The Ministry of Finance, Department of Revenue, through the Central Board of Indirect Taxes and Customs (CBIC), has issued Notification No. 82/2026-Customs (N.T.) dated 12 October 2026. The notification introduces the Customs Tariff (Determination of Origin of Goods under the Free Trade Agreement between India and New Zealand) Rules, 2026.
A product may qualify as originating in India or New Zealand if it is wholly obtained or produced in either or both countries, or if it satisfies the applicable Product-Specific Rules of Origin (PSRs) in Annexure A and the other requirements of the notification.
Wholly obtained goods include qualifying plants and agricultural products, animals born and raised in the country, minerals extracted there, specified marine products, and eligible waste and scrap.
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2. Bilateral cumulation
The rules allow bilateral cumulation. An originating material from India incorporated into a product manufactured in New Zealand may be treated as originating in New Zealand, and vice versa, subject to the prescribed conditions.
This provision can support cross-border manufacturing and supply chains between the two countries.
3. Qualifying Value Content (QVC)
Where a product-specific rule prescribes a qualifying value content requirement, the notification provides two calculation methods:
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Build-down method: Based on the FOB value of the goods minus the value of non-originating materials.
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Build-up method: Based on the value of originating materials as a proportion of FOB value.
The applicable percentage depends on the relevant product-specific rule. Costs and values must be determined under the prescribed customs valuation principles, with accounting records maintained in accordance with the applicable Generally Accepted Accounting Principles (GAAP).
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4. Minimal operations and de minimis provisions
The notification clarifies that certain basic operations do not, by themselves, confer originating status on goods. These include simple packaging, labelling, sorting, cutting, polishing, dilution, simple assembly and mixing.
It also provides limited tolerance for certain non-originating materials:
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10% of FOB value for qualifying goods that fail the applicable tariff-classification change requirement, subject to the stated conditions.
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For textile goods under HS Chapters 50–63, the specified tolerance is 10% of the total weight or value of the good.
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1% of total weight or value for specified wholly obtained goods containing certain non-originating materials from other HS chapters.
These concessions are subject to the detailed conditions in Rule 9 and do not override other applicable requirements.
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5. Proof of Origin and Certificate of Origin
Importers claiming preferential customs duty treatment must generally possess valid proof of origin. The notification recognises two forms:
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A Certificate of Origin issued by the designated issuing authority.
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An origin declaration completed by eligible exporters, including Indian status holders and approved exporters in New Zealand, as specified in the rules.
The proof of origin must be in English, contain a unique identification or certification number, and establish that the goods satisfy the origin requirements. It is generally valid for 12 months from completion or issuance.
In exceptional circumstances, it may be issued retrospectively within the prescribed 12-month period after importation.
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6. Record-keeping requirements
Exporters, producers, approved exporters, status holders and relevant issuing authorities must retain records establishing the originating status of goods for at least five years, or longer where applicable under domestic law.
Importers must also retain the necessary supporting records for at least five years from importation. The original proof-of-origin document must be retained in hard-copy written form, while other supporting records may be stored electronically or in another readily retrievable format.
This makes proper documentation of materials, production costs, labour and overheads important for businesses claiming preferential treatment.
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7. Verification and denial of preferential treatment
Customs authorities may verify the origin of imported goods through written information requests, checks with issuing authorities, requests to exporters or producers, and verification visits to production premises.
Preferential tariff treatment may be denied if the goods do not satisfy the origin criteria, sufficient information is not provided within the prescribed timelines, or the required cooperation with verification procedures is not given.
The rules also allow temporary suspension of preferential treatment in cases involving persistent or deliberate misrepresentation of origin. Incorrect declarations may attract civil, administrative or criminal sanctions under the applicable law.
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8. Post-importation claims and refunds
An importer who did not claim preferential tariff treatment at the time of importation may subsequently apply for the benefit and a refund of excess customs duties, provided the goods qualified when imported and the applicable conditions are met.
The rules permit the importing country to require the claim, proof of origin and supporting documentation within 12 months after importation, or a longer period where its domestic law allows.
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9. Product-specific rules in Annexure A
Annexure A contains the product-specific origin requirements arranged by Harmonized System (HS) classification. Depending on the product, the criteria may require:
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Wholly obtained status (WO).
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Change in tariff classification at the chapter, heading or subheading level.
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A prescribed qualifying value content.
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Compliance with a specified production process.
Businesses must check the rule applicable to the particular HS code rather than assume that all goods exported between India and New Zealand automatically qualify for preferential treatment. The notification also includes prescribed formats for proof of origin in its annexures.
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Impact on businesses, importers and exporters
The notification establishes the origin-determination framework that businesses will need to follow when seeking preferential customs duty treatment under the India–New Zealand FTA. Indian exporters and importers dealing with New Zealand should review the product-specific requirements, assess the origin of raw materials, maintain cost and production records, and ensure that the prescribed proof of origin is available.
Customs brokers, trade-compliance teams and finance professionals may also need to review documentation and valuation procedures to ensure that preferential duty claims are adequately supported. CASansaar