Non-manipulation certificate: the proof of direct transport that protects your preference

A non-manipulation certificate is a document that proves goods were not altered while they were unloaded, stored or transhipped in a third country between the place they were dispatched and their destination. It is one way to satisfy the 'direct transport' rule behind a tariff preference: the goods that arrive must be the goods that left, unchanged on the way. It does not replace the proof of origin - where there is a third-country stop, the importer needs both the proof of origin (such as a movement certificate EUR.1 or an origin declaration) and evidence of non-alteration.

For example, goods of Japanese preferential origin under the EU-Japan Economic Partnership Agreement are shipped from Japan but unloaded and stored for a few days in Singapore before continuing to the EU. To claim the preferential rate on import, the importer shows the proof of origin and, because the goods stopped in Singapore, evidence that they were not altered there - which can include a non-manipulation certificate issued by Singapore customs.

The same need arises when a single container is broken into smaller consignments at a third-country hub for delivery to different customers: splitting is allowed only under agreements that use the softer non-alteration clause, and only if the goods stayed under customs supervision and were not otherwise changed.

The rule behind it: direct transport, non-manipulation, non-alteration

An agreement requires goods to travel from the country of preferential origin to the destination without being changed on the way. The exact rule is set by each agreement's origin protocol, so the first step is always to read the specific agreement - some still use the strict form, others the flexible one. It goes by three names:

• 'direct transport' - the strictest form. In a third country the goods may only stay under customs supervision and be unloaded, reloaded or kept in good condition. Splitting the consignment is not allowed.
• 'non-manipulation' or 'non-alteration' - the modern form used in most newer EU agreements. It also allows the consignment to be split, and marks, labels, seals or compliance documents to be added - provided the goods stay under customs supervision and are not otherwise altered.

What each rule allows in a third country on the way:

The importer carries the burden of proof. In practice the first-choice evidence is a single transport document covering the whole journey - a through bill of lading. Where that is not available, or the goods were stored or split, the evidence can be records of customs supervision or a non-manipulation certificate issued by the customs authority of the country where the goods were stored or transhipped. Not every customs administration issues such a certificate, so it cannot always be obtained - which is why the other forms of evidence matter.

Who issues it

A non-manipulation certificate is issued by the customs authority of the country where the goods were unloaded, stored or transhipped. When the EU is the destination, that is the third country the goods passed through - its customs issue the certificate. When goods instead pass through the EU on the way between two other countries, an EU member state issues it - which is what the Lithuanian procedure below is for.

The EU procedure - Lithuania as an example

In the EU the procedure is set at national level. In Lithuania it is governed by Customs order No. 1BE-576 of 2 July 2024 (which replaced the 2019 order), as amended by order No. 1BE-702 of 20 October 2025. The application is made through the national Customs Authorisations System (MLS): the competent customs office accepts the application within one hour of submission, and decides whether to issue the certificate by the end of the next working day at the latest. The applicant confirms that the goods were transhipped directly, without any change or manipulation, and that the information given is accurate.

The application asks for, among other things: the reasons for needing the certificate; the goods (a 4, 6 or 8-digit Combined Nomenclature code, description, country of origin, packages, quantity, gross and net weight); the inbound transport, container and waybill and the date the goods were unloaded or transhipped; the outbound transport and the final destination; the customs declaration under which the goods were brought in or stored; and copies of any supporting documents.

New in 2026: direct transport reaches non-preferential origin

The direct-transport and non-manipulation idea has long belonged to preferential trade. From 1 July 2026 it also applies to a non-preferential claim (see: 'UCC change for US imports: proof of origin now includes direct transport', CCRM Issue 39 (2026)). To grant the 0% adjusted duties on most US-origin goods under Regulation (EU) 2026/1455, the EU added Article 59a to the UCC Implementing Act (by Regulation (EU) 2026/1422): the proof of non-preferential origin must now also include evidence that the goods were transported directly from the United States to the EU. Where they passed through a third country, a non-manipulation certificate from that country's customs is one accepted form of that evidence - and the whole file, origin and direct transport, must be in the declarant's possession when the declaration is lodged, not gathered afterwards.

Two things to keep in mind. The origin here is non-preferential, yet the claim is made through the declaration's preference-code mechanism. And the regime is temporary: Regulation 2026/1455 applies until 31 December 2029 and carries suspension triggers, including a review of US steel and aluminium tariffs on 31 December 2026, so the position may change.

Use case

Question to Smart Taric AI: "I import motorcycles 8711 50 00 from the US to Poland. What do I need to claim the 0% duty?".

Smart Taric AI shows that motorcycles with an engine over 800 cm³ (commodity code 8711 50 00) from the US carry a 0 % duty from 1 July 2026 under Regulation (EU) 2026/1455 - against a standard third-country rate of 6 % - and that to claim it you present a proof of origin established in accordance with Article 6 of that regulation (document code U190). Polish import VAT of 23 % applies.

That proof of origin is where a non-manipulation certificate can come in. The origin here is non-preferential, and under the new Article 59a the proof must also show the goods were transported directly from the US to the EU. For a direct US-to-Poland shipment, transport documents do the job. But if the same motorcycles were unloaded and stored in a third country on the way - say a warehouse in the UK - the importer has to show they were not altered there, and a non-manipulation certificate issued by that country's customs is one accepted form of evidence. Without the complete file - origin and direct transport - in hand when the declaration is lodged, the 0 % cannot be claimed and the 6 % applies.

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