G/RO/W/229  
 
19 April 2024  
(24-3299) Page: 1/42 
Committee on Rules of Origin  Original: English   
 
 
TOWARDS SIMPLE AND TRANSPARENT RULES OF ORIGIN FOR LDCS:  
CONVERGENCE ON  APPLICABLE  RULES OF ORIGIN  CRITERIA  
FOR MOST EXPORTED PRODUCTS FROM LDCS UNDER DFQF  
SUBMISSION OF THE LEAST DEVELOPED COUNTRIES  
The following submission, dated 17 April 2024, is being circulated at the request of the delegation 
of Togo on behalf of the LDC Group . 
 
_______________  
 
1  INTRODUCTION  
1.1.  With the aim of facilitating an effective work of the CRO, the WTO LDCs Group presented a 
tentative work program1 for 2023 -2024 containing a list of issues where the LDCs are planning to 
present submissions. The theme of the present submission has been reflected in such a work 
program and therefore ample time has been provided to provide sug gestions or comments.  
1.2.  The work program was designed to inform the CRO and delegates about the issues that may 
be addressed during the biennium 2023 -2024. This aims to achieve two main objectives: 1) to allow 
early preparation and contributions with the ob jective of holding fruitful CRO discussions, and 2) to 
effectively report the results of the debate and outcomes at the next MC. The work program will be 
updated shortly to introduce the themes and submissions for the next CROs of 2024 and 2025, while 
remaining open to suggestions and comments.  
1.3.  The LDC WTO group may also explore the possibility of holding intersessional CRO meetings, 
subject to necessity and in agreement with other WTO Members.  
1.4.  This work program  provides for the next CRO on 29 April 2024, two communications from the 
WTO LDC group, one of which concerns the convergence of applicable rules of origin.  
2  THE CASE FOR EXAMINING CONVERGENCE ON RULES OF ORIGIN FOR LDCS  
2.1.  The WTO LDC Group welcomes the opportunity to address the CRO after the Report of the 
Committee on Rules of origin to the General Council on preferential rules of origin for Least 
Developed Countries2 (Hereinafter "the Report "). 
2.2.  In this context, it is recalled that section 7 of the abo ve-mentioned Report, named "conclusion 
and next steps, " provides for a course of action of the work to be carried out by the CRO to improve 
LDC rules of origin. In particular, the LDC WTO group would like to underscore the importance of 
paragraphs 7.2 and 7.3 reproduced below:  
"7.2. In addition to the above and in conformity with the Decision of the Committee on Rules 
of Origin on preferential rules of origin adopted on 14 April 2022, Members will continue and, 
to the extent possible, intensify their work on identifying and where possible, agreeing on best 
practices on preferential rules of origin and related administrative requirements.  
 
 
1 Tentative work program: WTO/AIR/RO/16 , CRO Meeting of 13 October 2022 . 
2 See WTO document G/RO/99  of 24 November 2023:  
https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=q:/G/R O/99.pdf&Open=True . G/RO/W/229  
 
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  7.3. On the basis of the above, Members consider that in light of the divergent views of 
Members on the implementation o f the Bali and Nairobi Decisions and best practices in this 
regard, it is necessary to continue relevant discussions in the Committee on Rules of Origin 
as well as intensify bilateral engagement… " 
 
2.3.  Recent literature3 has examined developments in preferent ial RoO, which have led to 
simplifications and trade facilitating solutions introduced by administrations of preference -granting 
Members . These efforts have been observed in Free Trade Areas and unilateral trade preferences, 
such as those granted to LDCs. This evolution of RoO has been guided by lessons learned over more 
than 30 years of operation of major PTAs. In the context of LDC rules of origin, these developments 
have contributed to major reforms, including the Canadian reform of 20034, the EU reform  of 20115, 
the partial reform of Japan's GSP rules of origin6, and most recently, the introduction of new rules 
of origin for LDCs under the DCTS7. Further reforms are reportedly ongoing under the rules of origin 
of Canada and New Zealand. Additionally,  some other preference -granting Members  have introduced 
partial changes to rules of origin for LDCs, as recognized in the Report.  
2.4.  In light of the progress outlined above, it is both timely and crucial to initiate a dialogue 
regarding potential future refor ms on LDC rules of origin that may benefit from exchanges at 
multilateral level, in alignment with the spirit and conclusions of the Report. This dialogue aims to 
enhance discussions on best practices and foster convergence towards simple and transparent r ules 
of origin. While improvements in rules of origin are indeed welcomed, it would be best practice for 
these reforms to be based on shared practices. Such shared practices have the potential to generate 
a multiplying trade -facilitating effect on the util ization of trade preferences by firms.    
2.5.  For instance, the EU and the US, along with counterpart OECD nations such as Japan, South 
Korea, Australia, and New Zealand, have progressively moved away from methodologies of 
calculation of ad valorem percentage based on value -added. Instead, these preference -granting 
Members  have progressively adopted a value of materials calculation in major FTAs and, in some 
cases, in rules of origin for LDCs. It has to be noted that the US GSP and AGOA still adopt value -
added calculation. Furthermore, some innovations have been introduced, such as the deduction of 
the cost of freight and insurance in recent US PTAs and in the TPP, which has also been recently 
replicated in the UK DCTS.  
2.6.  This recent spillover effect serves as a v aluable example of the merit of discussing best 
practices at the multilateral level, while leaving adequate policy space for preference -granting  
Members  to design rules of origin for LDCs.    
2.7.  Recent studies8 have found that there is a "de facto " convergence on the adoption of Product -
specific rules of origin (PSRO) in many product’s sectors. This finding generates a potential trade 
facilitation phenomenon that need to be further examined, especially in the ca se of LDCs rules of 
origin.  
2.8.  Convergence on origin criteria and other administrative practices may represent a substantial 
scope to simplify and impart transparency on rules of origin for LDCs. The present submission starts 
to explore the scope for converg ence rules of origin applicable to main LDC exports.  
 
3 See Hoekman and Inama in East Asian Economic Review vol. 22, No. 1 (March 2018) 3 -28: 
https://papers.ssrn.com/sol3/papers.cfm ?abstract_id=3151371 .   
4  See for the Canadian reform of 2003: Challenges Faced by LDCs In Complying with Preferential Rules 
of Origin Under Unilateral Preference Schemes, G/RO/W/148  (Paper Presented by Uganda on Behalf of the 
LDCs Group) . 
5 For a review of the EU Reform of 2011 see WTO document above footnote 4 . 
6 For a discussion about the partial reform of Japan GSP rules of origin: Getting Better Rules of Origin for 
LDCs Using Utilization Rates , UNCTAD/ALDC/2019/3 . 
7 UK DCTS: https://www.gov.uk/government/collections/trading -with-developing -nations .   
8 See Inama and Crivelli 2017 and Inama; Rules of origin in international trade, Cambridge University 
Press , 2022:  https://assets.cambridge.org/97811070/81550/frontmatter/9781107081550_frontmatter.pdf ; 
and Challenges Faced by L DCs in Complying with Preferential Rules of Origin Under Unilateral Preference 
Schemes Paper Presented by Uganda on Behalf of the LDCs Group ( G/RO/W/148 ).  G/RO/W/229  
 
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  2.9.  The premise to better understand the scope of convergence of rules of origin criteria has been 
first discussed in a LDC submission made in 20149 . Such convergence approach has been applied 
in practice in recent studies10 carried out in the Asian region aiming at rationalizing the "noodle bowl " 
of different rules of origin growing exponentially in that region. The reasoning of convergence stems 
from distinguishing the "form" of a rules of origin from its  "substance ". The "form" is the way in 
which the rules are drafted using different methodologies (namely a change of tariff classification at 
heading level, at subheading level with or without exceptions, percentage criterion or specific 
working or process ing and their different variants). The "substance " is the manufacturing process 
necessary to comply with the "form". 
2.10.  One of the most classical examples is the PSRO for Chapter 1, concerning live animals. The 
PSRO can typically be drafted in one of three wa ys: 1) "Wholly obtained," 2) "A change to a good of 
heading 01.01 through 01.06 from any other chapter," or 3) "Change of chapter (CC)." Despite the 
differences in drafting, the substance remains consistent: for an Animal of chapter 1 to be considered 
as originating, the live animal must be born and raised in the country.  
3  INITIAL STEPS TO IDENTIFY POTENTIAL CONVERGENCE  
3.1.  Table 1 below lists the main 20 products at HS 4 -digit level that have been exported by LDCs 
in 2022 to Canada, US, EU, Japan China and India and represents 61.8% of the LDC dutiable trade 
to these preference -granting  Members . This is an initial submission that may be further elaborated 
and refined adding other preference -granting Members  and averages for multiple years to better 
capture the most representative products that LDCs are exporting to preference -granting Members . 
Table 1:  Most exported 20 products from LDCs to selected preference -granting 
Members : US, EU, Canada, Japan China and India ordered by descending 'Total Duties 
Paid' at the HS 4 -digit level  
HS Code  Produce description  
6203 Men's or boys' suits, ensembles,  jackets, blazers, trousers, bib and brace overalls, 
breeches and shorts (excl. knitted or crocheted, wind -jackets and similar articles, 
separate waistcoats, tracksuits, ski suits and swimwear)  
6110 Jerseys, pullovers, cardigans, waistcoats and similar articles, knitted or crocheted.  
7108 Gold (including gold plated with platinum) unwrought or in semi -manufactured forms, 
or in powder for  
6204 Women's or girls' suits, ensembles, jackets, blazers, dresses, skirts, divided skirts, 
trousers, bib an d brace overalls, breeches and shorts (excl. knitted or crocheted, 
wind-jackets and similar articles, slips, petticoats and panties, tracksuits, ski suits and 
swimwear)  
4202 Trunks, suit -cases, vanity -cases, executive -cases, brief -cases, school satchels, 
spectacle cases, bi  
6109 T-shirts, singlets and other vests, knitted or crocheted.  
1006 Rice 
6104 Women's or girls' suits, ensembles, jackets, blazers, dresses, skirts, divided skirts, 
trousers, bib and brace overalls, breeches and shorts, knitted or crocheted (excl. 
wind-jackets and similar articles, slips, petticoats and panties, tracksuits, ski suits and 
swimwear)  
8105 Cobalt mattes and other intermediate products of cobalt metallurgy  
6205 Men's or boys' shirts.  
7103 Precious stones (o ther than diamonds) and semi -precious stones, whether or not 
worked or graded but  
0713 Dried leguminous vegetables, shelled, whether or not skinned or split.  
2709 Petroleum oils and oils obtained from bituminous minerals, crude.  
6103 Men's or boys' suits, ensembles, jackets, blazers, trousers, bib and brace overalls, 
breeches and shorts (excl. wind -jackets and similar articles, separate waistcoats, 
tracksuits, ski suits and swimwear)  
1511 Palm oil and its fractions, whether or not refined, but not c hemically modified.  
7403 Refined copper and copper alloys, unwrought.  
 
