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.
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Notes: 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. According to the German customs authority's technical notice dated January 16, 2026, preferential certificates containing the note “revised rules” must be accepted even if the note is no longer required.
For supplier declarations issued retrospectively for 2025, the addition “RR” is still mandatory, provided that the proof was issued under the Revised Rules. In the Origin & Preferences software, supplier declarations will therefore generally continue to include the “RR” reference until the end of 2026.
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 in the article Pan-Euro-Mediterranean (PEM): Changes at the start of 2026.
Furthermore, there are still multiple agreements that do not yet implement the regional agreement and will therefore not be changed automatically 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 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. The labeling requirement still applies for 2025 if the preferential status has been determined in accordance with the revised rules of the Regional Convention.
Issue date before 2026 without reference
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 the supplier's declaration for those countries that have not yet converted and only for goods in chapters 25-97 of the Harmonized System.
Issue date before 2026 with reference to revised rules
If a supplier's declaration for a validity period that lies in 2026 is already issued in 2025 and contains a reference to "revised rules", check whether this reference also applies to 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 reference to the revised rules, but which apply the revised rules from January 1, 2026, only within the scope of permeability (see above).
In general, AEB recommends maintaining supplier’s declarations, especially for goods of chapters 1-24 with a validity period in 2026 based on revised rules only after the changeover (i.e. after January , 2026) and then specifying January 1, 2026, as the date of issue.
Issue date from January 1, 2026
For supplier’s declarations issued from January 1, 2026, you do not need to consider any special requirements. In general, the obligation to refer to a specific rulebase no longer applies, as exactly one rulebase applies for a destination country. If you are unsure whether your supplier is already applying the revised rules of the Regional Convention, you should ask. This applies in particular to goods that are not covered by permeability.
To this end, AEB will temporarily keep the reference to the revised rules on the supplier’s declarations. This is additional information and does not affect the validity of supplier’s declarations.