India-New Zealand FTA Rules of Origin 2026: Customs Duty, Certificate of Origin and Import-Export Compliance

Importing goods from New Zealand does not automatically make them eligible for lower customs duty in India. The goods must first meet the origin requirements under the applicable trade agreement. The same principle applies to Indian exporters who want their products to qualify for preferential tariff treatment in New Zealand.

The Ministry of Finance has notified the Customs Tariff (Determination of Origin of Goods under the Free Trade Agreement between India and New Zealand) Rules, 2026, through Notification No. 82/2026-Customs (N.T.), dated 12 October 2026.

The rules are set to take effect on 20, October 2026. They explain how customs authorities will determine whether goods qualify as originating from India or New Zealand under the FTA. They also cover the use of imported materials, Certificate of Origin requirements, claims for preferential duty and the verification of origin by customs officials.

For businesses involved in international trade, the main question is whether their products meet the conditions for preferential treatment. That determination depends on the product's origin, applicable HS code, supporting records and the requirements specified in the notification.

The new framework makes origin-related documentation an important consideration for Indian importers, exporters and manufacturers trading with New Zealand.

Notification at a Glance

The Central Board of Indirect Taxes and Customs (CBIC) has notified a dedicated framework for determining the origin of goods traded under the India-New Zealand FTA.

The notification contains 34 rules and three annexures. Together, they explain how originating status is established, which evidence may be needed and how customs authorities can examine claims for preferential tariff treatment.

The Regulatory Framework

The rules define the legal basis for determining the origin of goods and clarify the responsibilities of the authorities involved in checking preferential duty claims. Three aspects are important: the law under which the rules were issued, the role of customs authorities, and the link between origin criteria and the duty benefits available under the FTA.

Customs Tariff Act, 1975

The Government has issued the new rules under Section 5(1) of the Customs Tariff Act, 1975.

The Act provides the legal basis for prescribing rules to determine the origin of goods in connection with preferential trade arrangements.

Under an FTA, two countries can agree to lower import duties on specific goods. These lower rates apply only to products that satisfy the origin rules and other conditions mentioned in the agreement.

Rules of Origin provide the method for identifying such products.

Role of CBIC in FTA Customs Compliance

CBIC is responsible for customs administration on the Indian side under the notified framework.

Indian customs authorities can examine claims for preferential treatment and request information needed to verify the origin of goods.

The Department of Commerce is identified as India's competent authority, while New Zealand Customs Service performs the corresponding functions specified for New Zealand.

The involvement of these authorities is particularly relevant when a Certificate of Origin requires verification or when questions arise about the production of goods.

Relationship Between the FTA and Customs Duty

The India-New Zealand FTA and the notified Rules of Origin perform different functions.

The FTA sets out the trade arrangement between the participating countries, including tariff commitments. The Rules of Origin establish the conditions used to determine whether goods qualify as originating.

This distinction matters because a product can satisfy the applicable origin rule without necessarily being eligible for a zero-duty rate.

Before claiming a tariff preference, an importer must establish both the product's originating status, and the availability of the relevant concession under the applicable tariff provisions.

What are the India-New Zealand FTA Rules of Origin, 2026?

The Rules of Origin determine whether goods can be treated as originating in India, or New Zealand for the purpose of receiving preferential tariff treatment under the agreement.

A product's origin is not necessarily the same as the country from which it is shipped.

Goods can be manufactured using materials sourced from several countries. Some products may undergo substantial manufacturing in India or New Zealand, while others may receive only basic processing or packaging.

The rules distinguish between these situations by examining how the goods were obtained or produced.

Under Rule 3, originating status is determined through the following principal routes:

1. Wholly obtained or produced goods: Goods meeting the conditions prescribed in Rule 4.
2. Goods meeting Product-Specific Rules: Goods satisfying the applicable requirements under Annexure A.

In both cases, the other relevant provisions of the rules must also be satisfied.

Why Is Origin Determination Important for Businesses?

Origin determination can affect several parts of an import or export transaction.

