   
  
G/RO/W/191  
 
9 October 2019  
(19-6521) Page: 1/9 
Committee on Rules of Origin  Original: English  
 
 
DIRECT CONSIGNMENT R ULES AND LOW UTILIZATION  OF TRADE PREFERENCE S 
SUBMISSION BY THE LD C GROUP  
The following submission, dated 7 October 2019, is being circulated at the request of the delegation 
of Tanzania on behalf of the LDC Group . 
_______________  
 
1. The note presented by the WTO secretariat at the Committee on Rules of Origin "Utilization 
rates under preferential trade arrangeme nts for Least Developed countries under the LDC duty 
scheme1" (hereinafter the WTO note ) identified a series of issues related to paragraph 3.1 of the 
Nairobi decision on documentary evidence.  
2. The main issues discussed in the WTO note  relate to the low ut ilization of trade preferences 
for Agricultural products. More specifically, the WTO note  identified a number of country -products 
pairs where low utilization of trade preferences was recorded and direct consignment requirements 
were indicated as possible r easons for such low utilization. In fact , the products identified, mainly 
fruits, vegetables and mineral products, were subject to a wholly obtained origin criterion2 that is 
usually easily complied with given the nature of the products. The WTO note  indicated that 
documentary evidence related to direct consignment requirement could explain the reason for such 
low utilization.  
3. In particular the WTO note  identified a number of cases "show[ing] that direct transportation 
and certification requirements also ha ve a direct impact on utilization".  
4. In the same vein , another WTO document titled "Impact of the direct consignment 
requirement on preference utilization by least developed countries"3 further corroborates the 
analysis made in the previous WTO document: " The calculation of utilization rates in this note offers 
a clear indication that direct consignment requirements have a significant influence on the ability of 
LDCs to utilize trade preferences, particular those of landlocked LDCs"4. 
5. The fact that document ary evidence related to direct consignment requirements could be an 
insurmountable obstacle to utilization of trade preferences by LDC, especially landlocked and islands 
LDCs, has been initially identified by UNCTAD5 and repeatedly raised by the LDC Group a number of 
times.  
6. Such concern was reflected in paragraph 1.8 of the Bali Ministerial D ecision:  
"1.8 The documentary requirements regarding compliance with the rules of origin should be 
simple and transparent. For instance, requirement to provide proof of non -manipulation or 
                                                
1 See WTO document G/RO/W /185 dated 9 May 2019 . 
2 See paragraph 6.5 and 6.6 of WTO document G/RO/ W/185 dated 9 May 2019.  
3 See WTO document G/RO/W /187 dated  1 October 2019 . 
4 See paragraph 6.1 of WTO document G/RO/W/187 dated 4 October 2019 . 
5 See UNCTAD tra ining materials prepared for the CRO LDCs dedicated session of July 2015 and 
UNCTAD H andbook s on Duty -Free and Quota -Free Market Access and Rules of Origin for Least Developed 
Countries, UNCTAD/ALDC/2018/5 (Part I) , and UNCTAD/ALDC/2018/5 (Part II ). G/RO/W/191  
 
