The EximLabh Brief

Can your India-EFTA TEPA shipment use self-declaration instead of a Certificate of Origin?

DGFT Public Notice No. 29/2025-26 opens a self-declaration route for India-EFTA TEPA shipments, letting exporters certify origin on the invoice instead of a chamber-issued certificate.

The question

Can an Indian exporter shipping to Switzerland, Norway, Iceland or Liechtenstein under India-EFTA TEPA sign off on origin themselves, or does every shipment still need a chamber-issued certificate?

What changed

DGFT Public Notice No. 29/2025-26 dated October 28, 2025 amends the Handbook of Procedures 2023 to insert India-EFTA TEPA into Para 2.88(a) and operationalise a self-declaration route. The Ministry of Finance has separately notified the Customs Tariff (Determination of Origin of Goods under the Trade and Economic Partnership Agreement between India and the EFTA States) Rules, 2025, giving the origin protocol legal effect at the border.

The practical shift is from a single-channel, issuing-authority model to a dual-channel system. An exporter may now certify origin on a commercial document, typically the invoice, instead of obtaining a certificate from a designated issuing agency such as a chamber of commerce or export promotion council.

Who this actually hits

The self-declaration option is most relevant to exporters with established origin-management systems: those who can document the originating status of inputs, maintain product-specific rule-of-origin worksheets, and withstand a verification request from an EFTA customs authority. Exporters who rely on third-party suppliers for originating inputs, or whose products sit close to the product-specific rule threshold, may find the issuing-authority certificate more defensible. The issuing agency performs an independent assessment before certification. Self-declaration shifts that origin risk from the issuing agency to the exporter.

The compliance trap

Self-declaration is not automatically available to every exporter for every product. The TEPA origin protocol states that Article 3 of Appendix 2.A.3, the provision governing issuance of certificates by the issuing authority, "shall not apply to products of which, by their nature, origin can be easily verified." This carve-out suggests certain low-risk products may be routed to self-declaration more readily, while products requiring substantive origin analysis remain on the issuing-authority track. The precise product coverage must be confirmed against the DGFT Trade Notice and the TEPA Annex 2.A product-specific rules.

A second trap is the DSC requirement. The DGFT Trade Notice states that Digital Signature Certificate is mandatory for generation of a self-declaration-based eCOO. Only users whose profiles are linked with the IEC and hold a valid DSC can complete the process. Exporters who have been using Aadhaar e-sign for other DGFT filings may assume the same authentication works here. It does not for self-declaration. The scanned copy of the ink-signed self-declaration must also be uploaded, creating a document-retention obligation alongside customs and GST record-keeping.

A third trap is the interaction between DGFT procedure and CBIC enforcement. The DGFT ePlatform may accept a self-declared certificate, but the EFTA importing state's customs authority retains the right to verify origin under the TEPA verification provisions. If verification fails, the importer in the EFTA state loses preferential duty, and the Indian exporter may face a claim for the duty shortfall under the commercial contract.

Open confirmations

Several points remain unresolved before an exporter commits to the self-declaration route:

Do not assume DGFT and CBIC are harmonised. Confirm the specific DGFT notification and the TEPA Annex 2.A product-specific rules before selecting the self-declaration route.

Operator note

Treat self-declaration as a compliance decision, not a convenience decision. Before selecting "India EFTA TEPA (Self-Declaration)" on the Trade Connect ePlatform, confirm that the product-specific rule of origin is met with documentary evidence that can survive a post-importation verification. Maintain the origin worksheet, supplier declarations, and the ink-signed self-declaration for at least the longer of the CBIC five-year customs record period and the DGFT eight-year authorisation record period. If the product sits close to the value-added or tariff-shift threshold, or if the supply chain includes non-originating inputs from multiple sources, the issuing-authority certificate remains the safer route despite the additional processing time.

Primary sources

Confidence

DGFT, India-EFTA TEPA, certificate of origin, self-declaration, preferential tariff, rules of origin.