• Preferential customs duty: Goods must qualify under the relevant origin provisions before the applicable benefit can be claimed.
• Manufacturing decisions: Producers may need to examine where inputs are sourced and what processing is carried out.
• Trade documentation: Importers and exporters must keep suitable evidence to support origin-related information.
• Customs clearance: Authorities may examine the declared origin, and request further information.
• Commercial planning: The applicable origin requirement may affect whether a business can rely on preferential tariffs when calculating landed costs.

Businesses should therefore check origin eligibility during transaction planning rather than treating it as a formality at the time of customs clearance.

What Has Changed Under the New Customs Rules?

The notification creates a specific origin determination framework for trade under the India-New Zealand FTA.

It provides rules for determining origin, obtaining and using proof, maintaining records and verifying claims.

The rules do not require every business trading with New Zealand to obtain a new general registration. The obligations depend on the role of the business, the goods concerned and whether preferential origin treatment is being claimed.

Scope and Applicability of the India-New Zealand FTA Rules

The rules concern goods traded under the agreement where originating status is relevant.

Different stakeholders have different responsibilities.

Indian Importers

Indian businesses importing goods from New Zealand need to determine whether the products qualify for preferential tariff treatment.

Where such treatment is claimed, importers must satisfy the applicable declaration, and evidence requirements.

A valid Proof of Origin is an important part of this process. Importers may also need information concerning the product's manufacture or its movement through other countries.

Indian Exporters

Indian exporters supplying goods to New Zealand must examine the origin requirements applicable to their products.

The goods may contain imported raw materials or components, making it necessary to assess the relevant Product-Specific Rule.

Exporters applying for origin certification must provide accurate supporting information.

Manufacturers and Producers

Manufacturers have a particularly important role because the origin determination may depend on their production process.

Relevant details can include:

• The identity and origin of raw materials.
• The manufacturing operations carried out.
• The classification of inputs and finished goods.
• The value of originating and non-originating materials.
• Production and accounting records.

Not every product requires the same information. The applicable origin criterion determines what must be established.

Indian Status Holders

Rule 20 contains provisions for eligible Indian exporters recognised as status holders under the applicable framework.

These provisions are relevant to Origin Declarations and the responsibility for the accuracy of declared origin.

New Zealand Approved Exporters

Rule 21 covers approved exporters established in New Zealand.

Eligible exporters may receive authorisation to self-certify origin declarations, subject to the applicable conditions.

Applicability Matrix

The requirements should be applied according to the actual transaction rather than treating every stakeholder as subject to identical obligations.

Implementation Timeline and Important Dates

The main commencement date stated in the notification is 20 October 2026.

The rules also contain validity periods, document-retention requirements and procedural deadlines.

Does Every Business Have a Compliance Deadline of 20 October 2026?

No separate universal application deadline is prescribed for all businesses.

The date identifies when the notified rules are scheduled to commence.

Businesses seeking preferential treatment must comply with the relevant rules when making their claims.

Some procedural requirements are linked to the FTA's entry into force rather than simply to the notification date.

Which Goods Qualify as Originating Goods Under the FTA?

Rule 3 identifies the basic requirements for determining whether goods originate in India or New Zealand.

There are two main categories.

1. Wholly Obtained or Produced Goods

Rule 4 deals with goods obtained or produced in the territory of one or both FTA parties.

The categories include specified:

• Plants and plant products grown and harvested, picked or gathered in the relevant territory.
• Live animals born and raised there.
• Goods obtained from animals meeting the prescribed conditions.
• Products obtained through qualifying hunting, fishing, aquaculture or gathering.
• Minerals and naturally occurring substances extracted from qualifying locations.
• Fish and other marine products meeting the applicable vessel or territorial conditions.
• Certain waste and scrap suitable only for recovering raw materials.
• Goods produced solely from qualifying wholly obtained materials or their derivatives.

The rules contain particular conditions for marine products and other categories. The origin of such goods should not be determined merely by looking at the location where they were packed or sold.

2. Goods Meeting Product-Specific Rules

Goods manufactured from materials that are not wholly originating may still qualify when they satisfy the applicable Product-Specific Rule. These requirements are provided in Annexure A.

Depending on the product, the rule may involve:

• A change in tariff classification.
• A specified percentage of qualifying value.
• A particular manufacturing process.
• A combination of origin conditions.

