India. The factory must first be registered in the Ministry's factory registration service, and the application needs the commercial invoice (and a purchase certificate from the factory if the exporter is a trading company). The Ministry lists fees from AED 10 to AED 200 depending on invoice value, and an average processing time of one working day.

Certificate rules to get right

• The certificate must be in English, follow the format in Annex 3E and cover only one import consignment.
• It is valid for 12 months from the date of issue and must be presented to customs within that period.
• It should be issued before or at the time of export, or within five working days of shipment. In exceptional cases it can be issued retrospectively, marked 'Issued Retrospectively', but not more than 12 months after shipment.
• The invoice number and date on the certificate must match the commercial invoice. The HS code, description and quantity must match the goods.
• Minor typing errors do not automatically invalidate a certificate, but errors in the issuing authority's signature or seal are not treated as minor.
• If the original is lost, a certified true copy can be requested within the validity period.

Step 3: claim at import and be ready for verification

The importer claims the preferential rate in the customs declaration and must present the certificate when required. In India, the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020, known as CAROTAR, also require the importer to hold enough origin information to support the claim and to provide it on request. Since an amendment in March 2025 (Notification No. 14/2025-Customs (N.T.)), these rules refer to 'proof of origin' rather than only 'certificate of origin', and customs may ask for more supporting documents within tighter response times.

If customs doubts a claim, it can ask the exporting country's authority to verify it. The CEPA sets response times: 15 days to confirm authenticity of the certificate, 30 days to provide the minimum information document, and 90 days (extendable by up to 60 days) for a full origin check. Preferential treatment can be denied if records are not kept or information is not provided in time. Exporters and producers must keep supporting records for at least five years.

Checklist to avoid rejections

• Confirm the six-digit HS code with your buyer before applying, and check the CEPA rule for that code.
• Calculate value addition from actual cost records, not estimates, and keep the calculation on file.
• Collect supplier declarations or invoices for every input you treat as originating.
• Apply for the certificate before shipment and check every field against the invoice and packing list.
• Ship directly, or keep transit documents showing goods stayed under customs control.
• Send the certificate to the importer promptly and keep copies for five years.
• Answer verification requests quickly and completely.

This guide is general information. For a specific product, confirm the rule and documentation with DGFT, the UAE Ministry of Economy or your customs broker.

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