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. 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 a customized supplier declaration when sending LTSDs to customers? If this contains the note (*) = Transitional Rules, check for a chargeable adjustment by AEB.
  
  Example based on a LTSDfC
• Add-on for SAP: Schedule the import of an SAP transport for January 2025. The declaration of origin texts on the invoice will also change with the new PEM rules. If you are using Origin & Preferences together with the add-on for SAP, you will need to import an SAP transport to update it.