The first step is to identify the correct HS classification for the finished product.

Product-Specific Rules of Origin Under Annexure A

Annexure A contains the product-wise requirements for determining originating status.

It uses the Harmonized System of tariff classification to identify the rules applicable to different goods.

The annexure includes several origin criteria.

Wholly Obtained (WO)

WO applies where a product must satisfy the conditions for wholly obtained goods.

For instance, Annexure A identifies WO as the origin rule for HS Chapter 1, covering live animals, and Chapter 2, covering meat and edible meat offal.

The applicable conditions under Rule 4 must still be satisfied.

Change in Chapter (CC)

CC requires non-originating materials used in production to undergo a change at the two-digit HS chapter level.

This means the required origin test examines whether the classification of relevant non-originating inputs differs from that of the finished goods at the specified level.

Change in Tariff Heading (CTH)

CTH applies the change-in-classification test at the four-digit heading level.

Manufacturers using non-originating inputs must examine whether those inputs meet the applicable classification change.

Change in Tariff Subheading (CTSH)

CTSH involves a change at the six-digit subheading level.

The requirement is more specific because it examines a narrower level of tariff classification.

Qualifying Value Content (QVC)

QVC applies where Annexure A specifies a qualifying value requirement.

The producer must establish the relevant value percentage using the applicable calculation method.

Manufacturing Process Requirements

Certain goods may be subject to specific production conditions.

Annexure A includes a melt-and-pour criterion relevant to specified iron and steel products.

The exact process requirement must be checked against the relevant tariff classification.

Understanding the Origin Criteria

Where Annexure A provides alternative criteria, meeting one permitted alternative may be sufficient.

Where multiple criteria are required together, all specified conditions must be satisfied.

Businesses should never assume that a rule applying to one product automatically applies to similar products under another HS classification.

How Is Qualifying Value Content Calculated?

Qualifying Value Content, or QVC, is used to assess origin eligibility where a product-specific rule includes a value-content condition.

Rules 6 and 7 explain the calculation methods and the valuation of materials.

Build-Down Method

The build-down method starts with the FOB value of the finished goods and deducts the value of non-originating materials.

Formula:

QVC = [(FOB Value- Value of Non-Originating Materials) ÷ FOB Value] × 100

Under this method, the calculation focuses on the portion of the product's FOB value remaining after the relevant non-originating material value is deducted.

Build-Up Method

The build-up method uses the value of originating materials.

Formula:

QVC = (Value of Originating Materials ÷ FOB Value) × 100

Both methods are recognised under Rule 6.

What Is FOB Value?

FOB stands for Free on Board. Under the notification, it refers to the price paid or payable for goods when loaded onto the carrier at the named export port, including the relevant costs of bringing the goods onto that carrier.

What Is CIF Value?

CIF stands for Cost, Insurance and Freight.

For imported materials, Rule 7 refers to CIF value when determining the value of materials used in production.

How Are Materials Valued?

Rule 7 provides different methods depending on how the materials are obtained.

The rule also requires costs and values to be maintained in accordance with the applicable Generally Accepted Accounting Principles.

Where a claimed adjustment cannot be supported by evidence, Rule 7 restricts the adjustment.

Do All Products Have the Same QVC Requirement?

No. Annexure A specifies the applicable requirement by product classification.

The annexure generally expresses QVC percentages using the build-down method. Where build-up is used, the applicable requirement is ten percentage points lower.

An exception applies to goods under HS Chapter 71, for which the stated QVC percentage applies under either method.

Businesses should verify the appropriate method and threshold rather than applying a standard percentage to every product.

Bilateral Cumulation Under the India-New Zealand FTA

Rule 5 provides for bilateral cumulation.

This provision deals with materials originating in one FTA country that are used to produce goods in the other country.

Where the applicable conditions are satisfied, originating materials from one party may be considered originating in the other party when incorporated into production.

Why Is Bilateral Cumulation Relevant?

Manufacturers may obtain components or raw materials from suppliers in the other FTA country.

If those materials qualify as originating, bilateral cumulation may help the manufacturer meet the relevant origin requirements.

