Form D ASEAN Certificate of Origin: Criteria, Boxes, and Filing

To fill out the ASEAN Form D certificate of origin, first identify which origin criterion your goods meet, then complete the thirteen boxes so every detail matches your commercial invoice and shipping documents, and submit the form with supporting evidence to the issuing authority in your ASEAN country of export. Once endorsed, the certificate gives your buyer preferential tariff treatment under the ASEAN Trade in Goods Agreement (ATIGA), and it stays valid for twelve months from the date of issuance.¹

Step 1: Identify the Origin Criterion

Before you touch the form, work out how your product qualifies as originating. That answer goes into Box 8 and dictates which supporting documents you’ll need to gather.

Wholly Obtained (WO)

If the product is produced entirely within a single ASEAN member state with no foreign inputs, it qualifies as Wholly Obtained. This covers agricultural products grown domestically, minerals extracted from local soil, fish caught in territorial waters, and goods manufactured exclusively from such materials.² Enter “WO” in Box 8.

Regional Value Content (RVC)

If the product contains imported inputs, one route to qualification is showing that at least 40% of its FOB value comes from ASEAN sources. Subtract the value of non-originating materials from the FOB price, divide by the FOB price, and multiply by 100. If the result is 40% or more, the goods qualify.³ In Box 8, enter the actual percentage, for example “45%”.

Change in Tariff Classification (CTH or CTSH)

Alternatively, all non-originating materials must have undergone a shift in tariff heading at the four-digit level of the Harmonized System during manufacturing, so that the imported inputs sit under a different HS heading than the finished product.⁴ The Box 8 code is “CTH” (or “CTSH” for a six-digit subheading shift, where required).

Product Specific Rules (PSR)

Some product categories, particularly textiles, photographic equipment, and automotive parts, are governed by tailored rules in ATIGA Annex 3. These may require a different RVC threshold, a subheading-level tariff shift, or a specific manufacturing process. Check whether your HS code appears in Annex 3 before defaulting to the general 40% RVC or CTH test.⁵

De Minimis and Cumulation

If your product fails the CTC test because some non-originating materials stay within the same tariff heading, it can still qualify so long as the value of those materials does not exceed 10% of the product’s FOB price.⁶

Originating materials from any ASEAN member state can also count toward the criteria in the country of final assembly. Under full cumulation, materials that already qualify as originating in another ASEAN state are treated as domestic content. Partial cumulation applies where the good has an RVC of at least 20% from the contributing ASEAN state but falls short of the 40% threshold; in that case, mark the Form D “Partial Cumulation” and enter “PC” followed by the percentage in Box 8, for example “PC 25%”.⁷

Step 2: Complete the Thirteen Boxes

The Form D has thirteen boxes, and any inconsistency between them and your shipping paperwork can delay clearance or void the preferential rate. Here is what each box requires.⁸

Box 1, Exporter: your business name, full address, and country. This must match the entity applying for the certificate.
Box 2, Consignee: the buyer’s or importer’s name, address, and country in the destination ASEAN state.
Box 3, Transport details: means of transport and route so far as known, including departure date, vessel or aircraft name, and port of discharge.
Box 4, For official use: leave blank. The importing country’s customs authority uses this box to indicate whether preferential treatment is granted.
Box 5, Item number: sequential numbering for each line item in the shipment.
Box 6, Marks and numbers: the shipping marks and container or package numbers as they appear on the cargo.
Box 7, Description of goods: the number and type of packages, a clear product description, quantity, and the HS code of the importing country using the ASEAN Harmonised Tariff Nomenclature. If a third-country company issues the commercial invoice, tick the Third Country Invoicing checkbox and write the invoicing company’s name and country in this box.⁹
Box 8, Origin criterion: the code that matches how the goods qualify. Use “WO” for wholly obtained, a percentage such as “40%” for RVC, “CTH” or “CTSH” for a tariff classification change, “SP” for a specific process, or a combination such as “CTSH + 35%”. For partial cumulation, enter “PC” followed by the percentage.
Box 9, Gross weight and FOB value: gross weight or other quantity. You must include the FOB value when the RVC criterion applies. Cambodia, Indonesia, and Lao PDR require the FOB value regardless of which criterion is used.⁹
Box 10, Invoice number and date: these must match your commercial invoice exactly. Mismatches with the shipping documents are one of the fastest ways to get a Form D rejected.
Box 11, Exporter’s declaration: an authorized signatory of the exporter, manufacturer, or producer signs and dates, declaring that the goods meet the origin requirements.
Box 12, Certification: the issuing authority stamps, signs, and dates the certificate. You do not fill this in.
Box 13, Checkboxes: tick the applicable boxes. Third Country Invoicing if a non-ASEAN company issued the invoice, Exhibition if the goods were sent for display abroad before sale, or Accumulation if cumulation rules apply.

Step 3: Assemble Supporting Documents

The issuing authority will not endorse the Form D on the form alone. Submit a written application along with documentation proving the goods meet the origin criterion you declared.

Commercial invoice matching the details in Box 10. Every number, date, and product description should line up across the Form D and invoice.
Bill of lading or airway bill, confirming the transport route and supporting the direct consignment requirement.
Cost breakdown, if you are claiming RVC. This is a detailed statement of the FOB price, the value of non-originating materials, labor, and overhead, used to verify the 40% threshold.
Manufacturing records, if you are claiming CTC or a product-specific rule. Production logs, raw material sourcing records, and HS classification documentation showing that foreign inputs were transformed into a product under a different tariff heading.
Supplier declarations, if you are relying on cumulation. Documentation from suppliers proving the originating status of materials sourced from other ASEAN states.