9  See :” Challenges Faced by LDCs in Complying with Preferential Rules of Origin Under Unilateral 
Preference Schemes Paper Presented by Uganda on Behalf of the LDCs Group ( G/RO/W/148 ), 2014 . 
10 Developments regarding methods of calculation of the percentage criterion (paragraph 1.1 of the 
Nairobi Decision and item 1 of document G/RO/W/169  of 14 Ma rch 2017 and presentation RD/RO/52  of 4 
October 2017.  G/RO/W/229  
 
- 4 - 
 
  HS Code  Produce description  
4001 Natural rubber, balata, gutta -percha, guayule, chicle and similar natural gums, in 
primary forms or  
7402 Unrefined copper  
6403 Footwear with outer soles of rubber, plastics, leather or composition leather and 
uppers of leather  
6108 Women's or girls' slips, petticoats, briefs, panties, nightdresses, pyjamas, négligés, 
bathrobes, dressing gowns, housecoats and similar articles, knitted or crocheted (excl. 
T-shirts, ve sts, brassieres, girdles, corsets and similar articles)  
 
3.2.  It may be easily observed that the product composition of these 20 products is heavily 
concentrated on clothing products classified in HS 61 and 62 and a handful of mineral and agricultural 
products. An expansion of the list to cover the 100 most exported products would cover 94% of 
dutiable LDC exports. This preliminary observation indicates that convergence on rules of origin on 
a fraction of HS headings may lead to a significa nt step towards trade facilitation as LDC would have 
to comply with similar rules of origin criteria.  
3.3.  Table 2 below provides a comprehensive breakdown of the 20 most exported products, 
accompanied by the respective rules of origin applied by the EU, Japan,  and the UK. Notably, these 
preference -granting  Members  primarily employ product -specific rules of origin (PSRO), which may 
be set at chapter, heading, and, in certain instances, subheading levels. Japan adopts an across -
the-board CTH approach for products  not covered in its annex of product -specific rules of origin. The 
EU and the UK exclusively utilize PSRO.  
3.4.  Several observations may be made from a reading of table 2. The most striking factor is that 
for the clothing products of HS chapter 61 and 62 the PS R of EU, UK and Japan are similar, if not 
identical in terms of manufacturing requirements to obtain originating status: Manufacturing from 
non-originating fabrics.  
3.5.  This manufacturing requirement is common to all garments of chapters 61 and 62 for EU, Jap an 
and UK leading to a clear case for convergence beyond the "form" of the PSR as the wording of the 
PSROs are articulated differently. These differences are mostly deriving from technical drafting that 
may be addressed by a common understanding among the EU, UK and Japan. The case for 
convergence is different for shoes of heading 6403 where the manufacturing requirements are 
substantially similar for EU and UK but different in substance in the PSRO of Japan that excludes HS 
6406 parts of shoes from the CTH  PSRO.  
3.6.  When translated into manufacturing requirements, a notable disparity arises between the PSRO 
for shoes applied by the EU, UK, and Japan. Specifically, while the EU and UK PSRO consider the 
assembly of parts of shoes classified under HS 6406 into a c omplete shoe as conferring origin, 
Japan's PSRO takes a more stringent approach. Japan's PSRO excludes the use of non -originating 
parts of shoes by specifically excluding HS heading 6406, where such parts are classified according 
to the HS. This is clearly  an area of partial convergence, as Japan adopts a product -specific rule of 
origin that is notably more stringent than the criteria employed by the EU and UK.  
3.7.  Besides garments and shoes, the other main products concern gold where the PSROs are clearly 
divergent with EU having the most demanding criteria by introducing a series of CTH exclusions 
while Japan having a simple change of tariff heading with no exclusion of headings and UK being the 
most liberal by using a change of tariff subheading.  
3.8.  Heading 4202  trunks and suitcases shows partial convergence again among EU and UK 
providing for a CTH or VNOM 70% or 75% and Japan adopting a CTH with the exclusion of heading 
4205.     
3.9.  Rice of heading 1006 show drafting divergence on product -specific rules of origin with a wholly 
obtained rule in the case of EU and a different formulation in change of HS chapter in UK and CTH 
in Japan. Cobalt of heading 8105, precious stones of heading 7103 are also products that although 
not being import sensitive in preference -grant ing Members  still attract some degree of divergence 
with manufacture of any heading in the case of the EU that implicitly allows a CTSH while UK and 
Japan show more demanding requirements. The case of 2709 petroleum oil and natural rubber of 
4001 is simila r as there is partial convergence among EU and UK with a CTH and a VNOM of 70% or G/RO/W/229  
 
- 5 - 
 
  75% and with Japan only allowing CTH. Leguminous vegetables of heading 0703, shows convergence 
being an intrinsically wholly obtained product.  
3.10.  The remaining heading of HS1511  Palm oil and refined copper of 7403 are semi -manufactured 
products that may represent the first steps of insertion into value chains of light industries in LDCs 
showing convergence among EU and UK with a CTSH (with the exclusion of refined copper for UK) 
while Japan still having some rigidities caused by the exclusion of certain headings in both cases.   
3.11.  Table 2 below shows the potential duty savings that could be achieved through the full 
utilization of existing trade preferences, which are particularly n oticeable in certain headings. For 
example, gold indicates a potential duty saving of 383 million USD, while cobalt suggests a potential 
saving of 202.7  million USD, as illustrated in the "Missed Duty Savings" column. The "Total Duties 
Paid" column reflect s the combined value of duty payments under full coverage of preferences and 
full utilization, thereby demonstrating the scope for overall improvement in market access for LDCs. 
This underscores the significant benefits that could accrue to LDCs by maximiz ing the utilization of 
available trade preferences.  
3.12.  The total missed duty saving of the 20 products is equivalent to 1 ,493.6 USD million and the 
total duty paid is 4 ,726.78 USD million.  
3.13.  It is important to note that due to lack of data, mainly concerning th e other trade 
arrangements made available to LDC by China and India, table 2 and 3 below are not taking into 
consideration these additional trade preferences under these two preference -granting  Members .    
Legend : explanatory box to the following table 2 a nd table 3    
# Column  Description  
1 HS6 Harmonized System (HS) code at 6 -digit level  
2 Product 
Description  Product description of the internationally standardized system to classify traded product  
3 Total Imports  the value in current US thousand dollars of all imports by the PGC from the selected 
beneficiary during the selected year for the selected product  
4 DFQF Covered 
Imports  the value of imports that are classified in tariff lines that are dutiable and covered by the 
Duty-Free and Quota -Free (DFQF) scheme of the PGC  
5 DFQF Received 
Imports  the value of imports that received DFQF treatment.  
6 Other Pref. 
Imports   the value of imports that benefitted from non -reciprocal preferences other than DFQF and 
under selected Economic Partnership Agreements that the EU has entered with some 
African countries. Data on the following schemes are included: AGOA and the Caribbean 
Basin Initiative (CBI) in the case of the USA and the Economic Partnership Agreements 
entered by selected Sub -Saharan African countries with the EU.  
7 All Pref. Imports   the total value of imports that benefitted from preferences, i.e., the sum of DFQF -received 
and Other Preferential Imports.  
8 (COV/D but no 
REC/D Imports  DFQF covered imports, but there are no reco rded (REC) or reported (D for documented) 
imports of that item under DFQF  
9 Missed Duty 
Savings   The total number of duties paid could have been avoided if the exporter had taken all the 
necessary steps to qualify the product under the DFQF. Companies or individuals failed to 
take advantage of potential savings on import duties that they could have legitimately 
claimed or benefited from.  
10 Average Duty 
Paid for COV/D 
but no REC/D  the average amount of duty paid for goods that have been imported or brought into a 
country (COV/D) but haven't been officially recorded or documented (REC/D).  
11 Not COV/D 
Imports:   imports that DFQF does not cover  
12 Not COV/D 
Duties Paid  duty paid in value for imports that DFQF does not cover  
13 Average Duty 
Paid for not 
COV/D (%)   duty paid in percentage for imports that DFQF does not cover  
14 Total MFN 
Imports   the total value of imports subject to the payment of MFN customs  
15 Average MFN 
rate (%)  the average Most Favored Nation (MFN) tariff rate expressed as a percentage  
16 Total Duties Paid  the sum of all duties or taxes paid on imported goods at HS level product described  
 
  
  G/RO/W/229  
 
- 6 - Table 2: Most exported 20 products from LDCs to selected preference -granting Members : US, EU, Canada, Japan China, and India ordered by 
descending 'Total Duties Paid' at the HS 4 -digit level with trade flows and applicable rules of origin for EU, UK and Japan  
. Product 
Description  Total 
Imports  DFQF 
Covered 
Imports  DFQF 
Received 
Imports  Other 
Pref. 
Imports  All Pref.  
Imports  COV/D 
but no 
REC/D 
Imports  Missed 
Duty 
Savings  Av. 
Duty 
Paid 
for 
COV/D 
but no 
REC/D 
(%) Not 
COV/D 
Imports  Not 
COV/D 
Duties 
Paid Average 
Duty 
Paid for 
not 
COV/D 
(%) Total 
MFN 
Imports  Average 
MFN 
rate 
(%) Total 
Duties 
Paid EU UK Japan  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) 
6203 Men's or 
boys' suits,  7779.6  4733.8  4148.7  431.0  4579.7  304.1  40.5 13.31  2895.8  527.4  18.21  3199.9  17.7 567.9  (a) LDCs 
Manufacture 
from fabric  Manufacture 
from fabric  Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
6110 Jerseys, 
pullovers, 
cardigans,  8595.3  6469.7  5900.4  214.0  6114.4  432.8  55.6 12.85  2048 424.2  20.71  2480.9  19.3 479.83  (a) LDCs 
Manufacture 
from fabric  Manufacture 
from 
fabric/CC or 
75% 
MaxNom or 
processing 
rule Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
7108 Gold 3233.4  3233.4  165.9  0.0 165.9  3067.5  383.4  12.50  0 0 . 3067.5  12.5 383.44  Manufacture 
from 
materials of 
any heading, 
except those 
of headings 
7106, 7108 
and 7110  CTSH  CTH 
6204 Women's or 
girls' suits,  6344.7  4235.2  3896.4  180.9  4077.3  223 28.8 12.92  2044.4  337.4  16.50  2267.4  16.2 366.19  (a) LDCs 
Chapter rule 
applies  Manufacture 
from fabric  Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
4202 Trunks, 
suitcases, 
vanity -
cases,  3400.7  1127.9  422.4  274.3  696.8  435.6  29.9 6.88 2268.3  331.2  14.60  2703.9  13.4 361.13  CTH or 
VNOM 70%  CTH or 75% 
MaxNom 
(EXW)  Manufactured 
from products of 
the different 
tariff headings 
(excluding 
heading 42.05) 
of the products  
 
 For a complete description of the PSR or applicable rule of origin see Annex 1 . 
  
