Indonesian Vegetables: FTA Certificates of Origin 2025 Guide

A practical, field-tested decision guide for Indonesian exporters shipping fresh, chilled, and frozen vegetables to Malaysia. When to use ATIGA Form D vs RCEP, how to check tariffs, a quick ROO test for wholly obtained produce, and step-by-step e-SKA tips.

If you export Indonesian vegetables to Malaysia, choosing between ATIGA Form D and an RCEP Certificate of Origin can feel trivial until a shipment sits at the port or a duty bill erases your margin. We’ve handled hundreds of vegetable consignments, and this is the 5‑minute guide we wish every shipping partner had from day one.

Why this guide matters in 2025

Malaysia’s tariff preferences for HS 07 vegetables under ATIGA and RCEP are very similar on paper. In practice, the better choice often comes down to speed of issuance, documentation cleanliness, and how you route cargo. And since most fresh and chilled vegetables qualify as wholly obtained, the difference is almost never the rule of origin. It’s paperwork and process. That’s where money is won or lost.

Our decision framework and how we test choices

Here’s the simple framework we use before booking space:

Step 1. Confirm the HS code at the 6-digit level (HS 07xx.xx). We validate with the importer’s broker so there’s no mismatch later.
Step 2. Check Malaysia’s preferential tariffs under ATIGA vs RCEP for that HS code and year tranche. If both are 0%, we optimize for speed and error tolerance.
Step 3. Choose the origin document with the smoother path based on routing, invoicing, and how quickly we can get the certificate through Indonesia’s e‑SKA.

We keep a log of which combo led to faster clearance for each product and port. Repeatability matters.

What’s in scope: HS 07 examples we actually ship

We’re focusing on vegetables under HS Chapter 07. Typical lines include cucumbers, tomatoes, lettuce, carrots, radishes, peppers, and eggplant. For instance:

Japanese Cucumber (Kyuri): HS 0707
Tomatoes: HS 0702
Baby Romaine (Baby Romaine Lettuce) and Loloroso (Red Lettuce): HS 0705
Carrots (Fresh Export Grade) and Red Radish: HS 0706 and 0706.90
Purple Eggplant: HS 0709
Frozen lines like Premium Frozen Okra and Frozen Mixed Vegetables typically sit in HS 0710. Each code needs its own tariff check.

Head‑to‑head: ATIGA Form D vs RCEP for Malaysia in plain language

Here’s the comparison we rely on when deciding fast.

Tariff rate in Malaysia. For most HS 07 lines, ATIGA and RCEP both provide 0% in current tranches. If your line still shows a positive RCEP rate but 0% under ATIGA, choose Form D. When both are 0%, either works.
Rules of origin. For fresh/chilled vegetables grown in Indonesia, the criterion is usually "Wholly Obtained (WO)." Both agreements treat WO similarly. No edge here.
Speed of issuance in Indonesia. Our experience is that Form D via e‑SKA is the fastest for WO vegetables. RCEP is also smooth but can take slightly longer if an officer requests extra clarifications on the template.
Back‑to‑back certificates. Both ATIGA and RCEP allow back‑to‑back COs when transshipping through another member (e.g., Singapore) without processing. RCEP templates tend to spell out the back‑to‑back checkbox and references more clearly, which helps brokers.
Third‑country invoicing. Allowed under both. Make sure the CO indicates the third‑party invoice details exactly as per the agreement format. ATIGA Form D has a specific box for this, and RCEP certificates include a checkbox/field.
Validity period. Typically 12 months from issuance under both schemes. That means you can apply retroactively if needed, subject to each agreement’s rules.
Error tolerance. In our files, minor clerical issues are slightly more forgiving on ATIGA Form D for WO produce, but don’t rely on that. Clean documents save hours.
Bottom line. If tariff outcomes are the same, we default to Form D for speed on perishables. We switch to RCEP when a back‑to‑back scenario is clearer under the buyer’s broker, or when the importer explicitly prefers RCEP for internal compliance.

Practical takeaway: Check the rate. If both are 0%, choose the path with the fastest e‑SKA issuance and the cleanest fit for your routing and invoicing. That’s usually Form D for WO vegetables.

Which gives lower duty: Form D or RCEP?

Neither consistently “wins” across all HS 07 lines. Many lines are already 0% under both. The only reliable way is to check your exact HS code in Malaysia’s schedules for the current tranche. If ATIGA shows 0% and RCEP shows a positive rate, go with ATIGA Form D.

How to check Malaysia’s current rate in practice

Confirm HS at 6 digits with your importer’s broker.
Look up Malaysia’s ATIGA rate and the RCEP rate for that HS code and year tranche.
If both read 0%, prioritize the certificate you can issue faster and more cleanly.

Need help confirming the HS and current tariff for your SKU? You can Contact us on whatsapp. We’ll walk through the check with you.