However, purchasing materials from a business located in New Zealand or India does not automatically establish their originating status.

The underlying origin conditions still apply.

What Should Manufacturers Check?

Businesses relying on bilateral cumulation should review:

• Whether the materials genuinely qualify as originating.
• Whether appropriate supporting information is available.
• Whether the final goods meet the other applicable rules.
• Whether material sourcing and production records are consistent.

Bilateral cumulation provides a useful mechanism for qualifying production, but it does not remove documentary responsibilities.

De Minimis Rules for Non-Originating Materials

Rule 9 provides limited tolerance for certain materials that do not satisfy the applicable change-in-tariff-classification requirement.

This is referred to as the de minimis rule.

General 10% Provision

For goods outside HS Chapters 50-63, non-originating materials failing the applicable tariff classification change may be tolerated where their value does not exceed 10% of the finished goods' FOB value.

All other applicable requirements must still be met.

Textile and Apparel Goods

Goods under HS Chapters 50-63 have a separate provision.

The rule refers to a threshold of 10% of the total weight or value of the goods for the relevant non-originating materials.

Special 1% Provision

Rule 9 also contains a separate provision involving a 1% weight or value threshold for goods subject to the specified wholly obtained condition.

The exact requirements of that provision must be satisfied before it can be relied upon.

Does De Minimis Mean Businesses Can Ignore Origin Requirements?

No. It is a conditional tolerance mechanism.

It cannot be used to disregard every imported input or bypass other origin criteria.

Where a QVC requirement also applies, the relevant non-originating material values must be taken into account as required by the rules.

Manufacturing Activities That Do Not Establish Origin

Rule 8 identifies operations that are insufficient to confer originating status when carried out on non-originating materials.

This prevents basic handling activities from being treated as qualifying manufacture merely because they occur in an FTA country.

The listed operations include:

• Preserving goods during transportation or storage.
• Packaging goods for transport or sale.
• Simple sorting or grading.
• Simple cutting or grinding.
• Applying labels, marks or logos.
• Simple dilution without a substantial change in characteristics.
• Simple assembly operations.
• Simple polishing.
• Simple mixing.
• Certain other basic operations.

The rule also addresses combinations of the listed operations.

Why Does This Matter for Importers and Exporters?

A trader may receive goods manufactured elsewhere and undertake limited packaging or handling before shipment.

Such operations alone may not establish the origin required for preferential treatment.

Businesses should examine the actual processing carried out and whether the relevant product-specific criterion is met.

Treatment of Packaging, Spare Parts and Other Materials

Rules 10-14 explain how particular materials and accessories are treated when determining origin.

• Retail Packaging: Retail packaging classified with the finished goods is disregarded for certain origin tests.

    However, where a QVC requirement applies, the value of such packaging may need to be included in the appropriate originating or non-originating material value.

• Transport Packaging: Packing materials and containers used for transporting goods are disregarded when determining origin under Rule 11.
• Accessories and Spare Parts: Accessories, spare parts and tools presented with goods have specific treatment under Rule 12.

    The treatment depends on the origin criterion and conditions concerning how the items are supplied and invoiced.

• Indirect Materials: Rule 13 addresses indirect materials used in production.

    These may include tools, machinery-related supplies, lubricants and other materials not physically incorporated into the finished product.

• Fungible Goods: Rule 14 concerns commercially interchangeable goods or materials.

    Origin may be determined through physical separation or qualifying inventory management methods.

    Where an inventory management method is selected, the prescribed consistency and accounting conditions must be followed.

Direct Consignment and Third-Country Transportation Rules

Rule 15 addresses the movement of goods between India and New Zealand.

Direct Transportation: Goods transported directly between the exporting and importing FTA countries may satisfy the direct consignment condition.

Movement Through Third Countries: Goods can also move through one or more countries outside the FTA, subject to restrictions.

The rule permits specified operations necessary for transportation or preserving the goods.

However:

1. The goods must not undergo disqualifying production or other operations outside the FTA countries.
2. The activities carried out must fall within the permitted conditions.
3. The goods must remain under customs control in the non-party countries.

Supporting Shipping Records: Customs authorities may require evidence supporting the transportation conditions.

