A number of importers and agents are querying the origin criteria being used for manufactured goods on Certificates of Origin (CoO’s). From anecdotal evidence, particularly as to Wholly Obtained Goods (WO), it would appear that the relevant regulatory or certificate issuing authorities in China may be misreading of the rules. Customs Brokers will need to seek clarification from their clients where doubt exists as to WO goods, particularly noting for importers the issues of any short payment of customs duty and associated penalties if a CoO is applied and is subsequently found to not be valid. Please talk to us at Colless Young if this issue raises any concerns for you.
Source: http://www.cbfca.com.au/CBFCA/News/NNF/NNF2015/NNF_2015_174.aspx