Made in EU Threshold Position Analysis
Made in EU / Origin — In-Depth Analysis and Threshold Position
We resolve your origin position at the level of the applicable list rule and model, in three scenarios, which side of the proposed Made in EU thresholds you fall on.
Promise
We resolve your origin position at list-rule level, model your position against the draft Made in EU thresholds in three scenarios, and where required prepare your binding information application.
What is it?
The preliminary assessment is a finding; the in-depth analysis is work prepared for binding effect. Where a list rule specific to the product's tariff heading exists, that rule governs; where it does not, the "last substantial, economically justified processing or working" test applies.
List rules come in three forms: change of tariff heading, value threshold, and specified operation. Finding which one applies and reading the production flow against it is the technical core of this service.
Why is it necessary?
The Industrial Accelerator Act is still at Commission proposal stage and the text will change. What is sold here is therefore not compliance but position knowledge: knowing today which side of the threshold your product would fall on.
Knowledge buys time for decisions. A change of supplier takes three to nine months; moving a process step takes six to eighteen. Acting once the threshold is settled is acting too late.
What do we promise?
- We reproduce the applicable list rule in full in the report and justify our reading of it — we do not summarise it
- We calculate the value test on customs value, in two scenarios
- We carry out the economic justification test in writing
- We give a three-scenario position model against the Made in EU threshold: as things stand, at the margin, and as targeted
- We establish a monitoring protocol so the position is updated as the legislative process moves
Who is it for?
Companies where the preliminary assessment left uncertainty; the aluminium, concrete and mortar value chains; automotive and energy-intensive industry.
How do we work?
- 1Verification of the tariff heading
- 2Identifying the list rule and analysing its full text
- 3Building the value-added calculation
- 4Last substantial operation and economic justification tests
- 5Modelling the Made in EU threshold position (three scenarios)
- 6Preparing the binding information application file
Related services
Made in EU Origin Assessment
We read your production flow on site and determine where your product is deemed to originate under EU rules. We show, on your own product, why "we have an A.TR" is not enough.
1.3Assured Origin File
We prepare a file that stands behind your origin declaration, has passed independent expert review and can be defended under audit.
2.1Tariff and Production Scenario Design
If you cannot meet the origin rule, we redesign the production flow. Three scenarios, each with its origin outcome, cost and defensibility calculated.