On November 11 and 12, 2025, the Forum on Rules of Origin under the Regional Comprehensive Economic Partnership (RCEP) was co-organized by the Asian Development Bank (ADB), the United Nations Conference on Trade and Development (UNCTAD) and the RCEP Support Unit (RSU) in Manila, Philippines. The Forum was well participated by representatives of government agencies, experts and international organizations from RCEP member countries to discuss the implementation of rules of origin in the RCEP and various ASEAN+FTAs. Vietnamese delegation attending the Forum included representatives of the Foreign Trade Agency and the Multilateral Trade Policy Department of Ministry of Industry and Trade of Viet Nam. In addition, Deputy Director General of the Foreign Trade Agency also delivered an online presentation, contributing to the discussion of the Forum.

The role of rules of origin in FTAs

Rules of Origin (ROO) is one of the core chapters of any free trade agreement, acting as a “bridge” between preferential tariff commitments and actual benefits for businesses. In any FTA, tariff reduction or elimination commitments can only bring about real value when goods meet the origin criteria as prescribed by the FTA. In other words, ROO is the “key” to enable goods to enjoy incentives, while preventing illegal transshipment by non-Party countries to take advantage of tariff commitments.

The importance of ROO lies not only in the legal aspect but also in its far-reaching economic impacts. A clear, harmonized and flexible ROO system helps reduce compliance costs, facilitating businesses – especially small and medium-sized enterprises – to participate more deeply in the regional value chain. On the contrary, if ROO is too complicated or lacks consistency among FTAs, businesses will find it difficult to utilise and take advantage of incentives, reducing the effectiveness of integration policies.

Current status of ROO in regional FTAs

Over the past two decades, Southeast Asia and the Asia-Pacific region more broadly have been the focus of the process of signing FTAs ​​with the largest number and scope in the world. Most ASEAN countries simultaneously participate in many bilateral and multilateral FTAs ​​– from ASEAN+FTA (with China, Japan, Korea, Australia – New Zealand, India, Hong Kong (China)) to new-generation agreements such as CPTPP or bilateral FTAs. For each FTA, depending on the partners and the interests of the countries participating in the negotiations, a set of rules of origin for that FTA is developed, including product-specific rules (PSR) and procedures for granting, checking, and verifying the origin of goods (OCP-Operational Certification Procedures). The fact that one or a group of countries participate in multiple FTAs ​​at the same time, and each FTA has its own set of rules of origin, creates a phenomenon commonly known as the “noodle bowl” which can make it difficult for businesses, especially small and medium-sized enterprises, to choose and comply with appropriate rules of origin, leading to high transaction costs, risk of violations, and low rate of tariff preferential utilization.

The need to “converge and simplify” rules of origin

Given the above reality, the need to harmonize, converge, and simplify rules of origin is becoming urgent. Initiatives such as the RCEP Agreement, with its regional cumulation mechanism and unified ROO system, harmonizing the four sets of ROO rules of other ASEAN+ FTAs, are considered an important step to “untangle” the FTA noodle bowl of the region. Building a harmonized, transparent and business-friendly ROO framework not only helps reduce compliance costs but also increases the ability to connect supply chains and realize the benefits of regional economic integration.

To this end, ADB has coordinated with UNCTAD to conduct a series of studies, reviewing the rules of origin in various FTAs ​​in the region, specifically RCEP, ATIGA, CPTPP and ASEAN+ FTAs, thereby pointing out the potential for convergence of PSR regulations as well as the possibility of adopting good practices on OCP, such as the self-certification mechanism. The results and recommendations of the above studies were presented by ADB and UNCTAD at the Forum, thereby equipping policymakers and negotiators with perspectives and toolboxes for convergence and simplification of ROO regulations in FTAs. The Forum is also a place where researchers, scholars, and experts from relevant international organizations (such as WTO, WCO) share their views on how to turn research analysis into practical adoption of PSR regulations that can help facilitate trade in feasible areas, as well as applying these ideas to reviews, negotiations to upgrade, and new negotiations of FTAs.

Vietnamese delegation attending the Forum included representatives of the Ministry of Industry and Trade from: the Foreign Trade Agency, the focal point for egotiating and implementing rules of origin in FTAs of Viet Nam, and the Multilateral Trade Policy Department, the focal point for coordinating negotiations, reviewing, upgrading, and negotiating new FTAs ​​within the ASEAN. From the perspective of an expert and also a person directly engaging in the domestic policy-making process, Ms. Trinh Thi Thu Hien - Deputy Director General of the Foreign Trade Agency also gave an online presentation, sharing about the implementation of ROO of the RCEP in Vietnam.

The Forum ended on the afternoon of November 12, 2025 with the sharing of feedback from representatives of participating countries on the contents discussed at the Forum. Representatives of participating countries acknowledged the contents discussed, emphasizing the desire to build a system of ROO regulations that are simple, friendly and trade facilitative for businesses in practice./.

Source: Compiled by the Multilateral Trade Policy Department, Ministry of Industry and Trade of Viet Nam