Rules of Origin for aluminium circles, not alloyed — Dubai (UAE) to India
HS 76069110 · ALUMINIUM PLATES · Rules of Origin & preferential rate
Data last updated: · MFN duty & IGST verified against ICEGATE (Indian Customs EDI). Rules of Origin per CEPA Annex 3B. Verify your exact HS line before filing.
- CEPA eligible
- Yes
- Value addition (RVC)
- 45%
- Tariff-classification change
- CTSH Annex 3B rule set at chapter level — it covers the whole chapter, not this code alone
- MFN → CEPA basic duty
- 7.5% → 0%
Rule of Origin (CEPA Annex 3B, primary source): CTSH + VA 45% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).
Qualifying under the Rules of Origin
To claim the CEPA preference on aluminium circles, not alloyed (HS 76069110), the goods must qualify as UAE-originating. The Product-Specific Rule (Annex 3B) is "CTSH + VA 45% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required)": the goods must undergo a change of tariff sub-heading (CTSH) AND add at least 45% regional value content — both conditions, not either/or. Read that rule for what it is: Annex 3B supplies it at chapter level, so it governs hundreds of eight-digit codes rather than this one. It is the correct rule to apply, and it is also the place to check for a more specific carve-out before committing to a claim. Aluminium circles are blanked discs drawn into cookware, reflectors and pressed components, with steady Indian demand from utensil manufacturing. CEPA removes the basic duty. The 45% value-content rule — stricter than the 40% applying across most of the corpus — is met where UAE mills roll and blank the material themselves, and blanking alone on imported sheet is unlikely to carry it. Cookware-bound material faces food-contact expectations downstream from the buyer, separate from customs and evidenced by the mill's own documentation. Aluminium products are covered by a Quality Control Order requiring BIS certification of the producing mill, which has to be confirmed before shipment rather than at the port. Because circles are often bought by mid-size manufacturers on thin margins, the duty saving is decisive — make the Certificate of Origin part of the purchase terms rather than an afterthought, so the supplier commits to it at order stage. A valid Certificate of Origin filed through the eCoO 2.0 system must accompany the shipment; without it, customs charges the 7.5% MFN rate instead of the preference.
Check your own figures in the Rules of Origin (RVC) qualifier. Qualifying is only half of it — the preference is claimed with a Certificate of Origin, issued in the UAE before shipment or retrospectively within 12 months.
Frequently asked questions
- Does aluminium circles, not alloyed qualify for India–UAE CEPA?
- Yes, if it meets the Annex 3B Product-Specific Rule "CTSH + VA 45% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).": it must BOTH change tariff classification (CTSH) AND add at least 45% regional value content — both conditions are required, not either/or.
- What is the Rule of Origin for aluminium circles, not alloyed?
- Per CEPA Annex 3B: CTSH + VA 45% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).. RVC% = [(FOB − value of non-originating materials) / FOB] × 100 (FOB basis).
- What proof is needed at import?
- A preferential Certificate of Origin filed through eCoO 2.0, presented at customs before clearance. Without it, the 7.5% MFN duty applies.