Last reviewed 15 October 2021

We reported recently that HM Revenue and Customs (HMRC) had produced a series of guides relating to originating status of goods and preferential tariff treatment under the UK-EU Trade and Cooperation Agreement (TCA) (see HMRC sets out rules for moving goods between UK and EU).

Available at, this collection includes a guide to the process of cumulation which is described as an important part of modern free trade agreements (FTAs).

It provides a system that allows originating products from one party to be treated as if they are originating in another when deciding if a goods are able to meet a product-specific rule.

For example, this means products or materials originating in the EU can be considered as originating in the UK if those products are further processed in the UK or incorporated into another product before re-exporting to the EU.

All operations carried out in the UK or EU are taken into account when deciding if a good is able to meet a product-specific rule.

Full bilateral cumulation applies to both:

  • specific production processes (for example “combing” or “making up” in the manufacture of textiles products)

  • the value associated with such processing (for example in product-specific rules with value-add requirements).

Where an exported good has got its originating status through the application of full bilateral cumulation (for example where a UK exporter has met a product-specific rule through counting production carried on non-originating materials in the EU), the exporter of those goods must get a “supplier’s declaration” from the supplier of the non-originating materials.

The guide includes three applied examples of cumulation of originating materials (chopped tomatoes, cotton men’s shirts and diesel engines).