PEM rules 2025: Challenges and your next steps

Challenges at the turn of the year

Your next steps until the official decision in mid-December

Challenges at the turn of the year

Not all bilateral agreements will switch to the Regional Convention (new PEM rules) by the end of the year. This would result in two isolated cumulation zones:

• On the one hand, the agreements among each other in accordance with the matrix for the revised Regional Convention (new PEM rules)
• On the other hand, the bilateral agreements that still use the old PEM rules.

This would result in restrictions on cumulation and the granting of preferences for merchandise.

According to the publication (only in German) by the Swiss Federal Office for Customs and Border Security (BAZG), there is therefore probably an agreement in principle on transitional provisions that have yet to be officially adopted.

These transitional provisions provide, among other things, that:

• the new PEM rules will come into force on January 1, 2025 as planned and
• the old PEM rules will still apply as transitional provisions until December 31, 2025.

The official decision of the Joint Committee of the PEM Convention is not expected until mid-December and must be unanimous. In addition, the application of the transitional provisions must still be ratified by each participating country in the national procedure. It is therefore not certain that the transitional provisions will actually take effect for all participating countries as early as January 1, 2025.

AEB will plan for the different scenarios, implements the changes in the software, and will inform you as early as possible. Subscribe to the article Pan-Euro-Mediterranean (PEM): Change at the start of 2025 in the AEB Help Center. This will allow you to stay up to date and make your own active contribution. 

Your next steps until the official decision in mid-December

• List rules: Compare new and old list rules for your main products on wup.zoll.de.
  This will give you an insight into the rules that you will use for calculation in the future and enable you to assess the impact of the changes. Also check here whether you will still need manually created rules in the future. You may change the browser language for an automatic translation.
  For a direct comparison of the old and new rules, you can find help in the article PEM rules 2025: Comparing new and old list rules.
• Customs tariff numbers: It is essential to maintain the customs tariff numbers in the materials; the specification of a chapter is sufficient. As there is no permeability between the two regulatory systems for goods in the agricultural and food sector (goods in chapters 1-24), these materials will lose their origin. All materials for which you have not maintained a customs tariff number are evaluated according to the worst-case principle and therefore also lose their origin.
  Please note: In widget which AEB will provide in the application, you have the option of not deactivating the ratings for materials without commodity codes. If you know for sure that you do not have any materials in chapters 1-24, you can select this accordingly in the widget.
  
  
  Material overview: which Comm. codes?
  
  In this context, we would also like to point out that we will still not support weight rules for automated calculation in the future.
• Issuing long-term supplier's declarations:
  • For all goods from chapters 1-24, do not issue an LTSD until 2025. You can already extend issued LTSDs in preparation. However, do not send these until after the turn of the year and after the changeover of Origin & Preferences. This will reduce the number of revocations considerably.
  • For all goods from chapters 25-97, you can already extend and issue the LTSD today due to the permeability regulation.
• Customized forms: Do you use customized forms with changes in the supplier declaration when sending LTSDs to suppliers and/or customers?

  If you are not sure, we ask you to check whether adjustments have been made to the LTSD. You are responsible for maintaining the customized forms. Changes to your customized forms and documents are therefore not automatically made by us and delivered with a service pack. 
  

  Prepare yourself in case the decision is made in mid-December that an LTSD/LTSDfC must contain an additional text with a reference to the rule set used ((RR) = REVISED RULES). Other forms are not affected (e.g. Supplement to the long-term suppliers’ declaration ARTLIST_SU_DE_XLS).
  If you are still using these forms, please place an order with AEB for the chargeable adjustment. For a corresponding quotation, please contact the Support team via this link. If it turns out that the adjustment is not necessary, the order will be canceled.
  Note: The standard documents are available to you in any case. The implementation of adjustments must be planned in advance at AEB.

• New version of threshold file: The "FTA reform" field has been added to the threshold file for export to your host system and the interface has been adjusted. This field makes it possible to control the text selection for the declaration of origin if other countries join the Regional Convention on short notice. Delivery takes place with the November 2024 service pack.

  If you use the add-on for SAP from AEB, you do not need to take action now. This applies to both version 2.3 and version 3.0.

  If you use the add-on for SAP in version 2.3, import the transports provided at the beginning of January so that the new texts are available to you.

  If you use a host system other than SAP to determine the original declaration text for the destination country based on the threshold file, it is advisable to check and, if necessary, adjust the implementation.

• Add-on for SAP: Schedule the import of an SAP transport for January 2025.
  If you are using Origin & Preferences together with the Add-on for SAP, you will need to import an SAP transport to update it. This contains the necessary adjustments, such as the origin declaration texts on the invoice or the new texts for the changed limit value file.