  G/RO/W/229  
 
- 7 - . Product 
Description  Total 
Imports  DFQF 
Covered 
Imports  DFQF 
Received 
Imports  Other 
Pref. 
Imports  All Pref.  
Imports  COV/D 
but no 
REC/D 
Imports  Missed 
Duty 
Savings  Av. 
Duty 
Paid 
for 
COV/D 
but no 
REC/D 
(%) Not 
COV/D 
Imports  Not 
COV/D 
Duties 
Paid Average 
Duty 
Paid for 
not 
COV/D 
(%) Total 
MFN 
Imports  Average 
MFN 
rate 
(%) Total 
Duties 
Paid EU UK Japan  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) 
6109 T-shirts, 
singlets.  7225.9  5807.5  5151.9  247.7  5399.6  524.8  67.3 12.83  1301.5  256.7  19.72  1826.3  17.7 324.03  (a) LDCs 
Manufacture 
from fabric  Manufacture 
from 
fabric/CC or 
75% 
MaxNom or 
processing 
rule Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
1006 Rice. 1137.6  621.6  599.7  11.9 611.7  10.1 2 20.00  515.9  251.3  48.71  525.9  48.2 253.28  Manufacture 
in which all 
the materials 
of Chapter 
10 used are 
wholly 
obtained  CC CTH 
6104 Women's or 
girls' suits,  4678.9  3659.3  3311.7  226.6  3538.2  255 36.1 14.15  885.7  166.9  18.84  1140.7  17.8 202.97  (a) LDCs 
Manufacture 
from fabric  Manufacture 
from 
fabric/CC or 
75% 
MaxNom or 
processing 
rule Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
8105 Cobalt 
mattes  5072.7  5071.3  3 0.0 3 5068.3  202.7  4.00 1.4 0.1 3.70 5069.7  4 202.8  CTH or 
VNOM 70%)  CTH Manufactured 
from products of 
the different 
tariff heading 
(excluding 
unwrought) of 
the products  
6205 Men's or 
boys' shirts.  2245.1  1300 1072.7  158.5  1231.1  118.6  14.9 12.57  895.4  186.9  20.87  1013.9  19.9 201.81  (a) LDCs 
Manufacture 
from fabric  Manufacture 
from fabric  Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
7103 Precious 
stones  4255.9  4252.9  1.2 0.8 2 4251.7  179.4  4.22 2.2 0.2 10.47  4254 4.2 179.64  CTH or 
VNOM 70%)  CTH or 75% 
Max Nom 
(EXW)  CTH 
0713 Dried 
leguminous 
vegetables, 
shelled, 
whether  1737.1  1719.4  686 456.4  1142.4  577 169.5  29.37  17.7 2.5 14.14  594.7  28.9 171.96  Manufacture 
in which all 
the materials 
of Chapter 7 
used are 
wholly 
obtained  CTH Manufactured 
from products 
other than those 
of Chapter 7   
  G/RO/W/229  
 
- 8 - . Product 
Description  Total 
Imports  DFQF 
Covered 
Imports  DFQF 
Received 
Imports  Other 
Pref. 
Imports  All Pref.  
Imports  COV/D 
but no 
REC/D 
Imports  Missed 
Duty 
Savings  Av. 
Duty 
Paid 
for 
COV/D 
but no 
REC/D 
(%) Not 
COV/D 
Imports  Not 
COV/D 
Duties 
Paid Average 
Duty 
Paid for 
not 
COV/D 
(%) Total 
MFN 
Imports  Average 
MFN 
rate 
(%) Total 
Duties 
Paid EU UK Japan  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) 
2709 Petroleum 
oils 4541.7  0 0 361.6  361.6  0 0 . 4180.1  167.9  4.02 4180.1  4 167.92  CTH or 
VNOM 70%)  CTH; or 
75% 
MaxNOM 
(EXW).  CTH 
6103 Men's or 
boys' suits,  1879.1  1226.1  1004.5  70.8 1075.4  170.7  22.6 13.23  633 131.6  20.80  803.7  19.2 154.23  (a) LDCs 
Manufacture 
from fabric  Manufacture 
from fabric/  
CC or 75% 
MaxNom or 
processing 
rule Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
1511 Palm oil and 
its 
fractions,  255.9  103.1  96.9 2.1 99 4.2 2.2 53.00  152.7  151.9  99.48  156.9  98.2 154.15  Manufacture 
from 
materials of 
any sub -
heading, 
except that 
of the 
product  CTSH  Manufactured 
from products 
other than palm 
stearin of 
heading 15.11  
7403 Refined 
copper and 
copper 
alloys, 
unwrought.  6102.3  5765.5  5.7 103.2  108.9  5757.9  115.1  2.00 235.5  11.8 5.00 5993.4  2.1 126.87  Manufacture 
from 
materials of 
any heading  CTH Manufactured 
from products 
other than those 
of heading 74.01 
or 74.03  
4001 Natural 
rubber, 
balata, 
gutta -
percha, 
guayule, 
chicle  648.1  23.9 18.1 2.6 20.7 3.1 0.8 25.00  624.3  124.9  20.01  627.4  20 125.68  CTH or 
VNOM 70%)  CTH or 75% 
MaxNom 
(EXW)  CTH 
7402 Unrefined 
copper  6900.4  6900.4  1247.2  0.0 1247.2  5653.2  113.4  2.01 0 0 . 5653.2  2 113.36  Manufacture 
from 
materials of 
any heading, 
except that 
of the 
product  CTH Manufactured 
from products 
other than those 
of heading 74.01 
or 74.02   
  G/RO/W/229  
 
- 9 - . Product 
Description  Total 
Imports  DFQF 
Covered 
Imports  DFQF 
Received 
Imports  Other 
Pref. 
Imports  All Pref.  
Imports  COV/D 
but no 
REC/D 
Imports  Missed 
Duty 
Savings  Av. 
Duty 
Paid 
for 
COV/D 
but no 
REC/D 
(%) Not 
COV/D 
Imports  Not 
COV/D 
Duties 
Paid Average 
Duty 
Paid for 
not 
COV/D 
(%) Total 
MFN 
Imports  Average 
MFN 
rate 
(%) Total 
Duties 
Paid EU UK Japan  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) 
6403 Footwear 
with outer 
soles of 
rubber, 
plastics, 
leather  1916.5  939.8  635.5  80.9 716.4  223.4  20.4 9.15 976.7  81.6 8.35 1200.1  8.5 102.02  Manufacture 
from 
materials of 
any heading, 
except from 
assemblies of 
uppers 
affixed to 
inner soles or 
to other sole 
components 
of heading 
6406 CTH Manufactured 
from products of 
the different 
tariff heading 
(excluding  
heading 64.06) 
of the products  
6108   Women's or 
girls' slips…  1782.2  1126.5  1023.4      32.2 1055.6  71.2 9  12.62  655.4  78.6  11.99  726.6  12.1 87.57  (a) LDCs 
Manufacture 
from fabric / 
Spinning of 
natural 
and/or man -
made staple 
fibres or 
extrusion of 
manmade 
filament 
yarn, in each 
case 
accompanied 
by knitting 
(knitted to 
shape 
products) or  
Dyeing of 
yarn of 
natural fibres 
accompanied 
by knitting 
(knitted to 
shape 
products)  Manufacture 
from fabric/ 
CC or 75% 
MaxNom or 
processing 
rule Manufactured 
from woven 
fabrics, felt, 
nonwovens, 
knitted or  
crocheted fabrics 
or lace of 
Chapter 50 to 56 
or 58 to 60  
 
  
  G/RO/W/229  
 
- 10 - Table 3: Most exported 20 products from LDCs to selected preference -granting Members : US, EU, Canada, Japan, China and India ordered by 
descending 'Total Duties Paid' at the HS 4 -digit level with trade flows and applicable rules of origin Preference -granting Members  with a mix of 
across the board and product specific rules of origin (US, CANADA, India and China)  
HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
620
3 Men's or 
boys' 
suits… 
(ref. 
excl) 7779.
6 4733.
8 4148.
7 431.0  4579.
7 304.1  40.5 13.31  2895.
8 527.
4 18.21  3199.
9 17.7 567.
9 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided they 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
611
0   Jerseys, 
pullover
s.. 8595.
3 6469.
7 5900.
4 214.0  6114.
4 432.8  55.6 12.85  2048 424.
2 20.71  2480.
9 19.3 479.
83 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided the y 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
710
8   Gold …  3233.
4 3233.
4 165.9  0.0 165.9  3067.
5 383.4  12.50  0 0 . 3067.
5 12.5 383.
44 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH  
  G/RO/W/229  
 
- 11 - HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
620
4   Women'
s or 
girls' 
suits 
...(ref. 
excl) 6344.
7 4235.
2 3896.
4    
180.9  4077.
3 223 28.8  
12.92  2044.
4 337.
4  
16.50  2267.
4 16.2 366.
19 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided they 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
420
2   Trunks, 
suit-
cases …  3400.
7 1127.
9 422.4     
274.3  696.8  435.6  29.9   6.88 2268.
3 331.
2 14.60  2703.
9 13.4 361.
13 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
610
9   T-shirts, 
singlets.
.. 7225.
9 5807.
5 5151.
9 247.7  5399.
6 524.8  67.3 12.83  1301.
5 256.
7 19.72  1826.
3 17.7 324.
03 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided they 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH  
  G/RO/W/229  
 
- 12 - HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
100
6   Rice 1137.
6 621.6  599.7  11.9 611.7  10.1 2 20.00  515.9  251.
3 48.71  525.9  48.2 253.
28 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
610
4   Women'
s or 
girls' 
suits… 
(ref. 
excl) 4678.
9 3659.
3 3311.
7    
226.6  3538.
2 255 36.1  
14.15  885.7  166.
9  
18.84  1140.
7 17.8 202.
97 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided they 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
810
5   Cobalt …  5072.
7 5071.
3 3      
0.0 3 5068.
3 202.7    4.00 1.4 0.1   3.70 5069.
7 4 202.
8 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH  
  G/RO/W/229  
 
- 13 - HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
620
5   Men's or 
boys' 
shirts.  2245.
1 1300 1072.
7    
158.5  1231.
1 118.6  14.9  
12.57  895.4  186.
9  
20.87  1013.
9 19.9 201.
81 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided they 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
710
3   Precious 
stones…  4255.
9 4252.
9 1.2      
0.8 2 4251.
7 179.4    4.22 2.2 0.2  
10.47  4254 4.2 179.
64 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
071
3   Dried 
legumin
ous 
vegetabl
es … 1737.
1 1719.
4 686    
456.4  1142.
4 577 169.5   
29.37  17.7 2.5  
14.14  594.7  28.9 171.
96 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH  
  G/RO/W/229  
 
