Revocation of a Certificate of Origin – Supplyer’s declaration of a Packer required?

Financial Court Düsseldorf, judgement of 2 September 2015 – 4 K 1491/15 Z.


The packer of goods is not required to issue a supplyer’s declaration. If such declaration is missing, the customs authorities must not revoke a certificate of origin which has been issued before solely on that grounds.

Author’s note

The decision deals with the preference agreement between the EU and Switzerland. Since packing goods is not substantial working or processing,packing cannot constitute an origin of goods. Thus, there is no need for a supplyer’s declaration issued by a company solely packing the goods which have been produced elsewhere in the EU.