National content requirements ECA explained

National content requirements ECA programmes use domestic content rules to link official support to home-country goods, services and intangibles. National content requirements are national eligibility and quantum rules. They sit beside, and are distinct from, OECD Arrangement limits on maximum official support and local costs. UKEF and US EXIM publish detailed content policies that illustrate how two Participants operationalise the concept.

National content requirements ECA eligibility logic

An export credit agency exists to support national exports. Content policy defines what counts as national content, what counts as foreign content, and how much foreign content may ride inside a supported contract. Content rules apply most clearly to contract-specific products where an export contract links the supported exporter to the buyer or borrower. Non-contract-specific products may use a separate exporter test, as UKEF states for products outside contract-specific support.

UKEF's published approach is principles-based. Principle One sets a maximum level of support for all foreign content at 80% of the contract value, requiring a minimum 20% UK content. UK content is the contractual value of qualifying goods, services and intangibles from the UK, defined as total contract value minus foreign content. Valid UK content includes goods eligible for a UK country-of-origin certificate, services supplied from the UK, and intangible assets originating in the UK. Profit margin alone without UK processing or services is not treated as UK content.

US EXIM's medium- and long-term content fact sheet states that EXIM relies on US content as a proxy to evidence support for US jobs. Eligible goods and services in a US export contract must be shipped from the United States to a foreign buyer. The total level of support for an export contract is generally the lesser of 85% of the value of all eligible goods and services in the US export contract, or 100% of the US content in all eligible goods and services in that contract. Goods produced entirely in a foreign country other than the buyer's country may be eligible foreign content if shipped from the United States under EXIM's stated tests. Transshipped goods through the United States, including entry through a bonded warehouse, are excluded goods and are not eligible foreign content.

How UKEF principles two and three operate

Where Principle One is not met, UKEF may apply Principle Two. The 80:20 proportions then apply to the value of UKEF's support for a contract or a project that may consist of multiple contracts. Principle 2A allows support sized on a multiple of UK content within a single contract (illustrated as up to 85% of five times UK content). Principle 2B allows account to be taken of UK content in related contracts or an overall project where financing one contract unlocks UK supply elsewhere in the project.

Principle Three allows support where the proposal is conducive to supporting or developing UK exports, potentially with incentivisation mechanisms linked to future UK supply-chain spend, production or jobs. Decisions under Principle Three rest on UKEF's determination of a justifying statement by the applicant. Content requirements for contract-specific products therefore form a sequenced eligibility ladder rather than a single binary threshold.

UKEF may include documentation provisions and audits to assess consistency with UK content proposed at underwriting. For overseas applicants, UK content is the cost of purchasing goods, services and intangibles supplied under the contract by UK exporters and sub-contractors carrying on business in the UK. Brass-plate arrangements without genuine UK economic activity are not treated as UK content.

How US EXIM content limits support quantum

EXIM support for individual disbursements is based on aggregate US and foreign content percentages in an up-front Exporter's Certificate, irrespective of the relative amounts in any specific shipment request. Material changes in foreign content from the up-front certification must be notified, and future disbursements adjusted so that only the value of the US content is supported.

For transactions in Congressionally defined Transformational Export Areas, EXIM may provide full financing as allowed by the OECD Arrangement if the proposed transaction is at least 51% US content. For such transactions, all content of People's Republic of China origin is deemed ineligible for EXIM financing. Where the Arrangement allows deviations from the standard 15% cash payment, EXIM may support more than 85% of the net contract price if the transaction is at least 85% US content.

OECD Arrangement interaction

The Arrangement does not set a national content percentage. Article 11 caps official support at 85% of the export contract value, including third-country supply but excluding local costs, and separately permits official support for local costs under Category I and Category II caps. National content policy decides whether and how far an ECA will cover third-country supply inside that Arrangement envelope.

Local costs (goods and services in the buyer's country necessary to execute the exporter's contract or complete the project) are Arrangement local-cost support, not national content. National content is home-country value-add. Foreign content is third-country supply outside the supporting ECA's home base. Mixing the three categories in a credit paper without labels produces eligibility errors.

Content versus local costs and third-country supply

Credit applications should present four buckets separately: national content, eligible foreign (third-country) content, ineligible foreign content, and local costs in the buyer's country. National content drives ECA eligibility and support quantum under national policy. Eligible foreign content may be financed inside the Arrangement 85% export-contract envelope where the ECA's content rules allow. Local costs follow Article 11 Category I and II caps and are excluded from export contract value. Ineligible foreign content (for example EXIM excluded goods not shipped from the United States, or content that fails a national origin test) remains outside official support.

UKEF may audit UK content against underwriting expectations. EXIM adjusts future disbursements when material foreign-content changes occur relative to the Exporter's Certificate. Both practices treat content as a continuing compliance matter, not only an application-time representation.

Desk reading

Content schedules in applications should separate national content, eligible foreign content, ineligible foreign content and local costs. UKEF's 20% UK content Principle One and EXIM's lesser-of-85%-or-100%-of-US-content rule are national policy choices inside Arrangement maximum support. Other ECAs publish their own thresholds and definitions. Arrangement compliance on down payment, maximum support and local costs remains a separate checklist from national content eligibility.