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  any other prescribed form for a certification of origin for products shipped from  LDCs across 
other Members may be avoided. With regard to certification of rules of origin, whenever 
possible, self -certification may be recognized. Mutual customs cooperation and monitoring 
could complement compliance and risk -management measures. " 
7. Paragr aph 3.1 of the Nairobi Ministerial D ecision reiterates such concern providing the 
following:  
"3.1. With a view to reducing the administrative burden related to documentary and 
procedural requirements related to origin, Preference -granting Members shall:  
a)  As a general principle, refrain from requiring a certificate of non -manipulation for 
products originating in a LDC but shipped across other countries unless there are 
concerns regarding transhipment, manipulation, or fraudulent documentation; and  
b)  Consider other measures to further streamline customs procedures, such as minimizing 
documentation requirements for small consignments or allowing for self -certification."  
8. The LDC Group has faced opposition from some preference -giving Members  during the 
negot iations leading to the Nairobi decision on the issue of direct consignment. Such resistance to 
change was , in some cases , deliberate while in other cases , was also deriving from a 
misunderstanding about the requests from the LDCs.     
9. In this technically c omplex area it is important to clarify the issue at stake and what action is 
required by preference -giving Members to bring their requirements into conformity with the Bali and 
Nairobi Ministerial Decision s.  
10. Direct consignment requirements are provisions inserted in most Preferential Trade 
Agreement s (PTAs), either of a unilateral or reciprocal nature, to ensure that the originating goods 
exported from country A are the same as those imported in to country B and that they have not been 
manipulated or furthe r processed during transportation through third countries. Invariably , every 
PTA recognizes that due to geographical or logistic reasons the originating goods from country A 
may have to transit through  a third country in order to be delivered to country B.  
11. However where the practices of the majority of PTAs and especially the DFQF provisions of 
preference -giving Members  differs widely is the documentary evidence to be provided at the time of 
importation in country B in case of passage through the territory of a third country.  
12. The majority of administrations requir e documentary evidence o f non-manipulation during the 
transit in the territory of the third country and that the goods have not entered the customs territory 
of the third country. Such documentary evidence in the majority of preference -giving Members  is: 
1) a through bill of ladin g covering the transit through the third country ; and  2) a certificate of 
non-manipulation provided by the customs authority of the country of transit stating that the goods 
have remained under customs control etc.  
13. The issue is that such documentary eviden ce is not easy to obtain and/or it may entail a 
significant cost. As contained in Table 1 for QUAD countries and Table 2 for other preference -giving 
Members , the documentary evidence related to direct consignment is often a trough bill of lading 
covering t he passage through the third country or a statement by the customs of the third country 
of transit that the goods have not been manipulated during transit besides unloading, loading, and/or 
other operations necessary to preserve them in good condition. Non e of these documents are easy 
to obtain. Indeed, a through bill of lading may be impossible to produce because of the following 
reasons:  
1. Geographical or commercial reasons: in the case of some landlocked or island countries , 
there may simply be no ship ping agent capable of issuing a t hrough bill of lading and/or 
it may be too expensive or not convenient ; and 
2. The goods are sold by the LDC exporter or producer to an intermediary or to a hub and 
from that intermediary or hub are subsequently shipped to the country of final 
destination . 
 G/RO/W/191  
 
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  14. In these cases it is simply impossible to comply with the kind of documentary evidence of 
direct consignment demanded by some preference -giving Members  such a through bill of lading or 
a certificate of non -manipulation. S uch requirements are unduly penalizing goods that are originating 
in LDCs, especially SMEs that are often selling to traders rather than directly to the client located in 
the preference -giving Members.  Landlocked and island countries may be particularly di sfavoured 
due to geographical location or for being far from commercial routes.  
15. The Canadian requirements for direct consignment and the Eurasian Custom s Union's 
requirements  for direct purchase on the one hand, and the EU GSP corresponding provisions on the 
other hand, are at the opposing poles of the existing practices in this area.  
16. The Canadian General Preferential tariff provisions for the documentary evidence of direct 
consignment contains unusually strict and detailed requirement as follows:  
"Direct  shipment requirements6 
The goods must be shipped directly on a through bill of lading (TBL) to a consignee in Canada from 
the LDC in which the goods were certified. Evidence in the form of a TBL (or a copy) showing that 
the goods have been shipped directl y to a consignee in Canada must be presented to the CBSA upon 
request.  
The TBL is a single document that is issued prior to the goods beginning their journey when the 
carrier assumes care, custody, and control of the goods, and it is used to guarantee the direct 
shipment of goods from the country of origin to a consignee in Canada. It generally contains the 
following information:  
(a) Identity of the exporter in the country of origin;  
(b) Identity of the consignee in Canada;  
(c) Identity of the carrier or ag ent who assumes liability for the performance of the contract;  
(d) Contracted routing of the goods identifying all points of transhipment;  
(e) Full description of the goods and the marks and numbers of the package;  and 
(f) Place and date of issue.  
Note: 
A TBL that does not include all points of transhipment may be accepted, if these are set out in related shipping 
documents presented with the TBL.  
On a case -by-case basis, an amended TBL may be accepted as proof of direct shipment where documentation 
errors  have occurred, and the amended TBL corrects an error in the original document.  
In such cases, the carrier must provide proof that the amended TBL reflects the actual movement of the goods 
as contracted when the goods began their journey. Documentation pre sented must clearly indicate the actual 
movement of the goods.  
Air cargo is usually transhipped in the air carrier 's home country even if no transhipment is shown on the house 
air waybill. Therefore, where goods are transported via airfreight, the house ai r waybill is acceptable as a TBL.  
Under the LDCT treatment, goods may be transhipped through an intermediate country, provided that:  
- They remain under customs transit control in the intermediate country;  
- They do not undergo any operation in the interme diate country, other than unloading, reloading ;  
- Splitting up of loads or any other operation required to keep the goods in good condition;  
- They do not enter into trade or consumption in the intermediate country;  
- They do not remain in temporary stor age in the intermediate country for a period exceeding six months.  
A consignee in Canada must be identified in field No. 2 to ensure that the exporter in the beneficiary country 
certified the origin of the goods according to Canadian rules of origin. The c onsignee is the person or company, 
whether it is the importer, agent or other party in Canada, to which goods are shipped under a through bill of 
lading (TBL) and is so named in the bill. The only exception to this condition may be considered when 100 % of 
the value of the goods originates in the beneficiary country in question, in which case no consignee is required."  
  
