Türkiye Implements Revised Pan-Euro-Mediterranean Preferential Rules of Origin (PEM 2023)

What Changed Compared to the Previous Framework

• The Regulation operationalizes the transition from the legacy 2012 PEM rules to the revised 2023 PEM rules, providing a consolidated implementation basis for Türkiye within the PEM system.
• It clarifies key technical pillars such as origin-conferring processing, tolerance rules, insufficient operations, cumulation mechanics, accounting segregation (accounting separation of fungible materials), and proof of origin (EUR.1 and origin declarations).
• It strengthens the procedural structure around electronic issuance, retrospective issuance, duplicate documents, and administrative cooperation / post-clearance verification, aligning operational practice with updated PEM standards.
• It also includes transition arrangements to address shipments and proofs of origin issued under the earlier regime, ensuring continuity under defined time limits.
• The Regulation enters into force on the date of publication and is stated to be effective from 01.01.2025.

Practical Impact for Companies and Required Actions

• Re-validate product origin assessments: Exporters should re-run product-level origin calculations under the revised PEM rules. Assuming that prior (2012-based) analyses remain valid can create preference denial risk.
• Review supply chain and cumulation eligibility: Since cumulation conditions depend on the applicable PEM matrices and partner coverage, companies should confirm that suppliers, processing steps, and sourcing patterns still support preferential origin.
• Upgrade compliance around EUR.1 / origin declarations: Document accuracy, supporting evidence, and retention discipline become more critical as verification mechanisms are reinforced.
• Check “insufficient processing” exposure: Operations such as basic packing, labeling, simple assembly, or minor finishing are generally not origin-conferring. Manufacturing and subcontracting models should be checked to prevent origin challenges.
• Prepare for post-clearance verification: Firms should ensure that internal files can demonstrate origin logic and cumulation conditions, including supplier declarations and production records, to minimize retroactive duty and penalty exposure.

The related legal document