The European Union has introduced a major reform of the procedural rules on the preferential origin of goods, bringing significant changes to the Registered Exporter system (REX), documents on origin, supplier’s declarations and the future electronic management of proofs of origin.
Commission Implementing Regulation (EU) 2026/1183 of 2 June 2026 amends Implementing Regulation (EU) 2015/2447 and introduces a phased modernisation of the EU preferential origin framework.
The reform seeks to harmonise procedures across Member States, reflect the increasing use of the REX system under EU preferential trade arrangements and accelerate the digitalisation of the management and verification of proofs of origin.
Most of the new provisions will apply from 23 December 2027, while important changes concerning supplier’s declarations will apply from 23 June 2028. A further stage will begin from 2030 with the gradual implementation of the electronic Proof of Origin Certificate system, known as e-PoC.
New rules on the preferential origin of goods from December 2027
The first major phase of the reform will apply from 23 December 2027.
The Regulation introduces common definitions intended to provide greater consistency in the application of preferential origin procedures across different EU trade agreements.
A document on origin is defined as a document by which a competent authority, exporter or re-consignor declares that a product is considered originating for the purposes of a preferential agreement.
A preferential agreement, meanwhile, refers to a trade agreement under which the European Union applies preferential tariff measures provided for under the Union Customs Code.
These common definitions form part of a broader restructuring of the rules governing preferential origin within the EU customs framework.
Changes to the REX system for registered exporters
One of the most significant areas affected by the reform is the Registered Exporter system (REX).
The new rules update the procedures governing applications, registration and electronic management of exporters and re-consignors established in the European Union, as well as exporters established in third countries where the REX system is used.
The reform also strengthens administrative cooperation between the European Commission, Member States and beneficiary or partner countries.
A particularly important change concerns the use of the REX number on documents on origin.
Registered exporters will be required to indicate their REX number on the documents on origin they issue for originating products irrespective of the value of the consignment.
This means that once an exporter is registered in REX, the identification number will have to be consistently included in the relevant origin documentation.
The €6,000 threshold for non-registered exporters remains
The Regulation generally maintains the possibility for exporters that are not registered in REX to issue a document on origin where the value of the originating products in the consignment does not exceed €6,000.
However, this threshold will apply only where the relevant preferential agreement does not provide otherwise.
Where a preferential trade agreement between the EU and a third country expressly requires exporters to include an identification number regardless of the value of the goods, no value threshold will apply.
Companies should therefore continue to check the specific provisions of the preferential agreement used for each transaction instead of relying solely on the general €6,000 rule.
Replacement of documents on origin within the EU
The reform also establishes clearer rules for the replacement of documents on origin within the European Union.
Where originating goods have not yet been released for free circulation and remain under customs supervision in the customs territory of the Union, an existing document on origin may under the applicable conditions be replaced by one or more replacement documents.
This mechanism can be particularly relevant when consignments are divided, redistributed or re-consigned within the EU before being released for free circulation.
Registered exporters and re-consignors will therefore need to ensure that replacement statements on origin comply with the new procedural requirements.
Acceptance of expired documents on origin
The new preferential origin framework also provides for the possibility of accepting documents on origin after their normal period of validity has expired, subject to the conditions laid down in the Regulation.
This may provide additional flexibility where an origin document could not be submitted within its normal validity period for justified reasons.
However, acceptance is not automatic. Importers must be able to demonstrate that the relevant conditions for the late presentation of the proof of origin have been met.
Preferential origin and inward processing
Commission Implementing Regulation (EU) 2026/1183 also regulates the preferential origin of processed products obtained under the inward processing procedure.
This is particularly relevant for companies that import goods with preferential origin into the EU for processing before the resulting products are released for free circulation.
Under the conditions established by the Regulation, processed products obtained from goods with preferential origin may retain the relevant preferential origin treatment.
Companies using inward processing should therefore consider the new rules as part of their origin and customs compliance procedures.
Accounting segregation and preferential origin rules
The Regulation also harmonises the way in which certain options contained in EU preferential agreements are applied within the Union.
Where a preferential agreement provides the possibility of requiring prior authorisation to use accounting segregation, such prior authorisation will not be required in the European Union.
Accounting segregation can be particularly important where originating and non-originating fungible materials are stored together and physical segregation would be difficult or commercially impractical.
Businesses using this mechanism must nevertheless ensure that their records and internal controls allow them to demonstrate compliance with the applicable origin rules.
Documents on origin for multiple consignments
Where a preferential agreement allows a single document on origin to cover multiple consignments of identical products, the European Union will accept this mechanism in accordance with the provisions of the relevant agreement.
