---
title: "Which institution in which country or region shall issue the Certificate of Origin under transshipment trade?"
description: "Many foreign trade enterprises often encounter port detention，cargo seizure，compliance penalties and even order losses when carrying out transshipment trade，due to confusion over the issuing entity of the Certificate of Origin. In fact，the Certificate of Origin for transshipment trade shall be issued by the official authority or authorized third party of the corresponding country or region，based on the actual country of origin of the goods，policies of the transit country and trade compliance req..."
url: "https://www.sh-zhongshen.com/en/qa/transshipment-trade-origin-cert-issuer-country-region.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-10-24"
dateModified: "2026-10-24"
brand: "Zhongshen Trading China"
answerCount: 10
---

# Which institution in which country or region shall issue the Certificate of Origin under transshipment trade?

## Question

 I am the person in charge of a foreign trade enterprise in Shanghai focusing on solid wood furniture export. We received a large order from the EU last month, but have to transship the goods via Malaysia to avoid the excessively high anti-dumping duty rate imposed by the EU on Chinese solid wood furniture. I heard from peers before that some enterprises had their goods detained at EU ports for 12 days due to wrong issuing entity of the Certificate of Origin, they not only paid demurrage fees but also lost follow-up orders, which makes me very worried now. We have contacted a freight forwarder in Malaysia, but they alternately say it shall be issued by China or by Malaysia, and some friends say we can turn to a third-party institution. I am totally confused about where it should be issued, and I am afraid of making mistakes that will lead to the loss of the order. Can you explain it clearly to me? 

## Answers
                            
### Answer 1 — Best Answer

First，you need to complete the preliminary document review details，check three types of core documents one by one: proof documents of the actual country of origin of the goods，storage agreement of the transit country，and customs clearance requirements of the final buyer，with focus on confirming whether the goods have undergone substantial processing in the transit country (such as replacement of core components，change of commodity classification code)，which is the core basis for determining the issuing entity.

For core node connection，if the goods only go through non-substantial operations such as storage and sub-packaging in the transit country，the Certificate of Origin must be issued by the **official authority or authorized third party of the actual country of origin of the goods**，if the policy of the transit country requires the goods to go through simple processing conforming to local rules，it shall be issued by the chamber of commerce or customs authority of the transit country. You shall confirm the latest local origin rules with the transit country agent in advance to avoid node connection errors.

In terms of abnormality contingency plans，if you encounter temporary changes in the policy of the transit country，you shall immediately launch the **emergency process for document replacement and supplementation**，issue an explanation to the final buyer simultaneously，and contact the authority of the country of origin to issue the "Certificate of No Substantial Processing" as an auxiliary document to avoid port detention and cargo seizure. If you entrust a foreign trade agent to operate，you shall clarify the compliance responsibility for the issuing entity of the Certificate of Origin in the agency agreement.

At the final compliance implementation stage，you shall form a complete logical chain with documents including the Certificate of Origin，transit country bill of lading，and storage certificate，to ensure that all document information is consistent. Before submitting to the final buyer for customs clearance，you shall entrust a professional institution to conduct **compliance pre-audit**，and send the documents only after confirming there is no logical loophole，to ensure full-chain compliance.

**status:** accepted
**Author:** Kevin Lin
**Date:** 2026-10-25

### Answer 2

The issuing entity of the Certificate of Origin for transshipment trade directly affects customs valuation and customs clearance logic. If the issuing entity is inconsistent with the actual flow of goods, the customs will launch the price inquiry procedure, require the enterprise to supplement supporting documents such as transit country storage records and cargo transportation tracks, and even transfer the goods to the anti-smuggling department for investigation.

Enterprises shall ensure that the issuing entity of the Certificate of Origin is completely consistent with the "country of origin" field on the customs declaration form, and prepare the certificate of no substantial processing from the transit country in advance as an auxiliary document for customs declaration, to avoid declaration cancellation and re-submission or valuation disputes caused by inconsistent document logic. If a valuation dispute has occurred, the enterprise shall immediately submit a complete cargo circulation document chain to the customs, including the procurement contract, transit storage agreement, transportation bill of lading, etc., to prove that the goods have not obtained substantial value addition in the transit country, so as to promote the smooth completion of the valuation process.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-25

### Answer 3

The issuing entity of the Certificate of Origin for transshipment trade shall match the cargo ownership transfer nodes of the logistics path. If the Certificate of Origin is issued by the transit country, it shall be ensured that the storage and operation processes of the goods in the transit country meet local logistics supervision requirements, and the transit freight forwarder has completed the import declaration and export declaration procedures for the goods, to avoid invalidation of the Certificate of Origin caused by missing logistics nodes.

If the Certificate of Origin is issued by the country of origin, it shall be specified in the logistics entrustment agreement that the freight forwarder shall retain full monitoring records of the goods in the transit country, including seal number, storage photos, transportation track, etc., as proof that the goods have not been substantially processed. In case of logistics abnormalities such as cargo rollover or space shortage, you shall apply to the issuing institution of the Certificate of Origin for delayed issuance or supplementary annotation simultaneously, to ensure that the documents are consistent with the logistics progress, and avoid cargo ownership risks caused by delayed documents.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-10-25

### Answer 4

The issuing entity of the Certificate of Origin for transshipment trade directly affects the compliance of the cross-border tax structure. If you mistakenly choose the transit country to issue the Certificate of Origin, the enterprise may be deemed to have generated taxable income in the transit country, and need to pay corporate income tax or VAT in the transit country, increasing cross-border tax costs.