- 14 - HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
270
9   Petroleu
m oils 
and 
oils… 4541.
7 0 0    
361.6  361.6  0 0    .   4180.
1 167.
9   4.02 4180.
1 4 167.
92 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
610
3   Men's or 
boys' 
suits… 
(ref. 
excl) 1879.
1 1226.
1 1004.
5     
70.8 1075.
4 170.7  22.6  
13.23  633 131.
6  
20.80  803.7  19.2 154.
23 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Third country 
rules Use fabric 
produced in 
current or 
former GSP 
beneficiaries 
in the 
production of 
apparel, 
provided they 
add at least 
25% value in 
the LDC and 
Canada   WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
151
1   Palm oil 
…  255.9  103.1  96.9      
2.1 99 4.2 2.2  
53.00  152.7  151.
9  
99.48  156.9  98.2 154.
15 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH  
  G/RO/W/229  
 
- 15 - HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
740
3   Refined 
copper 
… 6102.
3 5765.
5 5.7    
103.2  108.9  5757.
9 115.1    2.00 235.5  11.8   5.00 5993.
4 2.1 126.
87 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
400
1   Natural 
rubber …  648.1  23.9 18.1      
2.6 20.7 3.1 0.8  
25.00  624.3  124.
9  
20.01  627.4  20 125.
68 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
740
2   Unrefine
d copper  6900.
4 6900.
4 1247.
2      
0.0 1247.
2 5653.
2 113.4    2.01 0 0    .   5653.
2 2 113.
36 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH  
  G/RO/W/229  
 
- 16 - HS 
Cod
e Product 
Descripti
on Total 
Impo
rts DFQF 
Cover
ed 
Impor
ts DFQF 
Receiv
ed 
Import
s Other 
Pref. 
Impo
rts All 
Pref. 
Impo
rts COV/
D but 
no 
REC/
D 
Impo
rts Misse
d 
Duty 
Savin
gs Avera
ge 
Duty 
Paid 
for 
COV/
D but 
no 
REC/
D (%)  Not 
COV/
D 
Impo
rts Not 
COV
/D 
Duti
es 
Paid Avera
ge 
Duty 
Paid 
for 
not 
COV/
D (%)  Total 
MFN 
Impo
rts Avera
ge 
MFN 
rate 
(%) Total 
Dutie
s 
Paid US Canada  India China  
GSP AGOA  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) 
640
3   Footwea
r… 1916.
5 939.8  635.5      
80.9 716.4  223.4  20.4   9.15 976.7  81.6   8.35 1200.
1 8.5 102.
02 Cost of 
local 
material
s + 
direct 
cost of 
processi
ng 
must >
= 35% 
of ex-
works 
price Cost of local 
materials + 
direct cost of 
processing  mus
t >= 35%  WO; 60% 
MaxNom  WO; 70% 
MaxNom+CTSH  WO; 
RVC>=40%/
CTH 
610
8   Women'
s or 
girls' 
slips…  1782.
2 1126.
5 1023.
4     
32.2 1055.
6 71.2 9  
12.62  655.4  78.6  
11.99  726.6  12.1 87.5
7 The 
direct 
costs of 
processi
ng 
operatio
ns 
perform
ed in 
such 
benefici
ary 
developi
ng 
country 
or such 
member 
countrie
s, is not 
less 
than 
53% of 
the 
apprais
ed 
value of 
such 
article 
at the 
time it 
is 
entered  Third-Country 
Fabric Rule  WO; 60% 
MaxNom  WO; 70% 
MaxN om+CTSH
+the final 
process of 
manufacture is 
performed 
within  
the territory of 
the exporting 
beneficiary 
country.  WO; 
RVC>=40%/
CTH 
 G/RO/W/229  
 
- 17 - 
 
  3.14.  Table 3 shows the scope for convergence for preference -granting  Members  that are either 
adopting a mix of across -the-board percentage rules of origin such as US and Canada and 
preference -granting  Members  that are adopting across the board criterion such as  China and India. 
The analysis shows considerable scope for convergence as the methods of calculation vary as well 
as the number of percentages required. On the positive side a substantial convergence may be noted 
among AGOA and Canadian rules of origin fo r textile and clothing that are converging, albeit with 
some notable differences, on a single transformation requirement that could be assimilated to 
manufacturing from non -originating fabric as already adopted by the EU; the UK; and Japan above.  
3.15.  As previo usly noted in submissions11 from LDCs, there exists considerable variation in the 
method of calculating  ad valorem percentages among preference -granting  Members  that continue 
to employ such methodologies as across -the-board criteria. The US, for instance, maintains a value -
added calculation that involves summing the direct cost of processing and the value of originating 
materials used to achieve a 35% threshold of the ex -works price. In contrast, Canada;  China;  and 
India all utilize an ad valorem percentage  calculation based on the value of non -originating materials 
used.  
3.16.  In addition, the level of percentages used vary considerably and are also dependent on the 
kind of cumulation allowed. To sum up on the liberal side of the spectrum Canada shows the most 
liberal combination with a limit of 80 of non -originating materials allowing cumulation with the 
materials originating with other GSP beneficiaries i.e., in a simple form this may resumed as being 
equivalent to a 20% value added. On the stringent side we ma y have India with a double requirement 
of 70% of VNOM and the combined requirement of CTSH and the requirement that the final process 
of manufacture is performed  within  the territory of the exporting beneficiary country.  
3.17.  A comparison of convergence among t he preference -granting Members  using PSRO and 
across the board percentage is not the object of this submission given its complexity. Some 
preliminary observations may be raised on the methodology that could be used in further 
submissions by comparing the m anufacturing requirement of a given PSRO such as CTSH for refined 
copper with a 35% value added requirement. Would the amount of working or processing that is 
generating a CTSH be equivalent to a 35% value added requirement or a 70% VNOM? A closer -
product specific analysis may provide valuable insights that may be discussed in further submissions.  
4  CONCLUSIONS AND WAY FORWARD  
4.1.  At the outset it must be stated that with the present submission the LDC are not advocating 
harmonization of rules of origin. Yet it emerges clearly from this preliminary analysis of the 20 most 
exported products  from LDCs that the diversity of rules of or igin among preference -granting  
Members  is disproportionate with the declared and reiterated objectives contained in last Report as 
follows:  
"It is important that the Committee on Rules of Origin fulfils the intention of the Agreement 
on Rules of Origin, t hat clear and predictable rules of origin facilitate the flow of international 
trade and do not create unnecessary obstacles. To that end the Committee should continue 
its work to ensure that preferential rules of origin applicable to imports from LDCs are  
transparent and simple and contribute to facilitating market access in line with the Decision 
on Measures in Favour of Least Developed Countries and the Bali and Nairobi Decisions. "    
4.2.  Against this background and the preliminary evidence arising from this  submission, the LDC 
WTO group invites the CRO to reflect on the scope for convergence on rules of origin for LDCs. The 
LDC WTO group will present further submission and reflections on this topic. In particular, discussion 
in the CRO may focus on the follo wing questions:  
-  Are the existing differences in rules of origin among preference -granting Members  generated 
by legitimate and undisputable exigencies of domestic constituencies and the desire to 
maintain trade preferences for products genuinely manufact ured in LDCs?  
 
11 Developments regarding methods of calculation of the percentage criterion (paragraph 1.1 of the 
Nairobi Decision and item 1 o f document G/RO/W/169  of 14 March 2017  and presentation RD/RO/52  of 
4 October 2017 . G/RO/W/229  
 
- 18 - 
 
  -  What feasible avenues and methods of work within the CRO could facilitate the development 
of transparent and simplified rules of origin on the basis of convergence and best practices,  
leading to better utilization of trade preferences?  
- How further evidence and research on the scope for convergence and trade facilitation could 
be deployed to generate the necessary political will to undertake the necessary steps for RoO 
reform?  
Legend : explanatory box to the following  table 4 
 
# Columns  Description  
1 HS6 Harmonized System (HS) code at 6 -digit level  
2 Product 
Description  Product description of the internationally standardized system to classify traded 
product  
3 Total dutiable 
Imports  the value of all imports (for each HS level product described) subject to the 
payment of customs duties unless they benefitted from preferences of any kind, 
i.e. the corresponding MFN rate of duty is greater than zero;  
4 DFQF Covered 
Imports  the value of imports that are classified in tari ff lines that are dutiable and covered 
by the Duty Free and Quota Free (DFQF) scheme of the PGC  
5 DFQF Received 
Imports  the value of imports that received DFQF treatment.  
6 Other Pref. 
Imports  the value of imports that benefitted from non-reciprocal preferences other than 
DFQF and under selected Economic Partnership Agreements that the EU has 
entered with some African countries. Data on the following schemes are included: 
AGOA and the Caribbean Basin Initiative (CBI) in the case of the USA and the 
Economic Partnership Agreements entered by selected Sub -Saharan African 
countries with the EU;  
7 Total Pref. 
Imports  the total value of imports that benefitted from preferences, i.e. the sum of DFQF -
received and Other Preferential Imports;  
8 Total MFN 
Imports  the total value of imports subject to the payment of MFN customs  
9 Total Duties Paid  the total value of duties paid at customs for imports for HS level product 
described  
10 TOP-1 First ranked supplier of HS level product described to th e selected preference -
granting  Members  (EU, UK, Japan, China and India)  
11 TOP-1 SHARE 
(%) Percentage of trade at HS level product described by TOP1 ranked country   
12 TOP-2 Secon d ranked supplier of HS level product described to the selected preference -
granting  Members  (EU, UK, Japan, China and India)  
13 TOP2 SHARE (%)  Percentage of trade at HS level product described by TOP2 ranked country  
14 TOP-3 Third ranked supplier of HS level product described to the selected preference -
granting  Members  (EU, UK, Japan, China and India)  
15 TOP-3 SHARE 
(%) Percentage of trade at HS level product described by TOP3 ranked country  
 
Countries  
KHM Cambodia  
AGO Angola  
BGD Bangladesh  
DRC Democratic Republic of the Congo  
GIN Guinea  
HTI Haiti 
LAO Laos 
LBR Liberia  
MDG Madagascar  
MMR Madagascar  
MOZ Mozambique  
SLB Solomon Islands  
TZA Tanzania  
UGA Uganda  
ZMB Zambia   
  G/RO/W/229  
 