                                                
6 Available from https://www.cbsa -asfc.gc.ca/trade -commerce/tariff -tarif/ldct -tpmd-
eng.html?wbdisable=true . G/RO/W/191  
 
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  17. The combination of such requirements is simply overwhelming in the context of today 's 
business transaction s and does not correspond to comm ercial realities. The requirement that a 
consignee in Canada should be identified in Box 2 of the certificate of origin practically nullifies any 
possibility for trade through  intermediaries or third country invoicing.   
18. Canada has granted special waivers7 from such stringent consignment requirements to 
Mexico, Haiti, and China to take into account their special situations but not to LDCs although it was 
so requested during the negotiations leading up to the Nairobi Decision.   
Table 1 - QUAD countries requirements in terms of documentary evidence of direct 
consignment8 
WTO Member  Administrative  
Requirements  Other requirements  Compliance with paragraph 
3.1 of Nairobi Decision  
European Union  
(EBA)i Non alteration principle: 
documentary evidence of direct 
consignment is not required unless 
EU customs have doubts  In case of  doubt E U 
customs authorities 
may request evidence 
of non-alteration  by 
"any means " YES, most liberal since 
reform of EBA RoO in 2011  
United States 
(GSP)ii 1. Goods r emained under 
customs control in  the country 
of transit  
2. The US Port director is satisfied 
that the importation results 
from the original commercial 
transaction ; and  
3. Goods w ere not subjected to 
operations other than l oading 
and unloading   
 (Source: 19 CFR 10.175)iii Shipping and other 
documents must show 
US as final destination  NO, first there is the 
requirement that the US is 
shown as final destination 
and for goods not showing 
US as country of final 
destination a number of 
requirements apply.  
United States 
(AGOA)iv Same as above  Same as above  NO, evidence is required  
Japanv 1. A through bill of lading ;  
2. A certification by the customs 
authorities or other 
government authorities of the 
transit countries; or    
3. Any other substantiating 
document deemed sufficientvi  NO, evidence is required  
Canadavii - The goods must be shipped 
directly on a TBL to a 
consignee in Canada from the 
beneficiary or LDC in which the 
goods were certified.    
- Evidence in the form of a TBL 
(or a copy) showing that the 
goods have been shipped 
directly to a consignee in 
Canada mus t be presented to 
the CBSA upon request.  Special waiver exists for 
goods coming from 
Mexico;  Haiti;  and 
Hong Kong, China 
where the documentary 
evidence is substantially 
relaxed  NO, evidence is required  
 
                                                
7 See paragraph 82 Memorandum D11 -4-4, Ottawa, 16 October 2017:  
"Some exceptions exist where goods may be entitled to alternative shipping requirements. For more 
information, please refer to Memorandum D11 -4-9, Goods Originating in Mexico, Deemed to be Directly 
Shipped to Canada for the Purposes of the General Preferential Ta riff (GPT), Memorandum D11 -4-10. 
Instructions Pertaining to the China Direct Shipment Condition Exemption Order, or Memorandum D11 -4-28, 
Haiti Goods Deemed to be Directly Shipped to Canada for the Purposes of the General Preferential  Tariff (GPT) 
and the Least Developed Country Tariff (LDCT) ". 
8 Table s 1 and  2 have been drafted on the basis of existing notifications made to WTO, expanding the 
first version prepared by UNCTAD in 2015 ( https://unctad.org/meetings/en/Presentation/aldc2015_06 -
agenda6_wto_en.pdf ). The authors are open for discussions to improve the content of the table.  G/RO/W/191  
 
