Exporting to Iran Through an Armenian Company: Why Repacking or Relabelling Does Not Give EAEU Origin

Repacking or relabelling imported goods in Armenia does not give them EAEU origin for export to Iran: Article 6.6 of the EAEU-Iran Free Trade Agreement lists packaging, repackaging and affixing marks, labels or logos as insufficient processing, alone or in combination. Selling through an Armenian company or shipping through Armenia does not confer origin either. Iran’s preferential duty depends on where and how the goods were produced, proved by a CT-3 certificate or, for consignments with a customs value up to EUR 5,000, an origin declaration.

Which agreement applies to exports from Armenia to Iran

The full EAEU-Iran Free Trade Agreement was signed on 25 December 2023 and entered into force on 15 May 2025, replacing the 2018 Interim Agreement. Its rules of origin are in Chapter 6. The Eurasian Economic Commission publishes the English text and annexes; the Commission describes its Russian version of Chapter 6 as an unofficial translation.

Under Article 28(2) of the EAEU Customs Code, the origin of exported goods is determined by an international agreement where one applies. For a shipment priced on preferential terms to Iran, Chapter 6 of the FTA is the test. Our overview of Armenia’s free trade agreements covers the other markets, and preferential duty rates and rules of origin explains how origin works across them.

Three separate questions: who sells, how goods travel, where they originate

Who sells: the Armenian company

A legal entity established under the law of an EAEU member state is a “person of a Member State” under Article 2(1)(17) of the Customs Code. An Հայկական ՍՊԸ therefore qualifies as an EAEU exporter. The definition describes the trader. It says nothing about where the goods were made, and an Armenian invoice, Armenian ownership or dispatch from Yerevan does not add origin to a product made elsewhere.

How goods travel: transit and customs status

Article 29(2)(1) of the Customs Code generally dispenses with proof of origin for goods placed under customs transit. The exemption is qualified by Article 29(3) to (5), including where there are indications that goods originate in a country subject to import or export prohibitions. Being excused from proving origin in transit is no evidence of EAEU origin.

Goods released for internal consumption in Armenia acquire the status of Union goods (Customs Code Articles 2(1)(47) and 134(2)). That is a customs status, separate from FTA origin. A machine made in a third country and cleared in Yerevan becomes a Union good and remains non-originating for the FTA.

The FTA adds its own transport condition. Article 6.9 requires direct consignment between the parties. Transit through a third country is allowed only where it is justified by geography or transport, the goods do not enter trade or consumption there, and nothing is done to them beyond unloading, reloading, storage or preservation. Transport documents and invoices are the evidence, and failure costs the preference.

Where goods originate: the Article 6.3 test

Article 6.3 gives three routes to originating status:

1. wholly obtained or produced in a party (Article 6.4);
2. produced entirely from materials that are themselves originating;
3. produced using non-originating materials, where the goods reach a value-added content (VAC) of at least 50% of the ex-works (EXW) price, or meet the product-specific rule for their heading in Annex 2.

Article 6.5(1) sets the formula: VAC = (EXW price minus the value of non-originating materials) divided by the EXW price, times 100. Annex 2 is driven by HS code and is not uniformly 50%. Pipes and tubes of headings 73.03 to 73.07 require a change of chapter, and goods vehicles of heading 87.04 need 40% VAC plus prescribed technological operations.

Two provisions are often misread. Article 6.8 allows necessary non-originating materials that fail a tariff-change rule up to 5% of the EXW price; it does not lower the 50% VAC threshold to 45%, and those materials still count in the VAC calculation. Article 6.7 allows cumulation: originating Iranian materials used in Armenia count as originating where the Armenian operations go beyond the Article 6.6(1) list, and their origin is supported by a CT-3.

Worked example 1: unchanged resale of imported goods

An Armenian LLC imports finished household appliances made in a third country, clears them in Armenia and sells them to a buyer in Tehran. No production takes place in Armenia, so none of the three Article 6.3 routes is met. The appliances are Union goods in Armenia and non-originating under the FTA, and the Iranian buyer pays the duty that applies to goods without preference.

Government Decision 1772-N of 30 December 2010, the general Armenian procedure for certificates of origin, allows a general-form certificate for foreign-origin goods exported without processing (Annex, paragraphs 31 and 32). That certificate records the foreign origin. It is not a CT-3 and gives no EAEU origin.