Example cost impact you can sanity‑check

Suppose HS 0704.90 (cabbage) faced an MFN duty of 5% at the time you ship, while ATIGA is 0%. On a USD 20,000 consignment you save USD 1,000 by filing Form D. If RCEP is also 0%, the savings are equivalent. Always verify the current tariff before you plan pricing.

Quick ROO test: can you claim “wholly obtained” (WO)?

For farm‑sourced vegetables harvested in Indonesia, WO is the cleanest criterion.

What qualifies. Plants grown and harvested in Indonesia. Packed and cooled without processing that changes their tariff line.
What doesn’t. Mixing origins in the same consignment. If farm invoices include multiple origins, you can’t declare WO for the whole shipment. Segregate lots and maintain origin‑specific packing lists, or remove the non‑Indonesian portion. RCEP won’t fix mixed origin for fresh HS 07 because the rule is still WO.
Documentation we keep ready. Farm origin statements, harvest dates, packing lists by lot, and traceability mapping to the invoice and PEB. These make officer questions much shorter.

Takeaway: If origins are mixed, don’t force a CO. Either split consignments or accept MFN. This prevents rejections and late‑night emails.

e‑SKA application steps that save a day

We file both ATIGA Form D and RCEP certificates through Indonesia’s e‑SKA. For WO vegetables, this is the flow that consistently gets us approvals fast.

Prepare the file. Commercial invoice, packing list, PEB export declaration, BL/AWB draft, farm origin statement, and HS classification note. Keep third‑country invoicing documents if used.
Complete the e‑SKA form. Choose ATIGA Form D or RCEP, declare origin criterion “WO,” input HS code, consignee, departure date, and gross/net weights that match the PEB.
Upload clean scans. Ensure the invoice consignee matches the CO. If you use third‑party invoicing, tick the correct box and state the third‑party details.
Respond to clarifications. If an officer asks for a farm statement or proof of non‑manipulation, send it immediately.
Print and share. For e‑Form D and RCEP with QR codes, we share the PDF to the buyer and broker as soon as issued.

How fast can you get a CO for airfreight? With a clean WO file, we often see same‑day issuance, sometimes within 3–6 hours. Plan one business day as a safe norm.

Transshipments, back‑to‑back COs, and third‑country invoicing

We regularly route via Singapore for hub consolidation. Two points matter most.

Back‑to‑back certificates. Both ATIGA and RCEP allow a back‑to‑back CO to be issued by the intermediate member (e.g., Singapore) if the goods don’t undergo processing beyond storage, splitting lots, or labeling. The back‑to‑back CO must reference the original CO, carry the same HS code, and reflect the remaining quantity.
Third‑country invoicing. Malaysia accepts it when properly indicated on the CO. Make sure the exporter, producer, and invoice issuer fields are accurate, and the CO’s third‑party invoice box is completed. We flag it early to the importer’s broker so there are no surprises at clearance.

Takeaway: When transshipping, decide early whether you’ll need a back‑to‑back. It dictates whether you should start with Form D or RCEP depending on the intermediate authority’s comfort.

Timelines, validity, and retroactive issuance

Validity. ATIGA Form D and RCEP certificates are generally valid for 12 months from the issue date.
Retroactive issuance. Allowed in defined circumstances for both agreements. For perishables, we’ve obtained retroactive Form D when the shipment had to depart before the certificate issued. Keep your file airtight.
Malaysia’s acceptance of e‑documents. In our experience, Malaysia Customs accepts ASEAN e‑Form D exchanged via the ASW and QR‑code RCEP certificates. Importers often prefer receiving the PDF early for pre‑declaration.

If your broker requests a paper original, provide the QR‑code version and confirm with them on file sufficiency. Different ports have slightly different habits.

The bottom line: when to use Form D vs RCEP

Use ATIGA Form D when both tariffs are 0% and you want the fastest path in Indonesia’s e‑SKA for WO vegetables.
Choose RCEP when a back‑to‑back via another RCEP member is more straightforward on the importer’s side, or when the buyer’s SOPs prefer RCEP formatting.
Skip the CO entirely if MFN is already 0% and your buyer doesn’t need a preferential claim. Don’t create paperwork that doesn’t deliver value.

In our experience, 3 out of 5 fresh vegetable shipments to Malaysia end up using Form D because the tariff outcome is the same and the issuance flow is slightly quicker. But we’ve also seen RCEP save the day in transshipment cases where the back‑to‑back documentation line‑up was cleaner.

If you want us to sanity‑check your HS code, routing, and certificate choice against your buyer’s preference, Contact us on whatsapp. And if you’re evaluating supply from Indonesia, you can also View our products to see the exact specifications we export, from cucumbers and tomatoes to frozen okra and mixed vegetables.

We’re the Indonesia‑Vegetables Team, and we’d rather help you avoid a 30‑minute delay today than fix a 3‑day problem next week. That’s how we ship vegetables that arrive ready to sell, not ready to argue.