Information Session on Rules of Origin

Wout van Duijn Global Trade Compliance and Customs Specialist EMEA

Ashland

Agenda WTO Geneva

Introduction Ashland

How we determine non-preferential origin

Interpretation

Requirements Authorities

Costs

Simplify business activities

Introduction Ashland

Ashland is one of the world’s leading specialty chemical companies

We have more than 10,000 employees serving customers in more than 100 countries.

www.ashland.com

Ashland Specialty Ingredients

Pharmaceutical Skin Care Paint & Coatings Energy Specialties

• Tablets

• Capsules

• Wound Care

• Skin lotions

• Anti-aging products

• Body washes

• Suncare

• Water based

architectural paints

• Drilling

• Cementing

• Stimulation

• Productions

• Civil engineering

• Inks and printing

• Ceramics

• Agriculture

Nutritional Hair Care Emulsion Polymerization Construction Industrials

• Food - texturant

• Custom food blends

• Beverage clarification

and stabilization

• Shampoos

• Conditioners

• Mousses/gels

• Hairspray

• Paints

• Adhesives

• Dry Mortar

• Gypsum

• Joint compound

• Intermediates

Oral Care All Other

• Toothpaste

• Mouthwash

• Denture adhesives

• Specialty solvents

Personal Care Pharma/Nutrition Coatings Industrial Performance

Ashland Performance Materials

Composites

Lightweight High Strength

Durability Corrosion Resistance

Adhesives

Strength Durability

Removability Food Safety

Elastomers

Pressure Sensitive

Wear Resistance

Durability

Adhesion

Global Trade Compliance at Ashland

Protect the Brand: Minimize Trade Compliance Exposure

· Reliable to the Company: Recognized expert in Global Trade Compliance and Customs

· Reliable to Customers : enable Ashland to be the Supplier of Choice

· Reliable to Government Agencies and Suppliers : enable Ashland to be a Trusted Trader

Facilitate International Trade

· Minimize number of holds or disruption in our Supply Chain

· Correct Trade Classifications

· Licenses and Compliance Controls

· Effective and Compliant Trade Practices : GT Partner Management, Compliance Manuals, Transfer Pricing

· Increase Awareness of Trade Compliance to support Key Business Initiatives

Deliver Financial Savings

· Stay abreast of Trade and Customs Regulations to identify Cost Savings Opportunities

· Cost Avoidance: Fines, Penalties, Preferential Trade

· Cost Recovery: Duty Drawback and Recovery, Processing Trade

· Efficiency gains in International Trade Operations

How we determine non-preferential origin

The finished products • Tariff classification

• The composition of the goods

• Process of production

• Raw material origin (LTSD)

Substantial change

• Rules on change of tariff heading - tariff shift

• Relabelling, repackaging or simple blending is not enough

Interpretation

Interpretation of the legislation for article 60 UCC and article 32 and 34 Delegated Regulation.

• Multiple interpretation

• Minimal operations

• Chemical reaction

• Economically justified

• Mixtures

• Challenge and opportunity

Example

• A-B-C mixing and grinding

• No chemical reaction

• Minimal operation

Material D

Material C

Material A

Material B

Requirements Authorities

Long Term Suppliers Declaration for materials with non-preferential origin not accepted in every memberstate.

• Lack of knowledge by suppliers

• Different treatment by authorities in member states

• No standard process

Costs

IT Systems • Ashland uses a SAP system which mentions origin and HS code

Time • Gathering and monitoring origin and H.S. Code is time consuming

Procedures • Authorities in member states have different procedures

Certificates • Legal certificate fees

Simplify business activities

Clear set of rules and specified by Industry • Chemical business is complex

Certification of the Exporter • Combination with AEO and AES

Digital Certificates, no hard copies • e-AWB or e-CMR

Mention only EU-origin • Not always accepted in country of destination