Pan-Euro-Mediterranean (PEM): upcoming changes to the preferential rules of origin

At the turn of the year 2024/2025, there were already extensive changes in the area of origin of goods and preferences. These required adaptations of the BEX GENESYS software as well as the cooperation of those responsible in the companies that use this software. 

The changes will continue to affect companies in the EU and Switzerland that use BEX software. Companies in the UK are not affected. The rules will not be changed for countries outside the PEM zone, such as South Korea, Mexico, Japan, and Canada. 

This article is the central location for all currently known and forthcoming specialist information, instructions, and calls to action (as of 10/2025). If you use the GENESYS software, it is essential that you read and implement the following instructions. 

What will change in the GENESYS on January 1, 2026?

  • In BEX’s GENESYS software, only individual agreements have so far been converted to the new rules. As of January 1, 2026, all affected agreements will be converted in the software to the rules of origin of the revised convention.  
  • The changeover takes place as part of a service pack that contains the widget “FTA reform guide”. It will support you step by step with all the necessary adjustments.
    BEX plans to make this available with the December 2025 update. Since there may also be changes on a short notice, stay informed by continuing checking out this site. 
  • For the software operated in the data centre, the service pack will be installed automatically (we will inform you in advance about the exact date). 
  • If you are running GENESYS as an in-house installation, you will need to install the service pack yourself (we will inform you, as usual, as soon as the update will be available) 

What is important for you now? What steps do you need to take? 

Preparation 

  • Clarify the technical questions in advance. Then your administrator, having the necessary preferential expertise, will be well prepared to carry out the change.  
  • Allocate sufficient specialist resources for the execution of the widget, e.g. for rule assignment and, if necessary, the creation of manual list rules. 

Actual changeover 

  • As soon as the widget is provided with the service pack, all data imports and exports from and to GENESYS are interrupted. These are only executed again after the widget has been completely executed for all clients. 
  • An administrator with specialist knowledge must run the widget after the turn of the year. The widget will guide you step by step through the changeover. Work in GENESYS can resume only after the widget has been fully executed in all clients. Also take this into account for substitution situations such as vacation or sick days. 

 

The information provided here is necessary to ensure a smooth transition at the turn of the year. Please note that your cooperation is required to guarantee the smooth running of your business transactions. If you have any questions or require further assistance, please do not hesitate to contact our support team. 

What are PEM and the Regional Convention?

The Pan-European Mediterranean zone of origin (short: Pan-Euro-Med or PEM zone) is a group of countries that have concluded numerous bilateral free trade agreements (FTAs) with each other since 2005, using the same rules of origin and thus creating the basis for the Pan-Euro-Mediterranean cumulation.

It turned out to be difficult to amend a large number of agreements at the same time. The aim was not to jeopardize the system of identical rules of origin. For this reason, the rules of origin were combined into a separate set of rules in 2013 – the so-called Regional Convention. In the free trade agreements, the so-called dynamic reference was henceforth used in the origin protocol, in which the rules for preferential origin of goods are established, to refer to the rules of the Regional Convention. In order to change the rules of origin, the change only needs to be made in the Regional Convention and no longer needs to be implemented in all bilateral preferential agreements. Nevertheless, amendments require confirmation at national level, which is why they cannot enter into force on the exact date.

The contracting parties have agreed on such a change to the rules of origin from January 1, 2025. The Pan-Euro-Med matrix describes which countries from the PEM zone have concluded agreements with each other and are therefore allowed to cumulate. The application of the Regional Convention is indicated by a date with the suffix “(C)”. The use of the revised rules is marked with an “(R)”.

Not all free trade agreements were converted to the Regional Convention (including dynamic reference) by the deadline. Even beyond January 1, 2026, free trade agreements will switch to the new rules.

Section of the Pan-Euro-Med matrix of German customs using Switzerland as an example. (Status: 11/18/2025)

What will change?

