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PEM rules 2026: Challenges and your next steps

Kerstin Graf
  • Updated

Challenges at the turn of the year 2026

Your next steps 

Challenges at the turn of the year 2026

The application of the transitional provisions for 2025 has been gradually ratified by the participating countries at national level since the beginning of the year.

The next major change will take place at the turn of the year 2026 with the end of the validity of the transitional provisions and the changeover of the agreements to the revised rules.

Not all bilateral agreements will switch to the Regional Convention by the end of the year 2025. For the time being, two isolated cumulation zones will therefore continue to be in place. The following cumulations are possible:

  • 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 without a dynamic reference to the Regional Convention, which still use the old PEM rules.

This results in restrictions on cumulation and the granting of preferences.

AEB is keeping an eye on developments, will implement the necessary changes in the software, and will inform you as early as possible. Subscribe to the AEB Help Center article Pan-Euro-Mediterranean (PEM):Changes at the start of 2026 now. This will allow you to stay up to date and make your own active contribution.

Your next steps 

  • 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.
    For a direct comparison of the old and new rules, you can find help in the article PEM rules 2026: Comparing new and old list rules.
    • Note: The "Rule maintenance" step is included in the agreement reform assistant. AEB strongly recommends that you carry this out carefully and do not skip it. Missing rule maintenance can lead to unexpectedly long calculation times. This is not a malfunction of the software.
  • 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 must be evaluated according to the worst-case principle and would therefore also lose their origin.
    Note: In the agreement reform widget, you have the option to keep the evaluations for materials without commodity codes. If you are certain that you do not have any materials from chapters 1-24, you can select this accordingly in the widget. However, this function can only be confirmed for all materials and not for selected materials.

    commoditycode.png
    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 2026. You can already extend these 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.
  • 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 has taken place with the November 2024 service pack.
    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.  
    If you use the add-on for SAP from AEB, you do not need to take action regarding the threshold file. This applies to both version 2.3 and version 3.0.
  • Add-on for SAP: Schedule the import of an SAP transport for January 2026.  
    If you are using Origin & Preferences with the add-on for SAP version 2.3, you will need to import an SAP transport to update it. This contains the necessary adjustments to the texts, such as the origin texts on the invoice or the new texts for the changed threshold file. You can check the version used with transaction /n/AEB/CONSISTENCY.  Find more information in the article Origin & Preferences Add-on for SAP® and the widget in O&P: Recommendations for how to proceed
  • Note: This transport only includes new texts, not a function update and therefore NO complete update of the AEB add-ons for SAP is required.  

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