Insufficient working or processing/production (insufficient / minimal operations)

• The examples of insufficient/minimal operations typically found in the EU preferential trade agreements include:
  • preserving operations to ensure that the products remain in good condition during transport and storage,
  • breaking-up and assembly of packages,
  • simple placing in bottles, cans, flasks, bags, cases, boxes, fixing on cards or boards and all other simple packaging operations,
  • simple assembly of parts of articles to constitute a complete article or disassembly of products into parts,
  • simple mixing.
• You should consult the relevant list of insufficient/minimal operations because not all EU preferential trade agreements contain the same list. Each preferential agreement sets out an exhaustive list of what count as ‘insufficient operations’. For the EU-UK Trade and Cooperation Agreement all insufficient/minimal operations are listed here: Article 43 (“Insufficient production”).
• Definition of “simple” - some of the listed operations can be clearly identified as minimal/insufficient operations, such as putting a label on a product. Some operations containing the word ‘simple’ – for example ‘simple assembly’ – need further clarification. Some preferential agreements contain a definition of ‘simple’. Under the EU-UK Trade and Cooperation Agreement, operations are “considered simple if neither special skills nor machines, apparatus or equipment especially produced or installed are needed for carrying out those operations.”
• Insufficient/minimal operations are important for cumulation because they set the minimal level of processing that has to be carried out to benefit from cumulation. So they have an impact on the final product’s origin.
• When determining the origin of a final product, all steps in the manufacturing process must be taken into account. Insufficient operations only apply if carried out on non-originating materials. Insufficient/minimal operations do not apply if any originating materials are used in the production of the final product.
• For further information please refer to Guidance on preferential rules of origin