Turkey Updates Pan-Euro-Mediterranean Preferential Rules of Origin Regulation (Effective 1 January 2026)

Why this matters for foreign exporters / importers to Türkiye:

The clarified scope of application removes ambiguity on which FTAs are covered, directly affecting eligibility for preferential tariffs as of 1 January 2026.
Cumulation eligibility must now be checked against Türkiye’s officially published table, not only Annex V, increasing the risk of preference denial if outdated matrices are used.
Exporters relying on multi-country sourcing under PEM may need to reconfigure supply chains to remain preference-compliant.
Incorrect cumulation application can trigger post-clearance preference denial, duty recovery, and penalties, even where origin logic appeared valid under prior practice.
Contract pricing and origin representations should be reviewed and updated to reflect the revised PEM framework and national implementation rules.

Turkey has published an amending regulation to the Regulation on Preferential Rules of Origin within the Scope of the Pan-Euro-Mediterranean (PEM) Regional Convention, as announced in the Official Gazette dated 31 December 2025, No. 33124

The amendment aligns the domestic regulatory framework with the revised PEM Regional Convention, as adopted by the PEM Joint Committee Decision No. 1/2023, which was approved by Türkiye through Law No. 7556 and Presidential Decision No. 10694.

Main Content of the Amendment

The regulation introduces two key changes:

1. Updated Scope of Application (Article 2)

Article 2 of the original regulation has been fully revised to clarify how the amended PEM Convention rules will be applied by Türkiye in its preferential trade relations.

The amended article explicitly lists the Free Trade Agreements and protocols under which the revised PEM rules will apply, including agreements between Türkiye and:

The Faroe Islands (via Denmark)
EFTA States
The European Union (including agricultural products and ECSC-origin goods)
Bosnia and Herzegovina
Morocco
Palestine
Georgia
Montenegro
Kosovo
North Macedonia

By doing so, the amendment provides legal certainty on which bilateral and multilateral trade frameworks are covered by the updated PEM origin rules.

2. Clarification on Cumulation Tables (Article 10/13)

Article 10(13) has been amended to specify that, for Türkiye, the application of cumulation provisions will be based on the official table published on the Ministry of Trade’s website.

While Annex V tables continue to show cumulation possibilities among PEM Contracting Parties, the nationally announced table will be decisive for implementation in Türkiye. This change emphasizes operational clarity and administrative control in the application of cumulation.

Entry into Force

The amendment enters into force on 1 January 2026.
From this date onward, preferential origin determinations under the PEM system must be assessed in line with the revised convention and the updated national regulation.

Practical Implications

Exporters and importers using PEM preferential tariffs must reassess their origin calculations and cumulation strategies as of 2026.
Companies should verify:
Incorrect application of cumulation may lead to loss of preferential treatment and post-clearance risks.

Overall, the amendment strengthens the alignment of Türkiye’s preferential origin regime with the modernized PEM framework, while providing clearer guidance on how cumulation rules are to be applied in practice.

See related legislation document

Turkey Amends Regulation on Pan-Euro-Mediterranean Preferential Rules of Origin (Effective 1 January 2026)