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  Table 2 - NON QUAD countries requirements in terms of documentary evidence of direct 
consignment9 
WTO Member  Administrative Requirements  Compliance/ 
comments  
Norwayviii - The WTO notification appears to not have been updated.  The latest 
Customs legislation available on the  internet provides for the 
non-alteration  ruleix  Yes, according to 
latest legislation  
Switzerlandx - According to information from the Swiss delegation,  Switzerland 
adopted the non-alteration  principle in 2017. Yes, to be checked at 
CRO  
New 
Zealandxi - Not required at point of import. Any normal transaction/commercial 
documents on request.    YES 
Australiaxii - There are no direct shipment requirements for LDC preferences    YES 
Eurasian   
CUxiii - Goods must be directly purchased  by the importer ; 
- Goods must be delivered directly ; 
- Not clear if documentary evidence of direct delivery is requiredxiv. NO, direct purchase 
is a unique 
requirement  
Chinaxv - As regards imported goods transiting a third country (region), relevant 
documents that, according to the Customs of China, are necessary to 
certify that the goods remains under customs controlxvi NO, evidence is 
required 
Indiaxvii - Requirement of direct shipment ; 
- The following shall be produced to the customs authority of India at 
the time of importation:    
 (a) a through Bill of Lading issued in the exporting country;   
 (b) a certificate of origin issued by the Issuing Authority of the 
exporting beneficiary country;    
 (c) a copy of the original commercial invoice in respect of the product; 
and   
 (d) supporting documents in evidence that other requirements of 
rule 7 (direct shipment) have been complied with . NO, evidence is 
required  
Rep. of  
Koreaxviii With respect to the goods which are not imported directly from the country 
of origin, but via a third country, if the relevant customs office, the 
institution authorized to issue certificates, or the chamber of commerce 
and industry of the third country confirms the country of origin of the 
relevant goods or issues a certificate to  that effect, the country of origin 
and a certificate to that effect shall be confirmed based on the certificate of 
origin issued by the country of origin for the relevant goods . NO, Evidence is 
required  
Chinese 
Taipeixix Excerpt from notified text "The exp orters from LDCs could present the self -
proof documentary of direct shipment to Customs ". Unclear  
Thailandxx (a) An Air Waybill, a t hrough Air Waybill, a Bill of Lading, a through  Bill of 
Lading or a multimodal or combined transportation document, that 
certifies the transport from the exporting DFQF beneficiary country to 
the Kingdom of Thailand, as the case may be. In the case of not 
having a through Air Waybill or through Bill of  Landing, supporting 
documents issued by the customs authority or other competent entity 
of other DFQF beneficiary country(s) or non -beneficiary country(s) that 
authorized this operation, according to its domestic legislation, are 
required;    
(b) An origin al Certificate of Origin (Form DFQF) issued by the issuing 
authorities of exporting DFQF beneficiary country; and    
(c) A commercial invoice in respect of the goods.  NO, evidence is 
required  
 
19. The LDC Group has observed the positive evolution of EU requirements in terms of 
documentary evidence related to direct shipment. The standard formulation of the documentary 
evidence of direct consignment in the EU FTAs and previous GSP regulations has traditionally been 
as follows:  
"1. The preferential treatment provided for under the Agreement applies only to products, 
satisfying the requirements of this Protocol, which are transported directly between the 
Community and (FTA partner country) or through the territories of the other countries  
referred to in Articles 3 and 4 with which cumulation is applicable  
However, products constituting one single consignment may be transported through 
other territories with, should the occasion arise, transshipment or temporary 
warehousing in such territor ies, provided that they remain under the surveillance of the 
customs authorities in the country of transit or warehousing and do not undergo 
                                                
