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Why Your Certificate of Origin Got Rejected: 3 Common Errors

Seungho ImFebruary 18, 20266 min read

Your product is made in Korea. You have the factory records, the supplier confirmation, everything. But customs rejected your Certificate of Origin anyway.

This happens more often than most exporters expect. And the reason is almost never about where the product was made. It is about how the document was filled out. This guide covers the three most common errors that cause C/O rejections and how to prevent them before you ship.

Why do Certificates of Origin get rejected?

A Certificate of Origin gets rejected when customs finds inconsistencies, missing information, or incorrect declarations on the document itself. According to trade compliance experts at Prodensa, most origin-related penalties stem not from fraud but from avoidable technical errors such as incorrect descriptions, missing data, or wrong HS codes.

The product may genuinely originate in the declared country. But if the paperwork does not prove it correctly under the applicable trade agreement's rules, customs will deny preferential treatment. The importer then pays the full most-favored-nation (MFN) duty rate instead of the reduced FTA rate.

According to a joint report by UNCTAD and Sweden's Kammerskollegium, EU exporters lost approximately €72 billion between 2009 and 2013 simply because they did not use negotiated preferential tariffs. A significant portion of that loss traces back to documentation issues, including C/O errors and failure to file for preferences at all.

What is the most common reason for C/O rejection?

The single most common cause is an HS code mismatch between the Certificate of Origin and other shipping documents. When the HS code on your C/O does not match the code on your commercial invoice or packing list, customs treats it as a discrepancy.

Here is how it happens:

  • Your C/O lists the product under HS 8516.79

  • Your commercial invoice lists it under HS 8516.80

  • Customs sees two different product classifications

Even if both codes refer to similar products, the mismatch is enough to trigger a review or outright denial. According to Cargoflip's export documentation guide, HS code errors are among the most frequent causes of C/O rejection across all trade lanes.

This matters because many FTA rules of origin are tied directly to HS classification. Under USMCA, for example, the product-specific rule of origin is determined by the good's tariff classification. If the HS code on your C/O does not match the code used in the origin analysis, the entire claim falls apart.

What does "origin criteria" mean, and why does selecting the wrong one cause rejection?

Origin criteria is the field on a preferential C/O where you declare how the product qualifies as originating. Most FTAs require you to select one of several methods:

  • Wholly obtained (A): The product was entirely grown, harvested, or extracted in the FTA territory. Common for agricultural goods and raw materials.

  • Tariff shift (B): Non-originating materials were transformed enough to change their HS classification. The final product falls under a different tariff heading than its imported inputs.

  • Regional Value Content (C): A minimum percentage of the product's value was added within the FTA territory, typically calculated using the transaction value or net cost method.

  • Produced entirely from originating materials (D): All inputs already qualify as originating under the agreement.

Selecting the wrong criterion does not just look like carelessness. It tells customs that the certifier may not understand how the product actually qualifies. According to CBP's USMCA implementing regulations under 19 CFR Part 182, a claim can be denied if the certification is based on inaccurate information and not corrected within the required time period.

For example, you mark "A" (wholly obtained) for a manufactured electronic component that uses imported parts. Customs knows an electronic component is not wholly obtained. The certificate is rejected, even though the product might qualify under criterion B or C.

How do document inconsistencies trigger C/O rejection?

Customs authorities cross-check your C/O against your commercial invoice, packing list, and bill of lading. Any inconsistency in product descriptions, quantities, or weights raises a red flag.

Common examples:

  • C/O says "electric heater" while the invoice says "portable heating unit"

  • C/O lists 500 units but the packing list shows 520 units

  • Consignee name on the C/O does not match the importer on the entry filing

According to trade documentation specialists at IncoDocs, unclear or vague product descriptions and missing details like date, quantity, or shipment information are leading causes of clearance delays. Banks processing Letters of Credit are equally strict. A mismatch between the C/O and commercial invoice can cause payment delays or outright rejection under documentary credit terms.

The fix is straightforward but requires discipline. Every document in the shipment set should use identical wording for product descriptions, and all quantities, weights, and party names should be verified for consistency before submission.

What happens after your C/O is rejected?

When customs rejects a C/O, the immediate consequence is the loss of preferential tariff treatment. Your buyer pays the full MFN duty rate. On a $50,000 shipment, the difference between an FTA rate of 0% and an MFN rate of 6–14% can mean $3,000 to $7,000 in additional duties.

But that is just the first shipment. If the rejection reveals a pattern of errors, the consequences escalate:

  • Retroactive duties: Under USMCA, CBP can audit import entries going back up to five years. If they find consistent misclassification or incorrect origin claims, the importer owes back duties on all affected entries.

  • Penalties: Under 19 U.S.C. § 1592, penalties for negligence can reach two times the unpaid duties. Gross negligence raises that to four times. Fraud cases can reach the full domestic value of the merchandise.

  • Heightened scrutiny: Companies flagged for origin violations face more frequent inspections and longer processing times on future shipments.

There is a path to resolution, however. According to Prodensa's analysis of USMCA compliance, approximately 40% of initial non-compliance notices are resolved favorably when companies provide additional documentation that was not included in the original filing. The key is responding quickly and thoroughly.

How to prevent C/O rejection: a checklist

Most C/O rejections are preventable with a consistent review process before submission. Use this checklist for every shipment:

  • HS code consistency: Verify the HS code is identical on the C/O, commercial invoice, packing list, and any other customs filings. If your country uses 10-digit codes, confirm the 6-digit level matches across all documents.

  • Origin criteria accuracy: Confirm which criterion (wholly obtained, tariff shift, regional value content, or produced from originating materials) applies to your product. If unsure, consult the product-specific rules of origin for the applicable FTA.

  • Product description match: Use the exact same wording for product descriptions across all documents. Do not paraphrase or abbreviate on one document if the full description appears on another.

  • Party information: Ensure exporter, importer, and producer names and addresses are consistent and complete. Under USMCA, the certification must include nine specific data elements including certifier identification, exporter details, and HS classification to the six-digit level.

  • Signature and date: An unsigned or undated C/O is an automatic rejection in most jurisdictions. Electronic signatures are accepted under USMCA, but the certification must still be properly executed.

  • Record retention: Keep all C/O-related records for at least five years. This includes the certificate itself, supporting invoices, production records, and any correspondence with the issuing authority.

A rejected C/O does not mean the product failed to qualify. It means the documentation did not prove it. Check the paperwork before customs does.

Seungho Im

Written by

Seungho Im

Founder of ovrseas, Korean Sourcing Agent

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