- 19 - Table 4: First three LDCs suppliers of most exported products to the selected preference -granting  Members  (EU, UK, Japan, China and India)  
HS6 Product description  Total 
dutiable 
Imports  DFQF 
Covered 
Imports  DFQF 
Received 
Imports  Other 
Pref. 
Imports  Total 
Pref. 
Imports  Total 
MFN 
Imports  Total 
Duties 
Paid TOP-
1 TOP-1 
SHARE 
(%) TOP-
2 TOP2 
SHARE 
(%) TOP-
3 TOP-3 
SHARE (%)  
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) 
6203 Men's or boys' suits, ensembles, jackets, blazers,  7,779.60  4,733.80  4,148.70  431 4,579.70  3,199.90  567.9  BGD 80.06  KHM 8.99 MMR 4.41 
6110 Jerseys, pullovers, cardigans, waistcoats and simi  8,595.30  6,469.70  5,900.40  214 6,114.40  2,480.90  479.8  BGD 62.27  KHM 26.46  MMR 5.93 
7108 Gold (including gold plated with platinum) unwrought  3,233.40  3,233.40  165.9  0 165.9  3,067.50  383.4  GIN 53.08  TZA 27.75  UGA 14.02  
6204 Women's or girls' suits, ensembles, jackets, blaze  6,344.70  4,235.20  3,896.40  180.9  4,077.30  2,267.40  366.2  BGD 67.79  KHM 21.31  MMR 8.26 
4202 Trunks, suit -cases, vanity -cases, executive -cases,  3,400.70  1,127.90  422.4  274.3  696.8  2,703.90  361.1  KHM 73.97  MMR 14.2 BGD 11.05  
6109 T-shirts, singlets and other vests, knitted or cro  7,225.90  5,807.50  5,151.90  247.7  5,399.60  1,826.30  324 BGD 79.6 KHM 9.13 HTI 6.55 
1006 Rice. 1,137.60  621.6  599.7  11.9 611.7  525.9  253.3  MMR 62.31  KHM 34.47  LAO 2.84 
6104 Women's or girls' suits, ensembles, jackets, blaze  4,678.90  3,659.30  3,311.70  226.6  3,538.20  1,140.70  203 BGD 53.98  KHM 31.21  MMR 8.5 
8105 Cobalt mattes and other intermediate products of c  5,072.70  5,071.30  3 0 3 5,069.70  202.8  DRC 99.81  ZMB 0.1 MDG 0.09 
6205 Men's or boys' shirts.  2,245.10  1,300.00  1,072.70  158.5  1,231.10  1,013.90  201.8  BGD 79.02  MMR 7.27 KHM 6.46 
7103 Precious stones (other than diamonds) and semi -pre 4,255.90  4,252.90  1.2 0.8 2 4,254.00  179.6  MMR 95.23  ZMB 3.95 MDG 0.29 
713 Dried leguminous vegetables, shelled, whether or n  1,737.10  1,719.40  686 456.4  1,142.40  594.7  172 MMR 66.31  MOZ 17.17  TZA 6.18 
2709 Petroleum oils and oils obtained from bituminous m  4,541.70  0 0 361.6  361.6  4,180.10  167.9  AGO 96.37  DRC 3.63 ??? . 
6103 Men's or boys' suits, ensembles, jackets, blazers,  1,879.10  1,226.10  1,004.50  70.8 1,075.40  803.7  154.2  BGD 54.71  KHM 37.54  MMR 5.42 
1511 Palm oil and its fractions, whether or not refined  255.9  103.1  96.9 2.1 99 156.9  154.2  NPL 59.36  LBR 20.72  SLB 7.53 
7403 Refined copper and copper alloys, unwrought.  6,102.30  5,765.50  5.7 103.2  108.9  5,993.40  126.9  DRC 82.64  ZMB 10.38  TZA 4.56 
4001 Natural rubber, balata, gutta -percha, guayule, chi  648.1  23.9 18.1 2.6 20.7 627.4  125.7  LAO 55.11  MMR 41.43  KHM 2.71 
7402 Unrefined copper  6,900.40  6,900.40  1,247.20  0 1,247.20  5,653.20  113.4  ZMB 57.79  DRC 22.07  TZA 16.49  
6403 Footwear with outer soles of rubber, plastics, lea  1,916.50  939.8  635.5  80.9 716.4  1,200.10  102 KHM 45.31  BGD 41.29  MMR 8.07 
6108 Women's or girls' slips, petticoats, briefs, panti es 1’782.2  1’126.5  1’023.4  32.2 1’055.6  726.6  87.6 BGD 62.57  KHM 28.72  MMR 6.03  
  G/RO/W/229  
 
- 20 - ANNEX 1  
COMPLETE DESCRIPTION OF THE PSR OR APPLICABLE RULE OF ORIGIN  
Table A: Sources of the rules of origin for the tables 2 and 3  
Country  Scheme  WTO Notification  of 
Preferential RoO for LDCs  Government website  
EU The EU provides DFQF access to certain developing countries as part of 
its Generalized System of Preferences (GSP). This arrangement allows 
eligible countries to export specified products to the EU market without 
tariffs or quotas.  G/RO/LDC/N/EU/1  https://policy.trade.ec.europa.eu/development -and-
sustainability/generalised -scheme -preferences_en   
UK The United Kingdom, after leaving the EU, has its own DFQF 
arrangements with developing countries called DCTS  G/RO/LDC/N/GBR/1/Rev.1  Developing Countries Trading Scheme (DCTS) - GOV.UK 
(www.gov.uk)  
JAPAN  Japan GSP as notified in (WTO doc or Japan government website)  G/RO/LDC/N/JPN/1  JAPAN'S GSP (Generalized System of Preferences) | 
Ministry of Foreign Affairs of Japa n (mofa.go.jp)  
US GSP  The United States Generalized System of Preferences program provides 
DFQF treatment for eligible products from designated beneficiary 
developing countries.  G/RO/LDC/N/USA/1 ; and 
G/RO/LDC/N/USA/4  Generalized System of Preferences (GSP) | United 
States Trade Represent ative (ustr.gov)  
US 
AGOA  The African Growth and Opportunity Act is a trade preference program 
that offers DFQF access to the US market for eligible products from 
eligible sub -Saharan African countries.   
G/RO/LDC/N/USA/3  African Growth and Opportunity Act (AGOA) | United 
States Trade Representative (ustr.gov)  
CANADA  Canada has its own DFQF initiatives to provide preferential access to its 
market for products from developing nations.  G/RO/LDC/N/CAN/2  TERMIUM  Plus® (termiumplus.gc.ca)  
INDIA  India has various trade agreements, including preferential trade 
arrangements, with developing countries that offer DFQF access to its 
market for certain goods.  G/RO/LDC/N/IND/1  https://commerce.gov.in/17182 -2/ 
CHINA  China has various trade agreements, including preferential trade 
arrangements, with developing countries that offer DFQF access to its 
market for certain goods.  G/RO/LDC/N/CHN/1   
 
Table B: Full text of rules of origin for table 2 and 3.  
HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
6203 Men's or boys' 
suits, ensembles, 
jackets, blazers, 
trousers, bib and 
brace overalls, 
breeches and 
shorts (excl. 
knitted or 
crocheted, wind -
jackets and similar 
articles, separate 
waistcoats, (a) LDCs 
Manufacture from 
fabric Manufacture from 
fabric  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule . The 
duty-free treatment 
provided under this 
subchapter shall apply to 
any eligible article w hich is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. yarn  
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. For 6203.11, 
6203.12, 6203.19, 
6203.22, 6203.23, 
6203.29, 6203.31, 
6203.32, 6203.33, 
6203.39, 6203.41, 
6203.49 (Part A1 in 
the regulations): use 
fabric produced in 
current or former 
GSP beneficiaries in 
the production of WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
count ry if they fulfil 
the following 
conditions:  
(a) the total value of WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substant ial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods  
  G/RO/W/229  
 
- 21 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
tracksuits, ski suits 
and swimwear)  the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of t he 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing  operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
35% of the appraised 
value of such article at the 
time it is entered.  yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Lesser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 
sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns  or 
finer  apparel, provided 
they a dd at least 
25% value in the 
LDC. (Any value that 
is added in Canada is 
also considered as if 
it were added in the 
LDC.) The ad valorem 
percentage is 
calculated by using 
the value of non -
originating materials 
as a percentage of 
the ex -factory price 
of the final goods as 
packed for shipment 
to Canada. LDCs may 
also use fabric 
produced in an LDC 
or Canada in the 
production of 
apparel, with no 
value requirement. In 
both cases, the yarn 
must also be 
produced in an LDC, 
Canada or a current 
or former GSP 
benefici ary country.  
For 6203.42, 6203.43 
(Part A3 in the 
regulations): Similar 
to the rules of origin 
for apparel A1&A2, 
with three 
modifications. The 
fabric may be cut in 
Canada, another 
LDC, a current or 
former GSP 
beneficiary or a 
country with which 
Canada has  a free 
trade agreement, 
LDCs may use fabric 
or yarn that has been 
produced in a country 
with which Canada 
has a free trade 
agreement, as long 
as 25% value is 
added in the LDC,  
and Any value that is 
added in Canada or a 
country with which  
Canada has a free  
trade agreement is 
included in the value 
requirement as if it the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local  value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary countr y is 
different from that of 
the goods.   
  G/RO/W/229  
 
- 22 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
were added in the 
LDC.  
Else: WO; 60% 
MaxNom  
6110 Jerseys, pullovers, 
cardigans, 
waistcoats, and 
similar articles, of 
wool, knitted or 
crocheted (excl. 
wadded waistcoats)  (a) LDCs 
Manufacture from 
fabric / Spinning of 
natural and/or 
man-made staple 
fibres or ex trusion 
of manmade 
filament yarn, in 
each case 
accompanied by 
knitting (knitted to 
shape products) or 
Dyeing of yarn of 
natural fibres 
accompanied by 
knitting (knitted to 
shape products) 
(7) Manufacture from 
fabric / CC or 75% 
MaxNom or 
processing rule  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product , or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in th e 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
36% of the appraised 
value of such article at the 
time it is entered.  Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. y arn 
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Less er 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 
sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns or 
finer  For 6110.11.90, 
6110.12.90 and 
6110.19.90, 
subheadings 
6110.20, 6110.30 
and 6110.90 (Part A1 
in the regulations) 
and 6110.11.10, 
6110.12.10 and 
6110.19.10 (Part A2 
in the regulations): 
use fabric produced 
in current or former 
GSP beneficiaries in 
the production of 
apparel, provided 
they add at least 
25% value in the 
LDC. (Any value that 
is added in Can ada is 
also considered as if 
it were added in the 
LDC.) The ad valorem 
percentage is 
calculated by using 
the value of non -
originating materials 
as a percentage of 
the ex -factory price 
of the final goods as 
packed for shipment 
to Canada. LDCs may 
also use f abric 
produced in an LDC 
or Canada in the 
production of 
apparel, with no 
value requirement. In 
both cases, the yarn 
must also be 
produced in an LDC, 
Canada or a current 
or former GSP 
beneficiary country.  
Else: WO; 60% 
MaxNom  WO; 
For not -wholly 
produced pro ducts: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export prod uct does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification  
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territo ry of the 
exporting beneficiary 
country.  WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the headin g of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.  
7108 Gold, incl. gold 
plated with 
platinum, 
unwrought or not 
further worked 
than semi -
manufactur ed or in 
powder form  Manufacture from 
materials of any 
heading, except 
those of headings 
7106, 7108 and 
7110 or 
Electrolytic, 
thermal or 
chemical CTSH  WO; 
For not -wholly produced 
products:  
1. The manufacturing or 
processing as provided 
for subparagraph (2) of 
paragraph 1 of Article 
26 of the Cab inet Order 
shall be manufacturing (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or WO;  
subsection 2:(3) 
Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or  
  G/RO/W/229  
 
