The reform of the Regional Convention is currently creating more and more ambiguity in preferential law. Particular care is required if you maintain supplier’s declarations for agreements in the pan-Euro-Med cumulation zone.
Note: The transitional provisions only apply until December 31, 2025. From January 1, 2026, there will only be one applicable agreement for a destination country in the Pan-Euro-Med cumulation zone. It is therefore no longer legally necessary to indicate whether the Revised Rules apply – even if such indications are still unobjectionable, as they merely constitute supplementary information.
Possible variants for the maintenance of supplier’s declarations in 2025
Possible variants for the maintenance of supplier’s declarations in 2026
Short overview of the reform
With Resolution 1/2023 of December 7, 2023, the rules and regulations of the Regional Convention were to be completely replaced by a new set of rules from January 1, 2025. However, on December 12, 2024, the previous set of rules was extended for an additional year as an alternative by Resolution 1/2024 of the Joint Committee of the Regional Convention. However, this resolution had to be ratified nationally by the individual states. Therefore, it was not implemented for all countries on January 1, 2025.
In Origin & Preferences, individual agreements have been converted to the revised rules of the Regional Convention since January 1, 2025. This step cannot be reversed, even if ratification takes place at a later date and the old rules are applicable again. You can read more about this in the Help Center under Pan-Euro-Mediterranean (PEM): Changes at the start of 2026.
Furthermore, there are still agreements that do not yet implement the regional agreement and will therefore not be changed to the revised regulations. From January 1, 2026, this will mean that two cumulation zones will have to be taken into account for preference determination in the future.
Possible variants for the maintenance of supplier’s declarations in 2025
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Supplier’s declarations without remarks
These are interpreted as calculated according to the old rules of the Regional Convention and may be adopted as confirmed agreements for all listed agreements that have not been converted in Origin & Preferences. Agreements that have already been converted in Origin & Preferences can be recognized by the addition in brackets (RR) in the “Agreements” pop-up when maintaining the “Confirmed agreements” field. Special regulations apply to these, as the permeability of the old rules to the new rules only applies in simplified form to goods from Chapter 25-97 of the Harmonized System and, according to the previous application of the law, only to supplier’s declarations on which “no cumulation applied” was confirmed. This will be easier in the future. The EU Commission is currently revising the legal provisions for the maintenance of supplier’s declarations in the Union Customs Code (UCC).
Practical implications: Only maintain supplier’s declarations for countries with converted agreements if they confirm “no cumulation applied” and the items are goods of chapters 25-97 of the Harmonized System.
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Supplier’s declarations with remark for confirmed transitional rules
Agreements for which the transitional rules have been confirmed may continue to be used for cumulation with the revised rules.
Practical implications: Maintain these supplier’s declarations only for agreements outside the PEM zone (e.g. Canada, Japan, or Chile) and the agreements that have already been converted, which are displayed with added (RR) in the “Agreements” pop-up under “Confirmed agreements”.
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Supplier’s declarations with REVISED RULES remark
Agreements for which the “REVISED RULES” remark has been confirmed may only be used for cumulation with the revised rules. Therefore, check whether the remark applies to all potential countries in the PEM zone or only to individual countries. You will often find information about this in footnotes or other remarks.
Practical implications: Maintain these supplier’s declarations as usual for the agreements outside the PEM zone (e.g. Canada, Japan, or Chile) and for the agreements already converted in Origin & Preferences. These can be recognized by the added (RR) in the “Agreements” pop-up under “Confirmed agreements”. Agreements from the PEM area that have been issued on this declaration according to the old rules – you can recognize this by the different remarks – can also be maintained as confirmed agreements.
Possible variants for the maintenance of supplier’s declarations in 2026
Even if there will only be one set of rules per destination country in 2026, the maintenance of long-term supplier’s declarations will still require care. Pay particular attention to the date of issue.
If a supplier’s declaration for a validity period that lies in 2026 has already been issued in 2025 and does not contain any reference to "Revised Rules", it will only continue to be valid for 2026 within the scope of permeability.
Practical implications: Only maintain supplier’s declarations for countries with converted agreements if they confirm “no cumulation applied” and the items are goods of chapters 25-97 of the Harmonized System.
If a supplier's declaration for a validity period that lies in 2026 is already issued in 2025 and does contain the note "Revised Rules", check whether this note also applies and has been confirmed for all agreements that actually apply the revised rules in 2026. If this is not the case, maintain the materials for countries without a Revised Rules note, but which apply the Revised Rules from January 1, 2026, only within the scope of permeability (see above).
For supplier’s declarations issued from January 1, 2026, you do not need to consider any special requirements. If you are unsure whether your supplier is already applying the revised rules of the Regional Convention, you should ask. This is especially important for products not covered by the permeability.
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