9 See footnote 8 . G/RO/W/191  
 
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  operations other than unloading, reloading or any operation designed to preserve them 
in good condition  
2. Evidence  that the conditions set out in paragraph 1 have been fulfilled shall be supplied 
to the customs authorities of the importing country by the production of:  
(a) a single transport document covering the passage from the exporting country 
through the country of transit; or  
(b) a certificate issued by the customs authorities of the country of transit:  
(i) giving an exact description of the products;  
(ii) stating the dates of unloading and reloading of the products and, where 
applicable, the names of the ships, or the other means of transport used;  
(iii) certifying the conditions under which the products remained in the transit 
country; or  
(iv) failing these, any substantiating documents. " 
20. As discussed in Inama (2020)10 and contained in the EU manual11, the proof  required for 
documentary evidence under such standard formulation could take any of the three forms outlined 
in paragraph (2). "In the absence of a single transport document (e.g. a through bill of lading) the 
customs authorities of the countries through which the goods transit must provide documentary 
proof that the consignment was at all times under their surveillance when on their territory. Such 
proof must contain the details outlined in paragraph (2) above. In simple terms, such documentary 
proof must  detail the history of the journey of the consignment through their territory and the 
conditions under which the surveillance has been conducted. This documentary proof is known as a 
certificate of non -manipulation . In the absence of either of the foregoin g proofs any other 
substantiating documents can be presented in support of a claim to preference. However, it is difficult 
to envisage any other documents (e.g. commercial documents) that would adequately demonstrate 
that all the conditions of paragraph 1 of the Article were satisfied" . 
21. Most recently, the EU introduced the concept of non -alteration with significant trade facilitating 
provisions. According to the non -alteration formulation introduced in the EU GSP and progressively 
in many EU FTAs such as th e EU-Japan reproduced below. According to the non -alteration concept 
only in case of doubt, the European Union customs authorities request the declarant to provide 
evidence of compliance (Paragraph 4 of article 3.2 below of the EU Japan FTA). Without reaso nable 
doubt, it will be assumed that direct consignment requirements are met. Systematic evidence of 
direct consignment is no longer required.  
22. It is important to emphasize that, even in the case where documentary evidence is requested 
the proof of direct c onsignment may be given "by any means". The leniency of such a provision 
contrast with the usual provisions of many preference -giving Members  in Tables 1 and 2 where often 
the proof of direct consignment may be given only by a through bill of lading or doc umentary 
evidence in the form of a certificate or statement of non-manipulation  provided by the Customs 
authorities of the country of transit.  
23. A guide from the EU further specifies the difference between the old legislation on evidence 
of documentary evid ence and the new non -alteration principle:  
"An important difference between the previous direct transportation requirement and 
non-manipulation  clause ( non-alteration principle) lies in documentary evidence to be 
provided. Until  31 December 2010, with direct transport in all cases where the goods were 
transported via another country, except where the country of transit was one of the countries 
of the same regional group, the EU importer was required to present documentary evidence 
that the goods did not  undergo any operations there (in the country of transit), other than 
unloading, reloading or any operation designed to keep them in their condition. The types of 
the referred documentary evidence were strictly defined in the law. The new non -manipulation 
(non-alteration principle) clause shall be considered as satisfied a priori  unless the customs 
                                                
10 See "Rules of origin in international trade Stefano Inama, Cambridge University Press, Forthcoming 
2020.  
11 A User's Handbook to the Rules of Preferential Origin used in trade between the European 
Community, other European Countries and the countries pa rticipating to the Euro -Mediterranean Partnership . G/RO/W/191  
 
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  authorities have reasons to believe the contrary; in such cases, the customs authorities may 
request the declarant to provide evidence of compliance, which may b e given by any means12". 
24. The LDC Group believe that the non-alteration  principle provision introduced by the EU or 
similar arrangements such those adopted Australia and New Zealand may constitute a best practice 
that should be progressively adopted by other preference -giving Members . The LDC Group calls to 
the other preferen ce-giving Members  to start considering the move to a similar approach abandoning 
requirements for a t hrough bill of lading and certificate of  the non-manipulation that do not adhere 
to business realities and trade facilitation practices. The LDC  Group  will enter into consultations with 
the EU to share the experience gained from the adoption of the non-alteration principle and the 
advantages to be gained in adopt ing similar best practices. The result s from such  consultation s will 
be shared in the forthcoming  CRO meetings to accelerate adoption of best practices in line with trade 
facilitation objectives and simple and transparent rules of origin for LDCs.  
Box 1 – Non-alteration provision in EU -Japan FTA  
 
