Generating REX statements: what every exporter needs to know

Everything about the Registered Exporter System: when REX is mandatory, how to generate statements correctly, and which mistakes to avoid.

Pillar context

The Registered Exporter System (REX) is the system used by the European Union for origin certification when exporting to and importing from countries with which the EU has concluded preferential trade agreements. For exporters who wish to benefit from reduced customs tariffs, registration in the REX system and the correct generation of origin statements is an absolute requirement. Yet in practice, considerable confusion exists about the rules, obligations, and pitfalls.

This article provides a comprehensive overview: from the fundamentals of REX to the operational details of generating statements, including the most common mistakes and how to prevent them.

What is the REX system?

The Registered Exporter System was introduced as part of the EU's Generalized System of Preferences (GSP) and is now also applied under various bilateral and regional trade agreements. The system replaces the traditional EUR.1 certificates issued by customs authorities with origin statements drawn up by registered exporters themselves.

Core principles

The REX system is based on several fundamental principles. First, the principle of self-certification: the exporter declares the origin of their goods themselves, rather than having this done by customs authorities. Second, the principle of registration: only exporters registered with the competent authorities may draw up origin statements for shipments above the value threshold. Third, the principle of post-verification: customs authorities in the country of import may verify the origin statement after the fact with the authorities in the country of export.

When is REX registration mandatory?

REX registration is mandatory for exporters wishing to draw up origin statements for shipments with a value exceeding 6,000 euros. For shipments below this threshold, any exporter may draw up an origin statement regardless of registration status. It is important to note, however, that this threshold applies per shipment, not per product or per invoice.

In practice, this means that virtually all professional exporters who regularly engage in preferential trade must be registered. The 6,000 euro threshold is quickly reached for industrial goods, chemical products, or machinery.

Which trade agreements require REX?

The REX system is applied under multiple trade agreements and arrangements. The most important are the EU GSP (Generalized System of Preferences) for developing countries, the EU-Canada trade agreement (CETA), the EU-Japan trade agreement (EPA), the EU-Vietnam trade agreement, the EU-Singapore trade agreement, the agreement with Pacific countries (EPA Pacific), and various other bilateral and regional agreements.

It is essential to verify per trade agreement whether REX applies, as some agreements use their own certification systems.

The registration process

Preparation

Before applying for REX registration, several matters must be in order. You must have an EORI number (Economic Operators Registration and Identification), a clear overview of the products you export with the corresponding HS codes, documentation supporting the origin of your products, and knowledge of the applicable rules of origin (Product Specific Rules, PSRs) per product and per trade agreement.

The application

REX registration is applied for at the competent authority in your country. In the Netherlands, this is the Customs authority (Douane), in Belgium the FPS Finance, in Germany the Hauptzollamt, and in France the Direction Generale des Douanes. The application typically includes completing an application form with company details, listing the products and HS codes for which you wish to draw up origin statements, a declaration that you are able to verify and document the origin of your products, and potentially additional supporting documentation.

Processing and assignment

After receiving the application, the competent authority verifies the details and assigns a REX number. This number is unique and is entered into the REX database, which is accessible to customs authorities worldwide. Processing time varies by member state but typically ranges from 2 to 6 weeks.

Validity and maintenance

A REX registration has unlimited validity in principle, but the exporter is obliged to report changes in their details to the competent authority. This includes name changes, address changes, changes in the product range, and changes in the production process that may affect origin.

The competent authority may revoke the registration if the exporter no longer meets the conditions or if verification reveals that origin statements have been incorrectly drawn up.

Correctly generating origin statements

The origin statement on the invoice

The origin statement under REX is placed on the commercial invoice, the packing list, or another commercial document that sufficiently identifies the goods. The statement must contain the following elements: the prescribed text as per the applicable trade agreement, the REX number of the exporter (for shipments above 6,000 euros), the date of preparation, and the origin of the goods.

Prescribed text

The exact text of the origin statement is specified in the relevant trade agreement and differs per agreement. A commonly used formulation is: "The exporter of the products covered by this document (customs authorisation No. ... [REX number]) declares that, except where otherwise clearly indicated, these products are of ... preferential origin."

It is crucial to use the correct text belonging to the specific trade agreement. Using text from a different agreement leads to rejection.

Language requirements

The origin statement must be drawn up in a language specified in the relevant trade agreement. In most cases, these are English, French, or Spanish, but some agreements also permit other languages. Always check the language requirements in the specific agreement.

Digital versus paper statements

While the origin statement is traditionally drawn up on paper, an increasing number of customs authorities accept digital statements. This requires, however, that the digital statement meets the same requirements as the paper version and that authenticity can be verified.

Product Specific Rules (PSRs) and origin

What are PSRs?

Product Specific Rules are the criteria that determine when a product can be considered as originating in a particular country. These rules are specified per HS code and per trade agreement. The three main types of PSRs are change of tariff heading (CTH), value criterion (a maximum percentage of non-originating materials), and processing criterion (specific operations that must have been performed).

