Paneuromed area: a new matrix to apply cumulation of origin

The Pan-Euro-Mediterranean Area (PEM) is based on a network of free trade agreements between the European Union and its partners, based on common rules of origin. This framework allows participating countries to use materials or components from other States in the area while obtaining preferential origin, even if local processing does not fully meet the criteria of the applicable agreement. This mechanism is the cumulation of origin.

This principle already exists in EU bilateral agreements: a French manufacturer can, for example, integrate components originating in Norway and consider them as originating in the EU for preferential treatment.

The objective of the NAPEUROMED area is to extend this system to all participating countries in order to create a dynamic and integrated economic zone, now comprising the 27 EU Member States and 23 other countries.

In order for cumulation to function fully, all countries must adopt and apply the same rules of origin in their agreements by the end of the year. The European Commission has put in place a matrix to verify, country by country, the possibilities of cumulation of origin according to the progress of integration of modernised rules.

The Official Journal of the EU C/2025/6212, containing the updated matrix, highlights the latest evolution: since October 2, 2025, Morocco applies modernised rules of cumulation of origin, but only for its trade with the EU. However, this progress remains partial, and the matrix still reveals many pending adjustments, even though the transitional measures are to be completed on 31 December 2025.

For an overview of the regional convention, the Administrative Notes and Notes are available on the dedicated page of customs.

For your specific business cases, our experts are at your disposal to assist you, analyse your situations and help you manage this subject safely.

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