__________  
i See G/RO/LDC/N/EU /1. 
ii See G/RO/LDC/ N/USA/1 . 
iii § 10.175 Imported directly defined  as follows:  
"Eligible articles shall be imported directly from a beneficiary developing country to qualify for treatment 
under the Generalized System of Preferences. For purposes of § 0.171 through 10.178 the words "imported 
directly " mean:  
(a) Direct shipmen t from the beneficiary country to the United States without passing through the 
territory of any other country; or  
(b) If the  shipment  is from a beneficiary developing country to the US through the  territory  of any other 
country, the merchandise in the  shipmen t does not enter into the commerce of any other country 
while en route  to the US, and the invoice, bills of lading, and other shipping documents show the US 
as the final destination; or  
(c) If shipped from the beneficiary developing country to the United State s through a free trade zone in 
a beneficiary developing country, the merchandise shall not enter into the commerce of the country 
maintaining the free trade zone, and  
1. The eligible articles  must not undergo any operation other than:  
(i) Sorting, grading, or tes ting; 
(ii) Packing, unpacking, changes of packing, decanting or repacking into other containers,  
(iii) Affixing marks, labels, or other like distinguishing signs on articles or their packing, if 
incidental to operations allowed under this section ; or 
                                                
12 The European Union's rules of origin for the Generalised System of Preferences A Guide For Users , 
May 2016 .                                                 ARTICLE 3.10 Non -alteration  
An originating product declared for home use in the importing Party shall not have, after 
exportation and prior to being declared for home use, been altered, transformed in any way or 
subjected to operations other than to prese rve them in good condition or than adding or affixing  
marks, labels, seals or any other documentation to ensure compliance with specific domestic 
requirements of the importing Party.  
Storage or exhibition of a product may take place in a third country pro vided that it remains under 
customs supervision in that third country.  
Without prejudice to Section B, the splitting of consignments may take place in a third country if 
it is carried out by the exporter or under its responsibility and provided that they remain under 
customs supervision in that third country.  
In case of doubt as to whether the requirements provided for in paragraphs 1 to 3 are complied 
with, the customs authority of the importing Party may request the importer to provide evidence 
of compl iance, which may be given by any means, including contractual transport documents such 
as bills of lading or factual or concrete evidence based on marking or numbering of packages or 
any evidence related to the product itself.  G/RO/W/191  
 