Viewed in isolation, the new rules are easier to comply with. The main long-term simplifications coming into force are the following:

  • Increase in general tolerance from 10% to 15%
  • Changes to the content and structure of the list rules, in particular through:
    • Increase in the proportion of permitted non-originating materials depending on the ex-works price; ergo higher percentage
    • Reduction of combination rules
    • Introduction of weight rules
    • Simplifications for the textile and chemical sectors through special procedures, additional textual rules that may apply
    • Many header rules are summarized in the chapter rules; i.e. omission of many ex-rules for HS heading or HS sub-heading
  • Movement certificate EUR-MED and declaration of origin on the invoice EUR-MED are no longer required

As a result of these changes, existing rule assignments must be dissolved and rules reassigned. Accordingly, the calculations and assessments must be carried out again.

When will the rule change come into force?

The new rules came into force on January 1, 2025, as revised rules to the Regional Convention. The agreements to which these rules apply are marked with an “R” in the matrix.
In addition, on December 12, 2024, the Joint Committee of the Regional Convention decided to extend the existing rules of the Regional Convention in addition to other transitional provisions. This means that the previous rules can be used for a further year, provided that the parties to the agreement have ratified these transitional provisions on a national level. The ratification of the transitional provisions pursuant to Decision No. 2/2024 is marked with “CR” in the cumulation options matrix. Agreements that are still based on the old set of rules are marked with a “C” in the matrix.

As of January 1, 2026, the transitional provisions will end and the revised rules of the Regional Convention will apply to agreements that have at least one “R” in the matrix.

Effects on the BEX software and your processes

  •  Until December 31, 2025: If an agreement converts from “C” to “R” without the “CR” marking in the matrix, BEX converts this agreement to the revised rules of the Regional Convention to ensure continued legal compliance. This is necessary because in this case it is unclear when and whether the change to “CR” status will take place before the end of 2025.
    If a changeover takes place, it is delivered by service pack to the agreement reform assistant.
  •  As of January 1, 2026: All agreements that are marked with at least one “R” in the matrix will be converted to the revised rules of the Regional Convention on January 1, 2026. BEX has deliberately chosen this date as LTSDs are typically valid for one calendar year, thus reducing the impact as much as possible.

Update (01/07/2025)

Maintenance of supplier’s declarations for the Regional Convention (PEM)

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.

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 requires national ratification, which is why it had not yet been implemented by all states by January 1, 2025.

In GENESYS, the agreements with Albania and Montenegro for the EU and CH jurisdictions were therefore converted to the revised rules of the Regional Convention as of January 1, 2025. This step cannot be reversed, even if ratification takes place at a later date and the old rules are applicable again. 

Update (12/17/2024)

Effects on the GENESYS software and your processes

EU location:

It is not yet clear which EU agreement partners that already have a reference to the regional agreement can still ratify the agreement by December 31, 2024. It is becoming apparent that a changeover will have to be made for individual EU agreements.

For the EU jurisdiction, the widget for the changeover will be delivered at the turn of the year for at least some agreements.

Switzerland location:

In a notification dated December 16, 2024, the Federal Office for Customs and Border Security (FOCBS) informed that the following agreements have been ratified by Switzerland and that the previous rules will continue to apply temporarily:

  • CH – EU
  • EFTA Convention:
    • North Macedonia
    • Turkey

For the following agreements the situation is not yet clear, but it is likely that the existing rules will continue to apply temporarily:

  • EFTA – Bosnia and Herzegovina
  • EFTA – Georgia
  • EFTA – Albania
  • EFTA – Montenegro

These conditions will not be met for the EFTA-Serbia Agreement, so the revised rules of the Regional Agreement will have to be applied.

For the Swiss jurisdiction, the widget for the changeover will therefore be delivered at the turn of the year, at least for Serbia.

BEX continues to monitor the situation and possible short-term ratifications and announcements for both locations. We will provide a service pack in line with the situation on December 30, 2024. This will include the necessary adjustments. You will be guided through all the necessary steps via a widget.

For the software operated in the cloud, the service pack will be installed automatically. If you are running GENESYS as an on-premises installation, you will need to install the service pack yourself.

Alexander Haun

At BEX, I work in product management. My main areas of focus are export controls, origin of goods, and preferences. I am responsible for the technical articles on these topics on the BEX blog.