- 23 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
separation of 
precious metals of 
heading 7106, 
7108 or 7110 or 
Fusion and/or 
alloying of precious 
metals of he ading 
7106, 7108 or 
7110 with each 
other or with base 
metals / 
Manufacture from 
unwrought precious 
metals  or processing, as a 
result of which the 
heading of the Tariff 
Schedule of the goods 
changes from any 
heading of raw 
materials originating 
from other countries 
used in the production 
of the goods. In the 
case of a good in e ach 
middle column of the 
Annexed Table, the 
manufacturing or 
processing shall be the 
manufacturing or 
processing in each 
lower column of the 
Annexed Table.  
2. When a good 
classified in HS Chapter 
50-63 is produced in a 
beneficiary country 
using non -origina ting 
material not satisfying 
PSR (Product Specific 
Rules), the goods shall 
not be considered to 
have undergone the 
substantial 
transformation in 
principal. However, if 
the total weight of the 
non-originating 
materials not satisfying 
PSR is less than 10% of  
the weight of the good, 
such non -originating 
material shall be 
disregarded in 
determining whether 
the goods have 
undergone substantial 
transformation.  
3. When the 
classification of goods 
consisting of different 
materials, goods made 
in different component s 
and sets for retail sale, 
are determined 
pursuant to Rule 3 of 
the General Rules for 
the interpretation of the 
Harmonized Tariff 
Schedule of the 
Customs Tariff Law 
Appendix, the origin of 
the goods is determined (i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such  countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countri es, is not less than 
37% of the appraised 
value of such article at the 
time it is entered.  manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and  
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  parts or products 
originating  outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following ar e deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed countr y or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for th e 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works v alue of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized  System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  "Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production  or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
  G/RO/W/229  
 
- 24 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
in accordance with 
manufacturing or 
proces sing prescribed 
for heading in which the 
goods are classified.  
6204 Women's or girls' 
suits, ensembles, 
jackets, blazers, 
dresses, skirts, 
divided skirts, 
trousers, bib and 
brace overalls, 
breeches and 
shorts (excl. 
knitted or 
crocheted, wind -
jackets and similar 
articles, slips, 
petticoats and 
panties, tracksuits, 
ski suits and 
swimwear)  (a) LDCs Chapter 
rule applies  Manufacture from 
fabric  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that artic le is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that  
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less  than 
38% of the appraised 
value of such article at the 
time it is entered.  Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. yarn  
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Lesser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 
sweaters, k nit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns or 
finer  For 6204.11, 
6204.12, 6204.13, 
6204.19, 6204.21, 
6204.22, 6204.23, 
6204.29, 6204.31, 
6204.32, 6204.33, 
6204.39, 6204.41, 
6204.42, 6204.43, 
6204.44, 6204.51, 
6204.52, 620 4.53, 
6204.59, 6204.61, 
6204.69 (Part A1 in 
the regulations) , and 
6204.49 (Part A2 in 
the regulations) : use 
fabric produced in 
current or former 
GSP beneficiaries in 
the production of 
apparel, provided 
they add at least 
25% value in the 
LDC. (Any value t hat 
is added in Canada is 
also considered as if 
it were added in the 
LDC.) The ad valorem 
percentage is 
calculated by using 
the value of non -
originating materials 
as a percentage of 
the ex -factory price 
of the final goods as 
packed for shipment 
to Canada. LDCs may 
also use fabric 
produced in an LDC 
or Canada in the 
production of 
apparel, with no 
value requirement. In 
both cases, the yarn 
must also be 
produced in an LDC, 
Canada or a current 
or former GSP 
beneficiary country.  
For 6204.62 and 
6204.63 (Part A3 in 
the regulations) : 
Similar to the rules of 
origin for apparel 
A1&A2, with three WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting benef iciary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manu facture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Valu e 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage , is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
  G/RO/W/229  
 
- 25 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
modifications. The 
fabric may be cut in 
Canada, another 
LDC, a current or 
former GSP 
beneficiary or a 
country with which 
Canada has a free 
trade agreement, 
LDCs may use fabr ic 
or yarn that has been 
produced in a country 
with which Canada 
has a free trade 
agreement, as long 
as 25% value is 
added in the LDC,  
and Any value that is 
added in Canada or a 
country with 
whichCanada has a 
free trade agreement 
is included in the 
value r equirement as 
if it were added in 
the LDC.  
Else: WO; 60% 
MaxNom  
4202 Trunks, suitcases, 
vanity cases, 
executive -cases, 
briefcases, school 
satchels, spectacle 
cases, binocular 
cases, camera 
cases, musical 
instrument cases, 
gun cases, holsters 
and similar 
containers; 
travelling -bags, 
insulated food or 
beverage bags, 
toilet ba gs, 
rucksacks, 
handbags, 
shopping -bags, 
wallets, purses, 
map-cases, 
cigarette -cases, 
tobacco -pouches, 
tool bags, sports 
bags, bottle -cases, 
jewellery boxes, 
powder -boxes, 
cutlery cases and 
similar containers, 
of leather or of 
composition Manufacture from 
materials of any 
heading, except 
that of the product 
or Manufacture in 
which the value of 
all the mat erials 
used does not 
exceed 70 % of the 
ex-works price of 
the product  CTH or 75% MaxNom 
(EXW)  Manufactured from 
products of the different 
tariff headings 
(excluding heading 
42.05) of the products  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United St ates; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of  this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than RoO: 
-The product must 
be imp orted 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufactur e or 
production of the WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non-originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change  in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods  
  G/RO/W/229  
 
- 26 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
leather, of sheeti ng 
of plastics, of 
textile materials, of 
vulcanised fibre or 
of paperboard, or 
wholly or mainly 
covered with such 
materials or with 
paper  39% of the appraised 
value of such article at the 
time it is entered.  in one or more 
designated AGOA -
beneficiary 
countrie(s ), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addi tion, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consum ption in the 
least developed 
country.  Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  in the territory of 
beneficiary country is 
different from that of 
the goods.  
6109 T-shirts, singlets 
and ot her vests, 
knitted or 
crocheted.  (a) LDCs 
Manufacture from 
fabric / Spinning of 
natural and/or 
man-made staple 
fibres or extrusion 
of manmade 
filament yarn, in 
each case 
accompanied by 
knitting (knitted to 
shape products) or 
Dyeing of yarn of 
natural fibre s 
accompanied by 
knitting (knitted to 
shape products) 
(7) Manufacture from 
fabric / CC or 75% 
MaxNom or 
processing rule  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country int o 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated  as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. yarn  
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Lesser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere For 6109.10, 6109.90 
(Part A3 in the 
regulations) : Similar 
to the rules of origin 
for apparel A1&A2, 
with three 
modifications. The 
fabric may be cut in 
Canada, another 
LDC, a current or 
former GSP 
beneficiary or a 
country with which 
Canada has a free 
trade agreement, 
LDCs may use fabric 
or yarn that has been 
produced in a country 
with which Canada 
has a free trade 
agreement, as long 
as 25% value is 
added in the LDC,  
and Any value that is 
added in Canada or a 
country with which  
Canada has a free 
trade agreement is WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting b eneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (th at is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change WO; 
For not -wholly 
produced products: 
The determining 
criter ia for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the  
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating  
  G/RO/W/229  
 
- 27 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
beneficiary developing 
country or such member 
countries , is not less than 
40% of the appraised 
value of such article at the 
time it i s entered.  sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns or 
finer  included in the value 
requirement as if it 
were added in the 
LDC.  
Else: WO; 60% 
MaxNom  in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classifica tion in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.  
1006 Rice Manufacture in 
which all the 
materials of 
Chapter 10 used 
are wholly obtained  CC WO; 
For not -wholly produced 
products:  
1. The manufacturing or 
processing as provided 
for subparagraph (2) of 
paragraph 1 of Article 
26 of the Cabinet Order 
shall be manufacturing 
or processing, as a 
result of which the 
heading of the Tariff 
Schedule of the goods 
changes from any 
heading of raw 
materials originating 
from other countries 
used in  the production 
of the goods. In the 
case of a good in each 
middle column of the 
Annexed Table, the 
manufacturing or 
processing shall be the 
manufacturing or 
processing in each 
lower column of the 
Annexed Table.  
2. When a good 
classified in HS Chapter 
50-63 is produced in a 
beneficiary country 
using non -originating 
material not satisfying 
PSR (Product Specific 
Rules), the goods shall 
not be considered to 
have undergone the 
substantial 
transformation in 
principal. However, if 
the total weight of the (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product , or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in th e 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
41% of the appraised 
value of such article at the 
time it is entered.  RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from o utside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Speci fic Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
  G/RO/W/229  
 
