The Central Board of Indirect Taxes and Customs (CBIC), Ministry of Finance, has notified the Customs Tariff (Determination of Origin of Goods under the Comprehensive Economic Partnership Agreement between India and Oman) Rules, 2026 vide Notification No. 48/2026–Customs (N.T.) [S.O. 419(E)], dated May 29, 2026. The Rules have come into force with effect from 1 June 2026, coinciding with the entry into force of the India-Oman Comprehensive Economic Partnership Agreement (CEPA).
The Rules establish a detailed legal framework for determining whether goods exported from India to Oman, or from Oman to India, qualify as ‘originating goods’ for the purposes of claiming preferential tariff treatment under the CEPA. Only goods certified as originating in accordance with these Rules will be entitled to the concessional rates of customs duty agreed under the Agreement.
Origin Criteria: Under Rule 4 of the notified Rules, goods shall be treated as originating in a Party if they are wholly obtained or produced in that Party, or if they satisfy the Product-Specific Rules (PSR) prescribed in Annexure-B to the Rules. Where value addition is the applicable criterion, two methods are permissible — the build-down method and the build-up method — giving exporters flexibility in demonstrating compliance.
Wholly Obtained Goods: Rule 5 enumerates categories of goods that qualify as wholly obtained in a Party, including live animals born and raised there, mineral products extracted from its territory, agricultural and fishery products harvested or caught there, and goods produced entirely from such materials.
De Minimis Tolerance: Rule 6 provides that goods which do not satisfy the applicable PSR may still qualify as originating, provided the value of non-originating materials that do not meet the change-in-tariff-heading requirement does not exceed 10 per cent of the FOB value of the goods. This tolerance provision is aimed at providing flexibility to manufacturers using small quantities of third-country inputs.
Minimal Operations: Rule 7 lists operations that, when performed alone or in combination, shall not confer originating status. These include operations such as simple packaging, labelling, sorting, washing, cutting, painting, and similar activities that do not result in substantial transformation of the goods.
Bilateral Cumulation: Rule 8 introduces the principle of bilateral cumulation, whereby materials originating in one Party may be considered as originating in the other Party when used in the production of goods. This provision strengthens the bilateral supply chain between India and Oman and encourages deeper integration of the two economies.
Direct Consignment: Rule 13 stipulates that preferential treatment shall be accorded only to goods that are directly consigned between the Parties. Goods transited through third countries must not undergo any operations other than unloading, reloading, or operations necessary to preserve them in good condition, and must remain under customs supervision during transit.
Proof of Origin: Rule 14 provides that an importer may claim preferential tariff treatment on the basis of a Certificate of Origin (CoO) issued in either electronic or hard copy form, an electronic Certificate of Origin (e-CoO), or an origin declaration made by an approved exporter. The Rules thus embrace digital documentation in line with modern trade facilitation practices.
Certificate of Origin — Validity and Issuance: Under Rule 15, a Certificate of Origin shall be valid for a period of 12 months from the date of issuance. The CoO shall be issued by the designated issuing authority within 5 working days of the date of exportation, ensuring timely clearance of goods at the port of import.
Record Keeping: Rule 19 requires exporters, producers, and importers to maintain all records and documentation relating to the origin of goods for a period of five years from the date of export or import, as the case may be. These records must be made available to the competent authority upon request.
Verification and Compliance: Rule 22 establishes a structured verification mechanism. Upon receipt of a verification request, the Party to whom the request is made shall acknowledge receipt within 15 days, furnish a preliminary response within 30 days, and complete the full verification process within 90 days. Rule 26 provides that preferential treatment may be denied where goods do not satisfy the origin requirements or where the importer or exporter fails to comply with the provisions of the Rules.
Temporary Suspension: Rule 29 empowers the competent authority to temporarily suspend preferential treatment in respect of goods from a particular exporter or for a particular tariff heading, where reasonable doubt exists as to the authenticity or accuracy of the proof of origin or the originating status of the goods concerned.
Electronic Data Exchange: Rule 34 provides for the exchange of information between the customs authorities of India and Oman through electronic means, facilitating seamless verification of Certificates of Origin and reducing the scope for fraudulent claims of preferential treatment.
Subcommittee on Rules of Origin: Rule 32 provides for the establishment of a Subcommittee on Rules of Origin under the CEPA Joint Committee, which shall meet as necessary to review the operation of the Rules, consider amendments where warranted, and address issues arising in the implementation of the origin-related provisions of the Agreement.
The India-Oman CEPA is a landmark bilateral trade agreement that seeks to expand trade and investment flows between the two countries. The notified Rules of Origin form a critical component of the Agreement’s implementation architecture, ensuring that the benefits of preferential tariffs are conferred only on genuinely originating goods, thereby protecting domestic industry and promoting authentic bilateral trade.
The notification has been issued under the powers conferred by sub-section (1) of section 5 read with sub-section (3) of section 3 of the Customs Tariff Act, 1975 and is accessible on the official website of CBIC at www.cbic.gov.in.
The Notification can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/05/Customs-Tariff-Determination-of-Origin-of-Goods-under-the-Comprehensive-Economic-Partnership-Agreement-between-India-and-Oman-Rules-2026.pdf