Relevant records can include:

• Bills of Lading.
• Airway Bills.
• Multimodal Transport Documents.
• Non-Manipulation Certificates.
• Relevant customs documents from transit countries.

The exact supporting evidence will depend on the route and the requirements of the importing customs administration.

Certificate of Origin Requirements Under the FTA

The Certificate of Origin is an important document for supporting preferential tariff treatment.

Rule 16 sets out the conditions for Proof of Origin, while Rule 17 addresses applications for Certificates of Origin.

Who Can Issue a Certificate of Origin?

A Certificate of Origin must be issued by a designated issuing body or authority under the applicable arrangements.

The notification provides for authorised signatures and official seals, including the permitted use of electronic methods.

What Information Must a Certificate Contain?

Annexure B specifies the required format and information.

Important fields include:

• Exporter's name, address and country.
• Producer's details.
• Importer or consignee details.
• Transport information, where known.
• Third-party invoicing information, where applicable.
• Six-digit HS code.
• Description of goods.
• Applicable origin criterion.
• Quantity or measurement details.
• Invoice information.
• Relevant certification details.

Validity of the Certificate: Proof of Origin is generally valid for 12 months from its issue or completion, depending on the form used.

Special provisions apply to qualifying multiple shipments in New Zealand.

Application Requirements: An exporter or producer applying for a Certificate of Origin must provide an application and suitable supporting evidence.

The issuing authority may examine whether the information establishes that the goods satisfy the relevant origin conditions.

Can a Certificate Be Issued After Importation?

Rule 16 permits retrospective issuance in exceptional circumstances, subject to the prescribed conditions and period.

The document must carry the required retrospective endorsement and explanation.

What Happens if the Certificate Is Lost?

The rule permits an application for a certified copy where the original certificate has been stolen, lost or accidentally destroyed.

The request must satisfy the prescribed conditions, and the certified copy has the same validity period as the original certificate.

Certificate of Origin vs Origin Declaration

The notification recognises Certificates of Origin and specified Origin Declarations as forms of Proof of Origin.

Their use is subject to the applicable conditions.

Indian Status Holders

Rule 20 provides for eligible exporters established in India to receive status-holder certification under the relevant framework.

An authorised status holder accepts responsibility for the origin declaration.

New Zealand Approved Exporters

Rule 21 provides for eligible exporters established in New Zealand to receive the required authorisation.

Approved exporters are assigned unique authorisation numbers.

Is Origin Self-Certification Automatically Available?

No general assumption should be made.

Rule 34 links the introduction of other forms of Proof of Origin, including Origin Declarations, to the establishment of an electronic system for verifying their authenticity.

Businesses should confirm the operational requirements before relying on an Origin Declaration for preferential tariff treatment.

How Can Indian Importers Claim Preferential Customs Duty?

Rule 22 specifies the requirements for claiming preferential tariff treatment.

An importer must establish that the goods qualify as originating and satisfy the applicable claim conditions.

Step 1: Check the Product Classification

Identify the correct HS classification.

Step 2: Review the Origin Criterion

Check whether the goods qualify under the wholly obtained rules or applicable Product-Specific Rules.

Step 3: Obtain Valid Proof of Origin

Ensure that the required origin documentation is available at the relevant stage.

Step 4: Make the Required Declaration

The importer must declare that the goods qualify as originating in accordance with the applicable procedures.

Step 5: Maintain Supporting Evidence

Customs authorities may ask for additional information concerning the origin determination or consignment conditions.

What Happens if Proof of Origin Is Missing?

Rule 22 permits customs authorities to deny preferential treatment, request a guarantee or take other action allowed under the relevant laws and procedures where proof is not produced.

Importers should therefore verify the availability and accuracy of origin documents before claiming concessional customs duty.

Documents and Record-Keeping Requirements

Rule 23 contains specific record-retention obligations. The exact documents needed to establish origin will depend on the goods and the relevant origin criterion.

Records Relevant to Importers

Importers may need to maintain:

• The applicable Proof of Origin.
• Supporting import documentation.
• Commercial invoices.
• Relevant shipping information.
• Documents supporting origin and consignment conditions.
• Information provided during customs verification.