If the Certificate of Origin is issued by the country of origin, the enterprise can enjoy the export tax rebate policy of the country of origin, and at the same time shall ensure that the storage and operation fees in the transit country comply with the arm's length principle, to avoid transfer pricing investigation by the tax authority caused by unreasonable related party transaction pricing. Enterprises shall calculate the difference in tax costs under different issuing entities in advance, including the amount of export tax rebate, tax burden in the transit country, customs clearance fees of the final buyer, etc., and select the optimal issuing entity to minimize tax costs.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-10-25

### Answer 5

The issuing entity of the Certificate of Origin for transshipment trade shall meet the compliance requirements of the foreign exchange receipt and payment path. If the Certificate of Origin is issued by the country of origin, the enterprise shall submit the export declaration form of the country of origin, Certificate of Origin, transit country bill of lading and other documents to the bank when receiving and paying foreign exchange, to ensure that the capital flow is consistent with the cargo flow and document flow, and avoid the bank refusing to handle foreign exchange settlement or purchase procedures due to inconsistent document logic.

If the Certificate of Origin is issued by the transit country, it shall be ensured that the agent of the transit country has completed the local foreign exchange filing procedures, and the amount of foreign exchange received and paid is consistent with the invoice amount of the transit country, to avoid funds being detained in the transit country due to foreign exchange control. Enterprises shall communicate with the bank in advance about the document requirements for foreign exchange receipt and payment, to ensure that the issuing entity of the Certificate of Origin meets the compliance audit standards of the bank, and avoid blocked capital circulation.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-25

### Answer 6

The issuing entity of the Certificate of Origin for transshipment trade shall comply with the provisions of the international trade contract. If the contract clearly requires the Certificate of Origin to be issued by the country of origin, but the enterprise mistakenly chooses the transit country to issue it, it will constitute a breach of contract and face the risk of claim from the final buyer.

Enterprises shall specify clauses such as the issuing entity, issuing time and document requirements of the Certificate of Origin in the trade contract, and add a force majeure clause to agree on the division of responsibilities when policy changes of the transit country lead to the change of the issuing entity. If a contract dispute caused by the wrong issuing entity of the Certificate of Origin has occurred, the enterprise shall immediately collect all relevant documents, including contracts, transit country policy documents, logistics records, etc., and resolve the dispute through negotiation or arbitration, to avoid damage to the enterprise's reputation due to breach of contract.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-25

### Answer 7

The issuing entity of the Certificate of Origin for transshipment trade directly affects the results of on-site customs inspection. If the Certificate of Origin is issued by the transit country, the customs will focus on checking whether the goods have processing traces of the transit country during on-site inspection, including packaging marks, component numbers, processing records, etc. If it is found that the goods have not undergone substantial processing, the Certificate of Origin will be directly deemed invalid, resulting in cargo seizure.

If the Certificate of Origin is issued by the country of origin, the customs will check whether the country of origin mark of the goods is consistent with the information on the Certificate of Origin during on-site inspection. If there is any inconsistency, the enterprise will be required to supplement supporting documents of the country of origin. Enterprises shall prepare inspection auxiliary documents corresponding to the issuing entity of the Certificate of Origin in advance, such as processing records, packaging mark samples, etc., to ensure the smooth passage of on-site inspection.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-10-25

### Answer 8

The issuing entity of the Certificate of Origin for transshipment trade shall match the marking requirements of the goods packaging. If the Certificate of Origin is issued by the country of origin, the country of origin mark shall be marked on the goods packaging, and the content of the mark shall be completely consistent with the country of origin information on the Certificate of Origin, to avoid invalidation of the Certificate of Origin caused by inconsistent packaging marks.

If the Certificate of Origin is issued by the transit country, the country of origin mark of the transit country shall be marked on the goods packaging, and at the same time, it shall be ensured that the packaging materials meet the packaging compliance requirements of the transit country and the final importing country, such as environmental protection standards, dangerous goods packaging requirements, etc. Enterprises shall confirm the production requirements of packaging marks with the packaging supplier in advance, to ensure that the packaging marks are consistent with the issuing entity of the Certificate of Origin, and avoid port detention or cargo seizure caused by packaging problems.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-24

### Answer 9

The issuing entity of the Certificate of Origin for transshipment trade directly affects the compliance of export tax rebates. If the Certificate of Origin is issued by the country of origin, the enterprise can apply for export tax rebates normally, but shall ensure that the storage and operation fees in the transit country are not included in the cost of export goods, to avoid tax correspondence audit caused by wrong cost accounting.

If the Certificate of Origin is issued by the transit country, the enterprise will not be able to enjoy the export tax rebate policy of the country of origin, and shall include the processing and operation fees of the transit country into the cost of goods, and at the same time shall ensure that the invoices of the transit country meet the audit requirements of the tax authority, to avoid tax risks caused by non-compliant invoices. Enterprises shall review the consistency between the issuing entity of the Certificate of Origin and the tax rebate documents in advance before applying for export tax rebates, to ensure the smooth completion of the tax rebate process, and avoid tax rebate failure or tax correspondence audit caused by inconsistent documents.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-24

### Answer 10

The issuing entity of the Certificate of Origin for transshipment trade shall match the overall planning of the supply chain structure. If the enterprise is engaged in transshipment trade for a long time, it shall determine the fixed issuing entity of the Certificate of Origin according to the policies, logistics costs, tax costs and other factors of the main transit countries, and build a stable supply chain structure.

If you choose the country of origin to issue the Certificate of Origin, you shall optimize the production, storage and logistics nodes of the country of origin, to ensure that the goods can be quickly transported to the transit country and reduce the transit time; if you choose the transit country to issue the Certificate of Origin, you shall establish a stable processing and storage cooperation relationship in the transit country, to ensure that the goods can meet the local origin rules. Enterprises shall regularly evaluate the compliance and cost-effectiveness of the supply chain structure, adjust the issuing entity of the Certificate of Origin according to market changes, and realize the optimization and upgrading of the supply chain.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-24

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