Fees vary by member state. Confirm the schedule with your country’s trade ministry or chamber of commerce before filing.

Step 4: Submit the Application

Applications go to the government authorities of the exporting member state, and the certificate should be issued at the time of exportation or shortly afterward.¹⁰ In practice, prepare the application and supporting documents before the shipment date so that the endorsed Form D is ready when the goods arrive at the destination port.

Most member states now process Form D applications through their National Single Window, a digital portal that connects exporters with the relevant government agencies. Malaysia’s system runs through the NSW-ePCO platform, and Singapore routes applications through TradeNet.¹¹ Digital submission reduces paperwork errors and speeds up processing compared with manual filing.

The ASEAN Single Window connects the National Single Windows of all member states and allows the electronic exchange of endorsed Form D certificates directly between customs authorities. As of mid-2025, all ten member states participate in the live exchange of the ATIGA e-Form D.¹² When an e-Form D moves through the ASW, the importing country’s customs can verify its authenticity electronically, which speeds cargo clearance and removes the risk of a paper certificate going missing in transit.¹³

Situations That Change How You File

Retroactive Issuance

If the Form D was not issued at the time of export because of accidental errors, omissions, or other valid reasons, it can be issued retroactively up to one year from the shipment date. The certificate must be clearly marked “ISSUED RETROACTIVELY”.¹⁴ Treat this as a fallback rather than a planning strategy; customs authorities in the importing country may scrutinize retroactive certificates more closely.

Back-to-Back Certificates

When originating goods are exported to an intermediate ASEAN state and then re-exported to a final destination in another ASEAN state, the intermediate country’s customs authority can issue a back-to-back Form D. The conditions are strict:¹⁵

The original Form D must still be valid.
The goods cannot undergo any further processing in the intermediate state beyond repacking, storing, or logistics operations needed to keep them in good condition.
The back-to-back Form D must contain the same origin information as the original.
The total quantity re-exported cannot exceed the quantity on the original certificate.
The intermediate country’s customs authority retains the original Form D for at least three years.

Third-Country Invoicing

If the commercial invoice is issued by a company located outside ASEAN, a common arrangement when a trading intermediary in a non-member country brokers the sale, tick the Third Country Invoicing checkbox in Box 13 and write the invoicing company’s name and country in Box 7.⁹ Forgetting to tick this box when the invoice comes from a non-ASEAN entity is a common mistake that leads to rejection at the destination port.

The Direct Consignment Boundary

Preferential tariff treatment applies only to goods shipped directly between the exporting and importing member states. If your cargo passes through a third country, ASEAN or otherwise, it still counts as directly consigned so long as the transit is justified by geography or transport logistics, the goods do not enter trade or consumption in the transit country, and they undergo no processing beyond unloading, reloading, or preservation.⁴ Breaking this rule, even accidentally by holding goods in a bonded warehouse longer than necessary without proper documentation, can void the Form D’s preferential treatment.

An Alternative to Filing Per Shipment

If you ship frequently across ASEAN, the ASEAN-Wide Self-Certification scheme lets an approved Certified Exporter make an origin declaration directly on the commercial invoice or other trade document, in place of applying for a Form D each time.¹ All ten member states participate. If that fits your operation, apply to your country’s competent authority for authorization; otherwise the Form D process above is what you follow.

After Submission: Records and Verification

Exporters using the Form D must retain all supporting documents, including cost breakdowns, invoices, bills of lading, supplier declarations, and manufacturing records. The minimum retention period under ATIGA is three years, and individual member states may require longer periods under their own customs laws. Keep the records accessible and organized; an audit years after the original shipment is not unusual.

Customs authorities in the importing country can launch retroactive verification at any time within the retention period, from written inquiries requesting additional documentation to physical verification visits at your production facilities.¹⁵ If you cannot produce the records to support your origin claim, customs can deny preferential treatment retroactively, meaning your buyer is hit with the full most-favored-nation duty rate on those shipments, plus potential penalties.

The strongest defense against verification problems is consistency. Make sure the HS codes, values, origin criteria, and product descriptions on your Form D match your invoices, packing lists, and manufacturing records exactly. Discrepancies between documents, even minor ones, are the most common trigger for deeper audits.

1
ASEAN. ASEAN-wide Self-Certification Guidebook
2
Center for WTO and International Trade. Rules of Origin in the ASEAN Trade in Goods Agreement
3
Ministry of Investment, Trade and Industry (MITI). Rules of Origin
4
ASEAN. ASEAN Trade in Goods Agreement
5
ASEAN. Annex 3 – Product Specific Rules (HS 2017)
6
UNCTAD. Handbook on ATIGA Rules of Origin
7
ASEAN. Appendix B – Partial Cumulation
8
ASEAN. Annex 7 CO Form D Revised – Box 9 and Overleaf Notes
9
ASEAN. Annex 7 Amended CO Form D and Overleaf Notes
10
Bureau of Customs (Philippines). Updates on the Implementation Arrangements of ATIGA Rules of Origin
11
Ministry of Investment, Trade and Industry (MITI). ASEAN Single Window Frequently Asked Questions
12
ASEAN. ASEAN Single Window
13
Singapore Customs. Electronic Exchange of Form D via the ASEAN Single Window
14
ASEAN. Annex 8 Operational Certification Procedure – Amended
15
Enterprise Singapore. Annex 8 Operational Certification Procedure