Records Relevant to Exporters and Producers

The rules refer to records necessary to establish the originating status of goods.

Such records may include:

• Material procurement records.
• Production information.
• Commercial and customs documentation.
• Material cost information.
• Relevant labour, overhead and accounting records.
• Evidence supporting the applicable origin criterion.

How Long Must Records Be Maintained?

A longer period may apply under the relevant domestic laws and regulations.

Rule 23 also requires retention of the original Proof of Origin document in hard-copy written form, while allowing other supporting records to be maintained in permitted formats that support prompt retrieval.

Customs Origin Verification and Inspection Procedures

Customs authorities may verify whether goods genuinely satisfy the requirements for preferential tariff treatment.

Rule 26 provides the relevant procedure.

When Can Verification Begin?

Verification may take place during importation or after the goods have been released.

Authorities may initiate checks based on risk assessment, random selection or reasonable doubts concerning origin.

What Can Customs Authorities Examine?

Depending on the circumstances, authorities may request:

• Information from the importer.
• Verification of a Certificate of Origin.
• Supporting records from exporters or producers.
• Information from the competent or issuing authority.
• Evidence supporting QVC calculations.
• Relevant production and accounting records.

Verification Visits

Where the prescribed conditions are met, customs authorities may request visits to exporter or producer premises.

Such visits may involve examining production facilities and related accounts or records.

Important Verification Time Limits

These are distinct procedural periods and should not be treated as applying to every type of customs enquiry.

What Happens During Verification?

The rules provide for goods to be released during verification subject to the applicable payment of duty or provision of security.

Once verification is completed, the customs administration must communicate its determination and the reasons supporting it.

Can Importers Claim Preferential Benefits After Importation?

Rule 25 addresses post-import preferential tariff claims.

An importer who did not claim preferential treatment at the time of importation may apply for the benefit and a refund of excess customs duty where the goods qualified at the time they were imported.

The claim is subject to the applicable procedures and documentary conditions.

Relevant Conditions

The importing country may require:

1. A claim for preferential treatment within the prescribed period.
2. A copy of the applicable Proof of Origin.
3. Other relevant import documentation.

The rule refers to a period of 12 months after importation, or a longer period where specified under domestic law.

What if the Earlier Claim Was Incorrect?

Where an importer discovers that a claim relied on information affecting the accuracy or validity of the Proof of Origin, the rules address correction of the import documentation.

Applicable additional duty and penalties may also have to be paid.

Exemptions, Transitional Relief and Special Cases

The rules contain provisions for certain practical situations.

• Proof of Origin Waiver: Rule 24 provides for cases where Proof of Origin is not required because the importing party has waived the requirement or its applicable law does not require it.
• Third-Party Invoicing: Rule 18 states that preferential treatment cannot be refused solely because an invoice was issued by a third party, or in another country, provided the relevant origin requirements are satisfied.
• Goods in Transit: Rule 30 covers eligible originating goods that are already on their way when the agreement comes into force.
• Goods in Customs Warehouses: It also applies to certain qualifying goods held under customs control, including goods stored in bonded warehouses.
• Minor Errors in Documents: Rule 31 addresses minor errors or discrepancies in Proof of Origin.

Minor typographical, spelling or formatting differences should not automatically result in rejection where the conditions of the rule are met.

These special provisions do not eliminate the need to establish the actual origin of the goods.

When Can Preferential Customs Duty Benefits Be Denied?

Rule 27 permits denial of preferential tariff treatment in specified situations.

These may include:

• Goods failing to meet the origin criteria.
• Failure to satisfy applicable requirements.
• Insufficient information following verification.
• Failure to respond to information requests.
• Failure to provide documents within prescribed periods.
• Failure to cooperate with relevant verification procedures.

Where preferential treatment is denied, the importer must be informed in writing of the reasons.

If the goods are found not to comply with the origin requirements, customs duty may be imposed in accordance with applicable domestic law.

Business Risks of Unsupported Claims

Apart from legal consequences, an incorrect origin claim may create practical difficulties such as:

• Unexpected customs duty liability.
• Delays arising from verification.
• Additional documentation work.
• Disputes with suppliers over origin information.
• Changes to the expected landed cost of imported goods.