- 28 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
non-originating 
materials not satisfying 
PSR is less than 10% of 
the weight of the good, 
such non -originating 
material shall be 
disregarded in 
determining whether 
the goods have 
undergone substantial 
transformation.  
3. When the 
classification of goods 
consisting o f different 
materials, goods made 
in different components 
and sets for retail sale, 
are determined 
pursuant to Rule 3 of 
the General Rules for 
the interpretation of the 
Harmonized Tariff 
Schedule of the 
Customs Tariff Law 
Appendix, the origin of 
the goods is determined 
in accordance with 
manufacturing or 
processing prescribed 
for heading in which the 
goods are classified.  value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the U S port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed c ountry; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  territory of the 
exporting beneficiary 
country.  
6104 Women's or girls' 
suits, ensembles, 
jackets, blazers, 
dresses, skirts, 
divided skirts, 
trousers, bib and 
brace overalls, 
breeches and 
shorts, knitted or 
crocheted (excl. 
wind-jackets and 
similar articles, 
slips, petticoats 
and panties, 
tracksuits, ski suits 
and swimwear)  (a) LDCs 
Manufacture from 
fabric / Spinning of 
natural and/or 
man-made staple 
fibres or extrusion 
of manmade 
filament yarn, in 
each case 
accompanied by 
knitting (knitted to 
shape products) or 
Dyeing of yarn of 
natural fibres 
accompanied by 
knitting (knitted to 
shape products) 
(7) Manufacture from 
fabric / CC or 75% 
MaxNom or 
processing rul e Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, produ ct, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. yarn 
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Le sser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 6104.13, 6104.19, 
6104.22, 6104.23, 
6104.29, 6104.31, 
6104.32, 6104.33, 
6104.39, 6104.41, 
6104.4 2, 6104.43, 
6104.44, 6104.49, 
6104.51, 6104.52, 
6104.53, 6104.59, 
6104.61 and 6104.69  
(Part A1 in the 
regulations): use 
fabric produced in 
current or former 
GSP beneficiaries in 
the production of 
apparel, provided 
they add at least 
25% value in the 
LDC. ( Any value that 
is added in Canada is 
also considered as if 
it were added in the 
LDC.) The ad valorem 
percentage is 
calculated by using 
the value of non -
originating materials WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exportin g beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Region al Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating  
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beneficiary developing 
country or such member 
countries , is not less than 
42% of the appraised 
value of such article at the 
time it is entered.  sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns or 
finer  as a percentage of 
the ex -factory price 
of the final goods as 
packed for shipment 
to Canada. LDCs may 
also use fabric 
produced in an LDC 
or Canada in the 
production of 
apparel, with no 
value requirement. In 
both cases, the yarn 
must also be 
produced in an LDC, 
Canada or a current 
or former GSP 
beneficiary country.  
For 6104.62, 6104.63 
(Part A3 in the 
regulations): Similar 
to the rules of origin 
for apparel A1&A2, 
with three 
modifications. The 
fabric may be cut in 
Canada, another 
LDC, a current or 
former GSP 
beneficiary or a 
country with which 
Canada has a free 
trade agreement, 
LDCs may u se fabric 
or yarn that has been 
produced in a country 
with which Canada 
has a free trade 
agreement, as long 
as 25% value is 
added in the LDC,  
and Any value that is 
added in Canada or a 
country with 
whichCanada has a 
free trade agreement 
is included in the 
value requirement as 
if it were added in 
the LDC.  
Else: WO; 60% 
MaxNom  in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in i ts 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the good s. 
8105 Cobalt mattes and 
other intermediate 
products of cobalt 
metallurgy; cobalt 
and articles 
thereof, n.e.s.; 
cobalt waste and 
scrap (excl. ash Manufacture from 
materials of any 
heading  CTH Manufactured from 
products of the different 
tariff heading (excluding 
unwrought) of the 
products  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary develo ping RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary WO; 
For no t-wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value  
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and residues 
containing cobalt  country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or suc h member 
countries , is not less than 
43% of the appraised 
value of such article at the 
time it is entered.  "growth, product or 
manufacture"  of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
benefici aries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
produ ct's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  parts or products 
originat ing outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following  are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed cou ntry or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for  the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmoni zed System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
product ion or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.  
6205 Men's or boys' 
shirts (excl. knitted 
or crocheted, 
nightshirts, singlets 
and other vests)  (a) LDCs 
Manufacture from 
fabric  Manufacture from 
fabric  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed For 6205.20, 6205.30 
(Part A1 in the 
regulations) and 
6205.90  (Part A2 in 
the regulations): use WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced WO; 
For not -wholly 
produced products: 
The determining 
criteria for  
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of Chapter 50 to 56 or 
58 to 60  the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into  
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
44% of the appraised 
value of such article at the 
time it is  entered.  and cut fabric from 
U.S. yarn  
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric f rom 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Lesser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 
sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns or 
finer  fabric produced in 
current or former 
GSP beneficiaries in 
the production of 
apparel, provided 
they add at least 
25% value in the 
LDC. (Any  value that 
is added in Canada is 
also considered as if 
it were added in the 
LDC.) The ad valorem 
percentage is 
calculated by using 
the value of non -
originating materials 
as a percentage of 
the ex -factory price 
of the final goods as 
packed for shipment 
to Canada. LDCs may 
also use fabric 
produced in an LDC 
or Canada in the 
production of 
apparel, with no 
value requirement. In 
both cases, the yarn 
must also be 
produced in an LDC, 
Canada or a current 
or former GSP 
beneficiary country.  
Else: WO; 60% 
MaxNom  shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a chan ge 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  "substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classificati on means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.  
7103 Precious stones and 
semi-precious 
stones, whether or 
not worked or 
graded, but not 
strung, mounted or 
set, ungraded 
precious stones 
and semi -precious 
stones, temporarily 
strung for 
convenience of 
transport (excl. 
diamonds and 
imitation precious 
stones and semi -
precious stones)  Manufacture from 
materials of any 
heading, ex cept 
that of the product 
or Manufacture in 
which the value of 
all the materials 
used does not 
exceed 70 % of the 
ex-works price of 
the product  CTH or 75% Max 
Nom (EXW)  WO; 
For not -wholly produced 
products:  
1. The manufacturing or 
processing as provided 
for subparagraph (2) of 
paragraph 1 of Article 
26 of the Cabinet Order 
shall be manufacturing 
or processing, as a 
result of which the 
heading of the Tariff 
Schedule of the goods 
changes from any 
heading of raw 
materials originating 
from other countries 
used i n the production 
of the goods. In the (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, produc t, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in t he 
beneficiary developing 
country or any two or RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items  must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export p roduct does 
not exceed 70% of 
the FOB value or ex -
works value of the WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value  
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case of a good in each 
middle column of the 
Annexed Table, the 
manufacturing or 
processing shall be the 
manufacturing or 
processing in each 
lower column of the 
Annexed Table.  
2. When a good 
classified in HS Chapter 
50-63 is produced in a 
beneficiary country 
using non -originating 
material not satisfying 
PSR (Product Specific 
Rules), the goods shall 
not be considered to 
have undergone the 
substantial 
transformation in 
principal. However, if 
the total weight of the 
non-originating 
materials not satisfying 
PSR is less than 10% of 
the weight of the good, 
such non -originating 
material shall be 
disregarded in 
determining whether 
the goods have 
undergone substantial 
transformation.  
3. When the 
classification of goods 
consisting of different 
materials, goods made 
in different components 
and sets for retail sale, 
are determined 
pursuant to Rule 3 of 
the General Rules for 
the interpretation of the 
Harmonized Tariff 
Schedule of the 
Customs Tariff Law 
Appendix, the origin of 
the goods  is determined 
in accordance with 
manufacturing or 
processing prescribed 
for heading in which the 
goods are classified.  more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
45% of the appraised 
value of such article at the 
time it is entered.  of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  shipment to Canada.  
(9) For the  purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classificat ion 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the headin g of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.  
713 Dried leguminous 
vegetables, shelled, 
whether or not 
skinned or split.  Manufacture in 
which all the 
materials of 
Chapter 7 used are 
wholly obtained  CTH Manufactured from 
products other than 
those of Chapter 7  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary WO;  
(3) Go ods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced WO; 
For not -wholly 
produced products: 
The determining 
criteria for  
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the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into  
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
46% of the appraised 
value of such article at the 
time it is  entered.  country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than on e 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more  
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
producti on of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or p roducts that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the go ods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which t he goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following  
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used  in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  "substantial 
transformation" shall 
be "R egional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.  
2709 Petroleum oils and 
oils obtained from Manufacture from 
materials of any CTH; or 75% 
MaxNOM (EXW).  WO; 
For not -wholly produced (A) General rule  
The duty -free treatment RoO: 
-The product must WO;  
(3) Goods other than WO; 
For not -wholly WO; 
For not -wholly  
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
bituminous 
minerals, crude.  heading, except 
that of the product 
or Manufacture in 
which the value of 
all the materials 
used does not 
exceed 70 % of the 
ex-works price of 
the product  products:  
1. The manufacturing or 
processing as provided 
for subparagraph (2) of 
paragraph 1 of Article 
26 of the Cabinet Order 
shall be manufacturing 
or processing , as a 
result of which the 
heading of the Tariff 
Schedule of the goods 
changes from any 
heading of raw 
materials originating 
from other countries 
used in the production 
of the goods. In the 
case of a good in each 
middle column of the 
Annexed Table, the 
manufacturing or 
processing shall be the 
manufacturing or 
processing in each 
lower column of the 
Annexed Table.  
2. When a good 
classified in HS Chapter 
50-63 is produced in a 
beneficiary country 
using non -originating 
material not satisfying 
PSR (Product Speci fic 
Rules), the goods shall 
not be considered to 
have undergone the 
substantial 
transformation in 
principal. However, if 
the total weight of the 
non-originating 
materials not satisfying 
PSR is less than 10% of 
the weight of the good, 
such non -originating 
material shall be 
disregarded in 
determining whether 
the goods have 
undergone substantial 
transformation.  
3. When the 
classification of goods 
consisting of different 
materials, goods made 
in different components 
and sets for retail sale, 
are determined 
pursuant to Rule 3 of provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a b eneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
associa tion of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
47% of the appraised 
value  of such article at the 
time it is entered.  be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the  
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and u sed in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20%  of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection , not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the lo cal value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which  
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  produced products: 
The determining 
criteria for 
"subst antial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional val ue 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary cou ntry is 
different from that of 
the goods.   
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
the General Rules for 
the interpretation of the 
Harmonized Tariff 
Schedule of the 
Customs Tariff Law 
Appendix, the origin of 
the goods is determined 
in accordance with 
manufacturing or 
processing prescribed 
for heading in which the 
goods are classified.  cumulation of 
origin").  
6103 Men's or boys' 
suits, ensembles, 
jackets, blazers, 
trousers, bib and 
brace overalls, 
breeches and 
shorts (excl. wind -
jackets and similar 
articles, separate 
waistcoats, 
tracksuits, ski suits 
and swimwear)  (a) LDCs 
Manufacture from 
fabric / Spinning of 
natural and/or 
man-made staple 
fibres or extrusion 
of manmade 
filament yarn, in 
each case 
accompanied by 
knitting (knitted to 
shape products) or 
Dyeing of yarn of 
natural fibres 
accompanied by 
knitting (knitted to  
shape products) 
(7) Manufacture from 
fabric / CC or 75% 
MaxNom or 
processing rule  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory o f 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under sec tion 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
48% of the appraised 
value of such article at the 
time it is entered.  Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. yarn  
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Lesser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 
sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers 
18.5 microns or 
finer  For 6103.42, 6103.43  
(Part A3 in the 
regulations): Similar 
to the rules of origin 
for apparel A1&A2, 
with three 
modifications. The 
fabric may be cut in 
Canada, another 
LDC, a current or 
former GSP 
beneficiary or a 
country with which 
Canada has a free 
trade a greement, 
LDCs may use fabric 
or yarn that has been 
produced in a country 
with which Canada 
has a free trade 
agreement, as long 
as 25% value is 
added in the LDC,  
and Any value that is 
added in Canada or a 
country with 
whichCanada has a 
free trade agreement  
is included in the 
value requirement as 
if it were added in 
the LDC.  
Else: WO; 60% 
MaxNom  WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value adde d 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transfo rmation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
differ ent from that of 
the goods.  
1511 Palm oil and its 
fractions, whether Manufacture from 
materials of any CTSH  Manufactured from 
products other than (A) General rule  
The duty -free treatment RoO: 
-The product must WO;  
(3) Goods other than WO; 
For not -wholly WO; 
For not -wholly  
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
or not refined, but 
not chemically 
modified.  sub-heading, 
except that of the 
product  palm stearin of heading 
15.11  provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary  
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of co untries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
49% of the appraised 
value of such a rticle at the 
time it is entered.  be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or  value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called  
"bilateral those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least develo ped 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting b eneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (th at is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classifica tion in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  produced products: 
The determining 
criter ia for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the  
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
cumulation of 
origin").  
7403 Copper, refined, 
and copper alloys, 
unwrought (excl. 
copper alloys of 
heading 7405)  Manufacture from 
materials of any 
heading  CTH Manufactured from 
products other than 
those of heading 74.01 
or 74.03 (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of cou ntries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
50% of the appraised 
value of such ar ticle at the 
time it is entered.  RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of lo cal 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) an y materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if th ey fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value a dded 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
region al value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficia ry country is 
different from that of 
the goods.   
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
materials. This 
concept is called 
"bilateral 
cumulation o f 
origin").  consumption in the 
least developed 
country.  
4001 Natural rubber, 
balata, gutta -
percha, guayule, 
chicle and similar 
natural gums, in 
primary forms or in 
plates, sheets or 
strip Manufacture from 
materials of any 
heading, except 
that of the product 
or Ma nufacture in 
which the value of 
all the materials 
used does not 
exceed 70 % of the 
ex-works price of 
the product  CTH or 75% MaxNom 
(EXW)  WO; 
For not -wholly produced 
products:  
1. The manufacturing or 
processing as provided 
for subparagraph (2) of 
paragraph 1 of Article 
26 of the Cabinet Order 
shall be manufacturing 
or processing, as a 
result of which the 
heading of the Tariff 
Schedule of the goods 
changes from any 
heading of raw 
materials originating 
from other countries 
used in the production 
of the goods. In the 
case of a good in each 
middle column of the 
Annexed Table, the 
manufacturing or 
processing shall be the 
manufacturing or 
processing in each 
lower column of the 
Annexed Table.  
2. When a good 
classified in HS Chapter 
50-63 is produced in a 
beneficiary country 
using non -originating 
material not satisfying 
PSR (Product Specific 
Rules), the goods shall 
not be considered to 
have undergone the 
substantial 
transformation in 
principal. However, if 
the total weight of the 
non-originating 
materials no t satisfying 
PSR is less than 10% of 
the weight of the good, 
such non -originating 
material shall be 
disregarded in 
determining whether 
the goods have 
undergone substantial 
transformation.  
3. When the (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary develo ping 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary devel oping 
country or such member 
countries , is not less than 
51% of the appraised 
value of such article at the 
time it is entered.  RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, pro duct or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i. e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsectio n (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other  least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary  
country.  WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials  used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
  G/RO/W/229  
 