Worked example 2: repacking or relabelling in Armenia

A trader imports shelled nuts in bulk, sorts them, packs them into retail bags in an Armenian facility and prints an Armenian brand on the bags. Sorting, packing into bags and affixing marks or labels all appear in the Article 6.6(1) list, which also covers washing, freezing and thawing, mixing without a material change, and simple assembly or disassembly. Listed operations confer no origin when performed alone or combined, so the nuts remain non-originating.

Buying an automated packing line does not change the outcome. Article 6.6(2) defines “simple” as an activity needing no special skills and no equipment especially designed for it, but the packaging and labelling subparagraphs carry no “simple” qualifier at all. Packaging or labelling done inside a production process that qualifies on its own terms is unaffected; Article 6.6 only stops these operations from conferring origin by themselves.

Worked example 3: real manufacturing in Armenia

A factory in Armenia makes a product whose heading has no specific rule in Annex 2, so the default 50% VAC test applies. The figures below are illustrative arithmetic on the Article 6.5 formula, not a customs ruling:

Where Annex 2 does set a rule, the percentage can be irrelevant. A plant that makes seamless tubes of heading 73.04 from imported Chapter 72 steel meets the change-of-chapter rule; one that only cuts and threads imported Chapter 73 tubes does not. Whether a real product qualifies turns on its HS code, the classification and value of every input, and the operations carried out.

Proof of origin and who issues it in Armenia

• CT-3 certificate (Article 6.15(1)(a), Annex 3): completed in English, one consignment per certificate (Article 6.18(4)), valid for 12 months from issue (Article 6.15(2)). In Armenia it is issued by the Chamber of Commerce and Industry of the Republic of Armenia, designated by Government Decision 514-N of 14 May 2015, with the Ministry of Economy as supervisor.
• Ծագման հռչակագիր (Articles 6.15(1)(b) and 6.17(1), Annex 4): made by the producer or exporter for consignments of originating goods with a customs value up to EUR 5,000. It is not available for consignments split to avoid the certificate.
• No document (Article 6.16): originating goods up to EUR 200 need no proof document, though they must still meet the origin rules.
• Late claim: Article 6.15(3) allows preference to be claimed later where proof of origin was unavailable at importation.

The Chamber’s current CT-3 fee and processing time were not confirmed from an official source for this article. A draft government decision that would replace the 1772-N procedure had not been adopted by 23 October 2026, and the Chamber remains the issuing body.

Evidence to hold before pricing a shipment on preferential terms

1. The HS code of the finished product and the Annex 2 rule for that heading, or confirmation that the 50% default applies.
2. A bill of materials listing each input with its HS code, value and origin, and supplier CT-3 certificates for any Iranian inputs relied on for cumulation.
3. The VAC calculation on the EXW price.
4. Production records showing operations beyond the Article 6.6(1) list.
5. Iran’s tariff commitment for the product in Annex 1. Origin is necessary for the preferential rate but not sufficient (Article 2.3), and Article 2.3(3) preserves charges equivalent to internal taxes, trade remedies and service fees.
6. A transport plan that meets direct consignment under Article 6.9, with the documents to prove it.
7. A CT-3 for each consignment, or an origin declaration where the customs value is EUR 5,000 or less.

Under Articles 6.23 and 6.24, preference can be denied for goods or evidence that do not comply with Chapter 6, which means the full non-preferential duty falls due on a deal priced without it. Penalties under Iranian law beyond the loss of preference were not researched for this article.

Sanctions screening and bank de-risking

Central Bank of Armenia Board Decision 21-N of 30 January 2026, published on 11 February 2026 and in force since 12 August 2026, added Chapter 15.1 to the CBA’s Regulation 4. Armenian banks must run risk-based systems against sanctions circumvention and screen customers and transactions before executing them. The obligation is general and names no country.

In practice, Iran-linked business is among the categories Armenian banks restrict, and an Iran-trade company should expect detailed questions on its goods, counterparties and payment routes. Banks decide case by case, change policy often and need not explain a refusal. No lawyer can promise that a bank will open or keep an account for an Iran-trade company, and we do not. Our guide to բանկային գործունեությունը Հայաստանում covers account opening, and the bank gate for Iranian-linked founders sets out what banks ask of them.

The company’s own Armenian taxes are a separate matter, covered in our Հայկական հարկային ուղեցույց, and companies hiring Iranian staff can see our EOR hiring strategy for Iranian IT talent. For the wider export picture, read export opportunities under Armenia’s trade agreements. Before quoting an Iranian buyer a preferential price, have the HS code, bill of materials and VAC calculation checked against Annex 2, since the Chamber issues the CT-3 on that evidence.

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Վերջին թարմացումը `հոկտեմբեր 23, 2026