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(iv) Operations necessary to ensure the preservation of merchandise in its condition as 
introduced into the free trade zone.  
2. Merchandise may be purchased and resold, other than at retail, for  export  within the free trade 
zone.  
3. For the purposes of this section, a free trade zone is a predetermined area or region declared 
and secured by or under governmental authority, where certain operations may be performed 
with respect to articles, without such articles having  entered  into the commerce of the country 
maintaining the free trade zone; or  
(d) If the  shipment  is from any beneficiary developing country to the US through the  territory  of any 
other country and the invoices and other documents do not show the US as the final destination, 
the articles in the  shipme nt upon arrival in the US are imported directly only if they:  
1. Remained under the control of the  customs authority  of the intermediate country;  
2. Did not enter into the commerce of the intermediate country except for the purpose of sale 
other than at retail, and the  Centre Director is satisfied that the importation results from the 
original commercial transaction between the importer and the producer or the latter's sales 
agent; and  
3. Were not subjected to operations other than loading and unloading, and other a ctivities 
necessary to preserve the articles in good condition; or… " 
iv G/RO/LDC/N/USA/3 . 
v G/RO/LDC/N/JPN /1. 
vi The provision related to documentary requirement for proof of direct shipment is found in paragraphs 
3 and 5 of Article 31, Cabinet Order for Enforcement of the Temporary Tariff Measures Law.  
(Extract of the Cabinet Order for Enforcement of the Temporary Tariff Measures Law, provisional 
translation)  
Article 31, paragraph 3: Any person who intends to have paragraph 1 or 3 of Article 8 -2 of the 
Temporary Tariff Measures Law applied to those products enumerated in subparagraph (2) or (3) of paragraph 
1 shall , at the time of import declaration of such products, submit one of the following documents, as a 
document proving that such products fall under either of such subparagraphs. However, this shall not apply to 
those products for which the total amount of cus toms value is not more than 200,000 yen.  
(1) A copy of a through bill of lading for transportation of such products from a beneficiary of 
references as their origin, to the port of importation in Japan.  
(2) A certificate issued by Customs or any other co mpetent government authorities in a country of 
non-origin where the products were transshipped, temporarily stored or displayed at exhibitions, 
etc. as provided for in subparagraph (2) or (3) of paragraph 1.  
(3) Any documents which are considered by the D irector General of Customs to be appropriate, 
excluding those enumerated in the preceding two subparagraphs.  
Article 31, paragraph 5: The following items shall be described in the certificate provided for in 
subparagraph (2) of paragraph 3.  
(1) Marks, nu mbers, descriptions and quantities of the products under consideration.  
(2) Dates on which such products were loaded on board, and/or unloaded from, a vessel, aircraft or 
vehicle in the country of non -origin and names, registered marks or kinds of such ve ssels, 
aircraft or vehicles.  
(3) Details of the handling of such products in the country of non -origin where the loading or 
unloading as provided for in the preceding subparagraph took place.  
vii G/RO/LDC/N /CAN/1 and G/RO/LDC/N /CAN/2.  
viii G/RO/LDC/N/NOR /1. 
ix See Regulations to the Act on Customs Duties and Movement of Goods (Customs Regulations), 
January 2019 Section 8 -4-38, Direct transport:  
(1) The products that are declared for importation to Norway, shall be the same as those that are 
exported from the GSP country where they are regarded as originating from. They must not have 
been changed, converted in any way or undergone treatments other tha n treatments that have 
the purpose of keeping them in good condition before they are declared. Storage of products or 
consignments and splitting of consignments may occur if this takes place under the responsibility 
of the exporter or a subsequent holder o f the goods and the products remain under the customs 
authorities' supervision in the transit country(ies).  
(2) Sub-section (1) is deemed to be met, unless the customs authorities have reason to believe that 
the opposite is the case. In that respect, the customs authorities may request that the declarant 
or customs debtor proves compliance. Proof can be provided with the assistance of any means, 
including contractual transport documents such as, for example, bill of lading or factual or 
specific evidence b ased on labelling or numbering of packages or any form of evidence 
associated with the actual goods.  
(3) Sub-sections (1) and (2) apply correspondingly for cumulation pursuant to Section 8 -4-35.  
x G/RO/LDC/N/CHE /1. 
xi G/RO/LDC/N/NZL /1. 
xii G/RO/LDC/N/AUS /1 and G/RO/LDC/N/AUS/ 1/Rev.1. 
xiii G/RO/LDC/N/RUS /1 and Decision No. 60 of the Council of the Eurasian Economic Commission dated 
14 June 2018 . 
xiv See for further details Decision No. 60 of the Council of the Eurasian Economic Commission dated 
14 June 2018 . 
xv G/RO/LDC/N/ CHN/1. G/RO/W/191  
 
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xvi Excerpt from notification made to WTO:  
3. Transport documents covered the whole route from the beneficiary country to ports of entry in 
China;  
4. For goods transported into the territory of China through other countries or regions, imp orters 
shall submit certified documents issued by customs of that country or region or other documents 
accepted by China customs. Those certified documents mentioned above are not compulsory 
when customs has obtained electronic data information of certifie d documents via related 
electronic data system for transshipment. If the transport documents are determined by China 
customs to be sufficient to fulfil the requirement of the Direct Consignment, importers are not 
required to submit certified documents. Sup porting documents required when the transport of 
consignment involves transit:  
- Customs Announcement No. 57, promulgated in 2015; and  
- Customs Announcement No. 52, promulgated in 2016."  
xvii G/RO/LDC/N/ IND/1. 
xviii G/RO/LDC/N/ KOR/1. 
xix G/RO/LDC/N/ TPKM/ 1 and G/ RO/LDC/N/TPKM/1/Corr.1.  
xx G/RO/LDC/N/ THA/1.  