In response to recent tariff threats from the United States and to provide further clarification on provisions in Cambodia’s Law on the Rules of Origin (2023), the Cambodian government has issued two Prakas aimed at tightening enforcement of the rules governing the export of goods to the US. The first Prakas addresses obtaining an Origin Certification Letter (“OCL”) to export certain goods to the US, while the second Prakas addresses anti-fraud measures. Both Prakas entered into effect on May 12, 2025 and existing regulations that do not conflict with their provisions remain in force.
Procedures for Obtaining an Origin Certification Letter
On April 30, 2025, the Ministry of Commerce (“MOC”) issued Prakas No. 047 on the Procedures for Applying for and Issuing Origin Certification Letters for the Export of Certain Goods to the United States (“Prakas 047”). It complements existing legal documents related to the prevention of origin fraud, ensuring compliance with Cambodia’s and the US’s rules of origin by strengthening verification procedures.
Mandatory registration
Exporters and producers must register with the MOC’s online CO Automation System at https://co.moc.gov.kh before applying for an OCL. Required uploads (in PDF) include:
- Certificate of Incorporation
- GSP/MFN Certificate
- Letter of authorization for the representative from the company owner or registered manager
- ID/passport and a 4×6 cm photo of the authorized representative or designated recipient
On-site inspection for the first OCL
Initial certification requires an inspection by MOC officials to verify compliance. The detailed steps for this process are outlined in Prakas 047’s Standard Operating Procedures (Annex II), which include:
- Procedures for initial and subsequent OCL issuance, which involves giving authority to the MOC officials to do the following:
- Inspect business premises, warehouses, and manufacturing sites
- Examine export documents such as purchase orders, invoices, and cost breakdowns
- Inspect aspects of the manufacturing process including raw materials, workforce, machinery, production capacity, and labeling
- Verify production records
- Documentation responsibilities of producers/exporters
- Mechanisms for inter-ministerial data sharing and verification
- Risk or complaint-based inspection and enforcement measures
- Cooperation mechanisms with competent US authorities
After inspection, the MOC officials will issue an initial inspection report, which is required for the initial and all future OCL applications.
Required documents for the OCL application
After registration and inspection, applicants must submit the following through the CO Automation System:
- Invoice and packing list
- Cost breakdown or reference documents required by the rules of origin
- Initial MOC inspection report
Issuing authority and fees
The General Directorate of Trade Support Services issues the OCL. There is no public service fee for the application. A sample OCL is provided in Annex III of the Prakas.
Anti-Fraud Measures
The MOC and the Ministry of Economy and Finance’s Joint Prakas No. 379 on Measures to Prevent Fraud on the Origin of Certain Goods Exported to the United States was also issued on April 30, 2025. It applies to all Cambodian producers and exporters shipping certain goods to the United States (the list of applicable goods is included in Annex I of Prakas 047).
Certification requirements
- Exporters must obtain an OCL from the MOC in accordance with Prakas 047.
- The OCL must be attached when submitting the customs declaration for exports claiming Cambodian origin.
Verification and investigation
If there are questions as to origin or at the request of the US authorities, the General Directorate of Trade Support Services and the General Department of Customs, with support from relevant institutions, will jointly investigate the origin of the goods.
Penalties for non-compliance
Any producer or exporter found committing fraud with regard to the origin of goods, including concealing transshipment operations, will face penalties under the Law on Rules of Origin and the Law on Customs, such as a fine ranging from KHR10 million to KHR40 million, and imprisonment of one to five years.