Checking PSRs for origin statements

Before drawing up an origin statement, you must verify that your product meets the applicable PSR. This requires a thorough analysis of the materials used and their origin, the production process and value added, the classification under the correct HS code, and the specific requirements of the applicable trade agreement.

Cumulation

Many trade agreements include cumulation rules, whereby materials from certain partner countries can be considered as originating. This can significantly expand the possibilities for preferential origin. Bilateral cumulation concerns the use of materials from the partner country. Diagonal cumulation concerns the use of materials from multiple countries that are part of the same cumulation network. Full cumulation concerns adding together all operations in the partner countries.

Common mistakes with REX statements

Based on years of practical experience, we identify the most common mistakes exporters make when generating REX statements.

Mistake 1: Using the wrong text

The most common mistake is using an origin statement belonging to a different trade agreement than the one under which the preference is claimed. Each trade agreement has its own prescribed text. Copying text from another agreement leads to rejection.

Mistake 2: Missing or incorrect REX number

For shipments above the 6,000 euro value threshold, the REX number must be stated. A missing or incorrect REX number results in the origin statement not being accepted. Always verify that the stated number matches the number in the REX database.

Mistake 3: Origin not verified

Drawing up an origin statement without prior verification of origin is a serious violation. The exporter is responsible for the accuracy of the statement and can be held liable for incorrect claims.

Mistake 4: Expired or revoked registration

An origin statement drawn up with a REX number from an expired or revoked registration is invalid. Regularly check the status of your registration and that of your suppliers.

Mistake 5: Insufficient documentation

The exporter must be able to support the origin of their products with documentation. This includes purchase documents, production documentation, supplier declarations, and PSR calculations. Without adequate documentation, the origin statement cannot be substantiated during verification.

Mistake 6: Incorrectly applying cumulation

Incorrectly applying cumulation rules is a frequent source of errors. Not all materials from all partner countries qualify for cumulation. Always check the specific cumulation provisions in the applicable trade agreement.

Mistake 7: No archiving

Exporters are obliged to retain the documentation underlying origin statements for a specified period. This retention period varies by member state and by trade agreement but typically ranges from 3 to 5 years. Failure to meet archiving obligations can lead to revocation of the REX registration.

Automating REX statements

Why automate?

With a high volume of shipments, manually generating origin statements becomes impractical and risky. Automation offers multiple advantages: consistent application of the correct text per trade agreement, automatic verification of the REX number and registration validity, integration with PSR verification, automatic archiving with audit trail, and reduction of human errors.

Integration with existing systems

An automated REX process ideally integrates with the ERP system for order and product data, the customs system for HS codes and tariff information, the document management system for archiving, and the LTSD management system for supplier declarations.

Workflow automation

An automated workflow for REX statements typically includes the following steps: automatic identification of shipments eligible for preferential origin, verification of the PSR per product and per trade agreement, checking the REX number and registration validity, generating the origin statement with the correct text, placement on the commercial document, and archiving the complete dossier.

Compliance monitoring and audit readiness

Periodic checks

Implement a periodic control process for REX-related activities. This includes monthly verification of supplier REX registration validity, quarterly review of generated origin statements for accuracy, annual evaluation of PSR calculations for changed products or processes, and continuous monitoring of changes in trade agreements.

Audit trail

A complete audit trail is essential for REX compliance. Document per origin statement the REX number and validity status, the PSR applied and supporting calculation, the source data (invoices, supplier declarations, production documentation), the date and method of verification, and the responsible employee.

Preparing for customs audits

During a customs audit, you must be able to demonstrate within a short timeframe per shipment that the origin statement was rightfully issued. This requires an organised archive with quick search functionality, direct linkage between origin statement and supporting documentation, and a clear overview of all statements per period, per product, and per trade agreement.

Developments and trends

Digitalisation

The trend towards digitalisation of origin certification continues. The EU is working on electronic exchange of origin information between customs authorities, which accelerates verification and reduces opportunities for fraud.

Expansion of REX

The REX system is gradually being expanded to cover more trade agreements. Exporters who invest now in a robust REX management process are prepared for this expansion.

Integration with CBAM and due diligence

The increasing attention to supply chain transparency and CBAM reporting creates opportunities for integrating origin certification with emissions data and due diligence information. Organisations that integrate these data streams achieve a higher level of compliance efficiency.

Conclusion

Correctly generating REX statements requires knowledge of the regulations, careful verification of origin, and discipline in documentation and archiving. Complexity increases as the number of trade agreements grows and traceability requirements become stricter.

Automation is no longer optional for organisations with a significant volume of preferential trade. The investment in automated REX processes pays back through avoided errors, faster turnaround times, and audit readiness.

Next step

Download the REX guide for a complete handbook with sample forms, an error checklist, and an implementation plan for automated REX statements.

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Related definitions

  • Preferential origin: Preferential origin determines whether goods qualify for preferential treatment under a trade agreement.
  • LTSD: An LTSD is a long-term supplier declaration supporting origin claims across multiple shipments.
  • REX: REX refers to registered exporters that may issue origin statements under specific arrangements.
  • BOI: BOI refers to a binding origin or information decision that provides legal certainty.