These risks are business implications and should not be confused with separate statutory penalties.

Suspension and Penalties for Incorrect Origin Claims

Rules 28 and 29 address repeated or deliberate misrepresentation and applicable sanctions.

Persistent or Intentional Misrepresentation

Rule 28 provides procedures where origin has been persistently or intentionally misrepresented.

Depending on the circumstances, the importing and exporting parties may consult about corrective measures.

Temporary suspension of preferential treatment may follow where the conditions are satisfied.

Temporary Suspension

The rule contains specific procedures for suspension decisions and their possible restoration.

Certain broader measures involve the Technical Committee on Rules of Origin and the Joint Commission.

Applicable Penalties

Rule 29 refers to civil, administrative and, where appropriate, criminal sanctions under the applicable customs laws and regulations.

It does not prescribe one fixed financial penalty for every violation.

Correction of Errors

The framework also recognises the relevance of correcting inaccurate information.

Under Rule 25, voluntary notification before discovery of the error by customs authorities may be considered as a mitigating factor, subject to the prescribed conditions.

Electronic Exchange of Origin Documents

Rule 34 provides for electronic exchange of origin information between the two countries. The rule addresses:

• Electronic exchange of Certificate of Origin information.
• Electronic systems for other forms of Proof of Origin.
• Authentication arrangements for Origin Declarations.
• The relevant implementation periods.

The electronic exchange mechanism for other forms of proof is to be established within 12 months from the agreement's entry into force.

The use of Origin Declarations is linked to the system needed to establish the authenticity of self-declarations.

Businesses should confirm the accepted proof and operational arrangements rather than assuming that every form of electronic self-certification is available immediately.

What Do Annexures A, B and C Specify?

The three annexures contain information that businesses may need when assessing product eligibility and preparing origin documentation.

Annexure A: Product-Specific Rules of Origin

Annexure A provides the relevant origin requirements against HS classifications.

It identifies the criteria applicable to different products, including wholly obtained status, tariff classification changes, QVC and specified processing conditions.

Annexure B: Certificate of Origin

Annexure B contains the Certificate of Origin template.

The form requires information about the parties, goods, origin criteria and relevant shipment details.

Annexure C: Origin Declaration

Annexure C provides the template for an Origin Declaration.

Its use is subject to the applicable authorisation and electronic verification conditions.

Impact on Indian Importers, Exporters and Manufacturers

The rules are likely to affect businesses differently depending on the products they trade and their involvement in establishing origin.

Impact on Indian Importers

Importers seeking preferential customs duty must be able to support the claim.

This may require closer coordination with overseas suppliers, particularly where production details or material-origin information is needed.

Importers may also need to examine whether their shipping route meets the consignment conditions.

Impact on Indian Exporters

Exporters supplying goods to New Zealand may need to review their manufacturing and procurement records before applying for origin certification.

Where a product uses materials sourced from outside the FTA countries, the exporter must assess whether the relevant product-specific criteria are met.

Impact on Manufacturers

Manufacturers may face more detailed documentation requirements where origin depends on tariff classification changes, or QVC calculations.

Reliable information about raw materials, production methods and costs may be necessary.

Impact on MSMEs

Smaller manufacturers and exporters may find origin classification and documentation difficult, particularly where they work with multiple suppliers.

The notification does not exempt all MSMEs from the rules merely because of their business size.

Affected MSMEs should therefore review their products and identify which information is needed to establish origin.

Impact on Import-Export Compliance Teams

Businesses may need coordination between procurement, production, accounts, logistics and compliance teams.

A customs duty claim can depend on information held by several departments rather than a single shipping document.

Benefits and Challenges for Businesses

Potential Benefits

The new rules establish a clearer framework for evaluating origin under the FTA.

Possible advantages include:

• Defined criteria for preferential tariff eligibility.
• A recognised framework for bilateral cumulation.
• Product-wise origin rules.
• Procedures for documentary verification.
• Provisions for post-import preferential tariff claims.
• Defined mechanisms for handling certain errors and special cases.

Actual duty savings depend on the relevant product, applicable tariff concession and fulfilment of all required conditions.

