At the policy level, the complex Rules of Origin (RoO), and the associated
Certificate of Origin (CoO), in the implementation of ASEAN-led FTAs are also seen
as burdensome by the region’s MSMEs. For example, the relatively high regional
value content, which stands at about 40 percent in most ASEAN-led FTAs (refer to
Table 2), is difficult for many MSMEs to comply with. This is not to mention high
administrative costs attached to the compliance requirement to prove a product’s
country of origin. In addition, multiple and often overlapping FTA commitments by
the AMS often generates confusion among MSMEs. These also make many ASEANled
FTAs redundant. It has been suggested that divergent RoOs across different
FTAs is likely to fragment, rather than integrate regional markets (Tran Ba Cuong,
2012: 11). Traders are also likely to face higher administrative and production costs.
All these constraints eventually lead to the low utilization rates of ASEAN-led FTAs.