PEM rules of origin from 2026 – new rules for importers and exporters in the PEM zone
From 1st January 2026, different rules of origin will apply to trade with PEM countries. The changes result from the Regional Convention on Pan-Euro-Mediterranean Preferential Rules of Origin (PEM), which covers 25 countries and aims to facilitate international trade and the integration of European and Mediterranean supply chains.
The new rules pose significant challenges for import and export companies, particularly in terms of correctly determining the origin of goods and taking advantage of customs preferences.
PEM zone – which countries does it cover?
The PEM zone includes, among others:
- the European Union,
- EFTA countries: Switzerland, Norway, Iceland and Liechtenstein,
- the Faroe Islands,
- the Barcelona Process countries: Algeria, Egypt, Israel, Jordan, Lebanon, Morocco, Palestine, Syria, Tunisia and Turkey,
- the Western Balkan countries: Albania, Bosnia and Herzegovina, North Macedonia, Montenegro, Serbia and Kosovo,
- Moldova, Georgia and Ukraine.
Different rules of origin regimes in the PEM zone
From 2026, not all PEM zone countries will apply the same rules of origin. In practice, this means that several regimes will operate in parallel:
- classic PEM rules,
- transitional rules,
- revised PEM rules.
The diversity of regimes increases the risk of errors in documents of origin and incorrect application of tariff preferences.
EUR.1 document and different rules of origin
The EUR.1 document does not always mean the same rules of origin regime. Depending on the country and the rules in force, it may confirm the origin determined according to different PEM rules.
Errors in the declaration of origin may result in:
- withdrawal of customs preferences,
- the obligation to pay additional customs duties,
- corrections to customs settlements,
- the risk of disputes with customs authorities.
Key obligations of importers and exporters
To avoid legal and financial risks, companies should pay particular attention to:
- identifying the applicable rules of origin regime,
- correctly verifying the origin of goods,
- correctly issuing documents of origin (EUR.1, invoice declaration or other documents),
- proper transmission of data to the customs agency together with the HS code,
- complete documentation of the origin of goods for possible inspection.
Operational recommendations for companies
Before shipping goods or clearing customs, companies should:
- check which rules of origin regime applies (Revised Rules, Transitional Rules or classic PEM),
- verify the origin of the goods in accordance with the applicable rules,
- prepare the correct document of origin,
- ensure that the documentation is complete for inspection purposes,
- consult experts in customs law and international trade.
Impact of PEM changes on international trade
Changes in PEM rules of origin may affect:
- the possibility of benefiting from customs preferences,
- import and export costs,
- customs clearance times,
- supply chain stability.
Proper preparation of companies allows for the reduction of operational and financial risks associated with the new PEM rules.
ADECON experts support importers and exporters in analysing rules of origin, verifying documents, and implementing procedures in accordance with applicable regulations.