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
classification of goods 
consisting of different 
material s, goods made 
in different components 
and sets for retail sale, 
are determined 
pursuant to Rule 3 of 
the General Rules for 
the interpretation of the 
Harmonized Tariff 
Schedule of the 
Customs Tariff Law 
Appendix, the origin of 
the goods is determined 
in acc ordance with 
manufacturing or 
processing prescribed 
for heading in which the 
goods are classified.  entry) may  consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  
7402 Unrefined copper; 
copper anodes for 
electrolytic refining  Manufacture from 
materials of any 
heading, except 
that of the product  CTH Manufactured from 
products other than 
those of heading 74.01 
or 74.02  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary dev eloping  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary developing 
country or a ny two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiary developing 
country or such member 
countries , is not less than 
52% of the appraised 
value of such article at the 
time it is entered.  RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufactu re" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced 
from outside 
countries (i.e. non 
AGOA -
benef iciaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" 
undertaken in the 
AGOA -beneficiary 
countrie(s), equal WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
follow ing are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of WO; 
For not -wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harm onized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process WO; 
For not-wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to t he 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
  G/RO/W/229  
 
- 40 - HS 
Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  
6403 Footwear with 
outer soles of 
rubber, plastics, 
leather or 
composition leather 
and uppers of 
leather (excl. 
orthopaedic 
footwear, skating 
boots  with ice or 
roller skates 
attached, and toy 
footwear)  Manufacture from 
materials of any 
heading, except 
from assemblies of 
uppers affixed to 
inner soles or to 
other sole 
components of 
heading 
6414/6415/6416/6
417/6418/6419/64
20/6421(depending 
on the HS 6 d igits) CTH Manufactured from 
products of the different 
tariff heading (excluding  
heading 64.06) of the 
products  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufacture of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produce d in the 
beneficiary developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performe d in such 
beneficiary developing 
country or such member 
countries , is not less than 
53% of the appraised 
value of such article at the 
time it is entered.  RoO: 
-The product must 
be imported 
directly from the 
AGOA -beneficiary 
country into the 
United States;  
-Items must be 
"growth, product or 
manufacture" of 
one or more AGOA -
beneficiary 
countries (these 
requirements can 
be met jointly by 
more than one 
AGOA beneficiary - 
this concept is 
called ‘cumulation 
of origin’);  
-Products may 
incorporate 
materials sourced  
from outside 
countries (i.e. non 
AGOA -
beneficiaries) 
provided that the 
sum of the direct 
cost or value of the 
materials produced 
in one or more 
designated AGOA -
beneficiary 
countrie(s), plus 
the "direct costs of 
processing" WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the val ue 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed for 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that 
     (i) originate in 
any other least 
developed country or WO; 
For not -wholly 
produced product s: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufacture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub-heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff 
classification in which 
the non -originating 
material used in its WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the goods 
listed in the "Produc t 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non-originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is 
different from that of 
the goods.   
  G/RO/W/229  
 
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
undertaken in the 
AGOA -beneficia ry 
countrie(s), equal 
at least 35% of the 
product's appraised 
value at the US 
port of entry (See 
Note below);  
-Cost of local 
materials + direct 
cost of processing 
must >= 35%  
-In addition, a total 
of up to 15% of the 
35% local content 
value (as appraised 
at the US port of 
entry) may consist 
of US -originating 
parts and 
materials. This 
concept is called 
"bilateral 
cumulation of 
origin").  in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedule 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory o f the 
exporting beneficiary 
country.  
6108 Women's or girls' 
slips, petticoats, 
briefs, panties, 
nightdresses, 
pyjamas, négligés, 
bathrobes, dressing 
gowns, housecoats 
and similar articles, 
knitted or 
crocheted (excl. T -
shirts, vests, 
brassieres, girdles, 
corsets and similar 
articles)  (a) LDCs 
Manufacture from 
fabric / Spinning of 
natural and/or 
man-made staple 
fibres or extrusion 
of manmade 
filament yarn, in 
each case 
accompanied by 
knitting (knitted to 
shape products) or 
Dyeing of yarn of 
natural fibres 
accompanied by 
knitting (knitted to 
shape products) 
(7) Manufacture from 
fabric / CC or 75% 
MaxNom or 
processing rule  Manufactured from 
woven fabrics, felt, 
nonwovens, knitted or  
crocheted fabrics or lace 
of Chapter 50 to 56 or 
58 to 60  (A) General rule  
The duty -free treatment 
provided under this 
subchapter shall apply to 
any eligible article which is 
the growth, product, or 
manufact ure of a 
beneficiary developing  
country if - 
(i) that article is imported 
directly from a beneficiary 
developing country into 
the customs territory of 
the United States; and  
(ii) the sum of - 
(I) the cost or value of the 
materials produced in the 
beneficiary  developing 
country or any two or 
more such countries that 
are members of the same 
association of countries 
and are treated as one 
country under section 
2467(2) of this title, plus  
(II) the direct costs of 
processing operations 
performed in such 
beneficiar y developing 
country or such member 
countries , is not less than 
53% of the appraised 
value of such article at the 
time it is entered.  Summary of 
Apparel Rules of 
Origin Under AGOA  
-Apparel assembled 
from U.S. formed 
and cut fabric from 
U.S. yarn  
-Apparel assembled 
and further 
processed from 
U.S. formed and 
cut fabric from U.S. 
yarn 
-Apparel cut and 
assembled from 
U.S. fabric from 
U.S. 
yarn and thread  
-Apparel assembled 
from regional fabric 
from U.S. or 
African yarn  
-Apparel assembled 
in a Lesser 
Developed Country 
using foreign fabric 
or yarn  
-Cashmere 
sweaters, knit to 
shape  
-Merino wool 
sweaters, knit to 
shape, with fibers WO;  
(3) Goods other than 
those set out in Part 
A1, A3 or B of 
Schedule 1 originate 
in a least developed 
country if the value 
of the materials, 
parts or products 
originating outside 
that country, or in an 
undetermined 
location, and used in 
the manufacture or 
production of the 
goods is no more 
than 60% of the ex -
factory price of the 
goods as packed f or 
shipment to Canada.  
(9) For the purpose 
of subsection (3), the 
following are deemed 
to have originated in 
the least developed 
country:  
     (a) any materials, 
parts or products that 
are used in the 
manufacture or 
production of the 
goods referred to in 
that subsection and 
that WO; 
For not-wholly 
produced products: 
Products not wholly 
obtained or produced 
shall be considered 
as originating in the 
exporting beneficiary 
country if they fulfil 
the following 
conditions:  
(a) the total value of 
the non -originating 
materials used in the 
manufa cture of the 
export product does 
not exceed 70% of 
the FOB value or ex -
works value of the 
product so produced 
or obtained (that is, 
the local value added 
content in the 
exporting beneficiary 
country is at least 
30%);  
(b) the product has 
undergone a change 
in tariff classification 
in sub -heading at the 
6 digit level of the 
Harmonized System 
nomenclature from 
the tariff WO; 
For not -wholly 
produced products: 
The determining 
criteria for 
"substantial 
transformation" shall 
be "Regional Value 
Content" (RVC) or 
"Change in Tariff 
Classification" (CTC). 
Whereas the  goods 
listed in the "Product 
Specific Rules" (PSR) 
are not subject to the 
said criteria.  
The criterion of RVC 
means that the 
regional value 
content of goods, 
expressed as a 
percentage, is no less 
than 40%.  
The criterion of 
Change in Tariff 
Classification means 
that the heading of 
all non -originating 
materials used in the 
production or 
manufacture of goods 
in the territory of 
beneficiary country is  
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Code Product Description  EU UK Japan  US Canada  India China  GSP AGOA  
18.5 microns or 
finer       (i) originate in 
any other least 
developed country or 
in Canada, or  
    (ii) have a value of 
no more than 20% of 
the ex -factory price 
of the goods, as 
packed for shipment 
to Canada, and 
originate in a country 
set out in Schedul e 2, 
other than a least 
developed country; 
and 
(b) any packing 
required for the 
transportation of the 
goods referred to in 
that subsection, not 
including packing in 
which the goods are 
ordinarily sold for 
consumption in the 
least developed 
country.  classification in which 
the non -originating 
material used in its 
manufacture are 
classified; and  
(c) the final process 
of manufacture is 
performed within the 
territory of the 
exporting beneficiary 
country.  different from that of 
the goods.  
 
__________