The Form D process thus involves an emphasis on the verification of paper documentation, rather than the verification of the underlying facts of the transaction. ASEAN government authorities devote more time and resources to confirming whether the Form D document conforms to the ATIGA requirements than to whether the goods actually qualify for the duty preferences.

Self-certification by exporters would move the focus away from the Form D documentation and toward the fundamentals of the transaction. Under certain conditions, trusted traders/exporters could provide a statement/declaration about the origin of the product in question on the invoice. While maintaining a substantial degree of reliability, it would be simpler and more cost-effective and would therefore enhance utilization of the advantages offered by the ATIGA.

Self-certification is based on the assumption that “the exporter knows best” what it is making, how it is made and who supplied the materials to make it; in other words, the exporter is – almost – always in the best position to initially establish whether its goods satisfy the applicable origin criteria. Frankly, the Form D process is also based on the same principle: it is the exporter that declares in the application for a CO that its goods meet the applicable RoO.