Main Challenges

Businesses may face difficulties involving:

• Product classification: Incorrect HS classification can lead to selection of the wrong origin criterion.
• Material-origin information: Suppliers may need to provide sufficient information about where materials originate.
• Cost calculations: QVC requires accurate records, and application of the correct valuation method.
• Document management: Businesses must retain supporting evidence for the prescribed period.
• Verification readiness: Importers, and exporters may need to respond to customs questions involving transactions completed earlier.

These challenges make it useful to review origin requirements while planning the trade transaction, rather than waiting until documentation is submitted to customs.

What Should Businesses Do Before 20 October 2026?

Affected businesses should examine their current or planned trade with New Zealand and identify the origin conditions relevant to their products.

1. Review the Goods Being Traded: Identify the products imported from or exported to New Zealand.
2. Check the HS Code: Confirm the correct tariff classification for each product.
3. Examine Annexure A: Identify the applicable origin requirement.
4. Review Raw Materials and Production: Determine whether the available records support wholly obtained status, a tariff classification change, QVC or another prescribed condition.
5. Check Proof of Origin Arrangements: Confirm the appropriate certificate, or declaration and the applicable eligibility conditions.
6. Review Shipping Documentation: Where goods travel through third countries, check whether the required consignment conditions can be established.
7. Organise Supporting Records: Maintain relevant documentation in accordance with the prescribed retention requirements.
8. Check Preferential Tariff Eligibility: Confirm the actual tariff concession separately from the product's originating status.
9. Prepare for Customs Verification: Identify who will respond to requests for origin information and ensure supporting documents can be retrieved.

These steps are recommended compliance-preparation measures. They do not represent a separate mandatory registration process under the notification.

Importer and Exporter Compliance Checklist

The checklist is intended to help businesses organise their compliance review. Actual obligations remain those prescribed under the rules and applicable customs law.

How Corpseed Can Help with India-New Zealand FTA Compliance

For businesses trading between India and New Zealand, determining origin can involve more than checking a Certificate of Origin. Depending on the product, companies may need to assess material sourcing, customs classification, valuation records and the documents supporting a preferential tariff claim.

Corpseed's import compliance services and related regulatory assistance can help businesses review their applicable requirements and identify documentation gaps.

• Import Compliance Services

Corpseed assists businesses in understanding applicable import regulations, and documentation requirements.

This may include reviewing product-related regulatory requirements and helping importers organise records needed for compliance assessment.

• Export Compliance Consulting

Exporters can seek assistance in understanding relevant trade documentation requirements and identifying compliance issues connected with their products.

• Certificate of Origin Assistance

Corpseed can support businesses with understanding the relevant origin certification requirements, and the supporting information needed for applications or document review.

Certificates must still be issued by the designated competent issuing authority.

• Customs Compliance Services

Customs-related compliance support may include reviewing applicable documentation, identifying origin-related issues and preparing businesses for relevant procedural requirements.

• DGFT Consultancy Services

Where separate DGFT licences, registrations or trade authorisations are relevant to a transaction, businesses may seek assistance with those requirements.

Such authorisations should not be confused with the FTA's origin determination rules.

• Import-Export Documentation Services

Businesses may require assistance in organising commercial, product, shipment and origin-related records.

Accurate documentation can make compliance reviews easier and reduce the risk of discrepancies between information supplied by different parties.

Need assistance with import or export compliance?

Businesses trading with New Zealand can contact Corpseed for relevant import compliance services, export compliance consulting and assistance with understanding the documentation requirements applicable to their products.

Key Takeaways

CBIC Notification No. 82/2026-Customs (N.T.) establishes the Rules of Origin for goods traded under the India-New Zealand FTA, with commencement scheduled for 20, October 2026.

The rules explain how goods qualify as originating, the role of product-specific criteria, how Certificates of Origin and permitted declarations work, and how customs authorities may verify preferential tariff claims.

For Indian importers, exporters and manufacturers, the main task is to establish eligibility using the correct HS classification, origin conditions and supporting records.

A preferential customs duty claim should be made only when the goods qualify under the applicable origin rules and the relevant tariff concession is available.