The World Customs Organization (WCO) has published a new Study on the Origin Determination of Remanufactured and Recycled Goods, highlighting significant gaps in the rules of origin applicable to these products under free trade agreements (FTAs).
The study, approved by the 147th/148th Sessions of the WCO Council, examines how rules of origin are currently applied to recycled and remanufactured goods across 19 Customs administrations. The WCO says the findings reveal a lack of clear definitions, origin criteria and procedures in many FTAs.
Why Rules of Origin Matter
Rules of origin determine the country of origin of goods and can be critical in deciding whether an importer is eligible for preferential tariff treatment under an FTA.
The WCO study points out that rules of origin were primarily developed around conventional, newly manufactured products. This creates difficulties when the goods entering international trade are recycled or remanufactured.
The issue is becoming increasingly important as countries move towards circular economy models, in which products and materials are reused, recovered, refurbished, remanufactured or recycled rather than discarded.
Study Examines Practices in 19 Countries
In 2026, WCO Members were asked to provide information on whether they apply rules of origin to recycled and remanufactured goods, which trade agreements they use and the challenges faced by Customs administrations.
Out of 78 Members invited to respond, 19 Customs administrations — approximately 24.36% — submitted responses. The WCO found that only a few of the responding administrations reported that their FTAs provide clear definitions of which goods qualify as recycled or remanufactured.
In many FTAs, such goods are dealt with under provisions concerning wholly obtained goods, including:
- By-products generated during manufacturing, such as metal offcuts and fabric scraps;
- Used parts obtained through dismantling, including parts recovered from discarded electronic equipment; and
- Remanufactured products, such as restored laptops capable of performance comparable to new products.
Only Some Customs Administrations Grant Preferential Treatment
The study found that 10 of the responding administrations indicated that they grant preferential treatment to recycled and remanufactured goods, while the remaining eight indicated that they do not, largely because of the absence of appropriate procedures and rules of origin.
The WCO notes that FTAs generally require these goods to qualify as goods that are wholly obtained or produced entirely within the territory of one or more parties to the agreement.
However, the treatment of recycled and remanufactured goods remains a grey area in many agreements.
Customs Faces Practical Difficulties
The WCO study identifies several practical challenges for Customs administrations.
1. Identifying remanufactured goods
Customs authorities may have difficulty determining whether a product is new or remanufactured, particularly where the import documentation does not clearly identify the goods as remanufactured.
While certain categories have dedicated HS codes, the WCO notes that most recycled and remanufactured goods do not have separate dedicated HS codes.
2. Establishing the origin of materials
Another challenge is establishing the origin of materials used in remanufactured goods.
Because the goods may have been manufactured many years earlier, records concerning their original production may no longer be available.
3. Origin of recovered materials
Customs administrations may also face uncertainty over whether recovered raw materials obtained from used products can qualify as wholly obtained goods for purposes of preferential origin.
WCO Calls for Specific Rules of Origin
The WCO study recommends developing rules of origin specifically addressing recycled and remanufactured goods.
According to the WCO, properly designed rules of origin can help unlock preferential tariffs under FTAs and can influence production decisions and the development of supply chains between countries participating in preferential trade arrangements.
The study recommends several measures.
Traceability Systems
The WCO recommends establishing systems that can document the movement of materials from collection through to the final product.
Possible approaches include:
- Mass balance systems;
- Physical segregation; and
- Controlled blending.
Better Records of Waste Materials
The WCO also recommends clear specifications for input materials and proper records documenting the origin of waste, including whether it is pre-consumer or post-consumer waste and where it originated.
Such documentation could help reduce uncertainty regarding the origin of materials used in recycled and remanufactured products.
Third-Party Certification
The study further recommends the use of third-party certifications and standards to verify recycled content and product quality.
The WCO also highlights the potential role of technical standards and certification systems in assuring consumers that remanufactured products are safe and meet applicable technical requirements.
Implications for Importers and Exporters
The WCO’s study could have important implications for businesses involved in the circular economy, recycling, refurbishment and remanufacturing.
Importers and exporters dealing in such goods may need to pay closer attention to:
- Applicable FTA rules of origin;
- Whether remanufactured or recycled goods are specifically defined;
- HS classification;
- Origin of recovered materials;
- Documentary evidence supporting origin;
- Traceability of inputs;
- Eligibility for preferential tariff treatment; and
- Certification requirements.
Businesses should not assume that a recycled or remanufactured product automatically qualifies for preferential customs duty under an FTA. Eligibility depends on the applicable agreement and its rules of origin.
Circular Economy and International Trade
The WCO’s study comes as trade agreements increasingly incorporate circular economy concepts.
The WCO notes that some FTAs already contain provisions intended to promote trade in recycled and remanufactured goods, including differentiated tariffs at the six-digit HS level for certain recycled or remanufactured products or subheadings covering both new and recycled/remanufactured products.
However, the WCO emphasizes that for these ambitions to be achieved, the terms “recycled” and “remanufactured” need to be clearly defined, along with appropriate origin rules and procedures.
Key Takeaway
The new WCO study highlights a growing challenge at the intersection of Customs, rules of origin and the circular economy.
As international trade increasingly incorporates recycled and remanufactured products, Customs administrations and businesses need clearer rules for determining their origin. Without appropriate definitions, documentation and procedures, businesses may face uncertainty when attempting to claim preferential tariffs under FTAs.
The WCO’s recommendations on traceability, documentation, certification, technical standards and dedicated rules of origin could help provide greater certainty for Customs authorities and international traders.
Official Source
World Customs Organization (WCO), “Origin Determination of Remanufactured and Recycled Goods – WCO publishes new study,” 28 July 2026.