This can simplify origin management for businesses involved in regular supplies of identical products over a given period.
The precise requirements, validity period and conditions will continue to depend on the preferential agreement concerned.
Preferential tariff treatment based on importer’s knowledge
The reform also expressly addresses claims for preferential tariff treatment based on importer’s knowledge.
Where this possibility is provided for in the relevant preferential agreement, such claims will be accepted in the European Union in accordance with the terms of that agreement.
Importer’s knowledge allows an importer to claim preferential tariff treatment on the basis of information in its possession demonstrating that the imported products qualify as originating.
This mechanism places particular responsibility on the importer, which must have sufficient supporting information available to demonstrate compliance with the applicable rules of origin if requested by customs authorities.
Exporter signatures on documents on origin
The Regulation also harmonises the requirements relating to exporter signatures.
Where a preferential agreement allows the exporter’s signature on a document on origin to be waived, the signature will not be required in the European Union.
This prevents additional procedural requirements from being imposed at EU level where the applicable preferential agreement already provides for such a waiver.
Changes to the Generalised Scheme of Preferences
The first phase of the reform also updates the procedural rules applicable to the EU’s Generalised Scheme of Preferences (GSP).
The changes cover areas including:
- Statements on origin
- Obligations associated with the REX system
- Verification of preferential origin
- Administrative cooperation
- Circumstances in which preferential tariff treatment may be refused
These amendments reflect the transition towards self-certification through the REX system and the increasing digitalisation of preferential origin procedures.
New supplier’s declaration from 23 June 2028
A second major phase will apply from 23 June 2028 and will significantly change the current supplier’s declaration framework.
The new supplier’s declaration will be based on a set of standardised and coded data elements designed to facilitate electronic exchange and processing between suppliers, customers and customs authorities.
The reform aims to make origin information easier to transmit through increasingly digital supply chains while also improving its traceability and verification.
New information required in supplier’s declarations
The new framework introduces definitions for the supplier, the customer and the originating status of goods for the purposes of supplier’s declarations.
In addition to the information already required under the current system, the future declaration will contain additional data elements relating to matters such as:
- The customs authority responsible for verification
- The customs representative, where the declaration is completed by a representative
- Details of any cumulation applied
- Concerning the use of accounting segregation for originating and non-originating fungible materials
This will increase the level of detail businesses need to retain and communicate throughout their supply chains.
Companies using supplier’s declarations to support the preferential origin of exported products should therefore review whether their ERP, customs and product-master data systems can capture the information required under the new framework.
New verification procedure for supplier’s declarations
The Regulation introduces a new procedure for the verification of supplier’s declarations.
The customs authorities where the supplier is established will be able to verify the declaration.
In addition, where a supplier and customer are established in different Member States, the customs authorities where the customer is established may request assistance from the authorities responsible for the supplier.
The verification procedure will have a maximum duration of 120 days.
If no reply is received within that period, or if the information supplied is insufficient to confirm that the supplier has complied with the applicable requirements, the supplier’s declaration under verification will not be taken into account when determining the originating status of the goods concerned.
INF 4 certificate to be abolished
The introduction of the new supplier’s declaration verification procedure will also result in the abolition of the INF 4 information certificate.
The existing documentary mechanism will therefore be replaced by the new framework for direct administrative cooperation between customs authorities.
This change forms part of the broader transition towards electronic customs processes and more direct exchanges of information between authorities in different Member States.
Easier access to approved exporter authorisation
The reform also modifies the conditions for obtaining approved exporter authorisation.
The current requirement for an exporter to make frequent consignments of products originating in the European Union will be removed.
Instead, it will be sufficient for at least one of the countries to which the company exports to have a preferential agreement with the European Union that provides for the possibility of using approved exporter status.
This change may make approved exporter authorisation accessible to a broader range of businesses that make less frequent but commercially significant preferential exports.
The e-PoC system will digitalise proofs of origin
The third stage of the reform will begin from 2030 with the gradual introduction of the EU electronic Proof of Origin Certificate system (e-PoC).
The system is designed to support the electronic issuing, presentation, management and verification of documents on origin, as well as the associated administrative cooperation between customs authorities.
One of its first major applications will concern the EUR.1 movement certificates used under the Regional Convention on pan-Euro-Mediterranean preferential rules of origin, commonly known as the PEM Convention.
The e-PoC system represents an important step towards the digitalisation of preferential origin documentation, reducing reliance on paper certificates and facilitating exchanges between customs administrations.
EUR.1 certificates and e-PoC from 2030
From 26 June 2030, EU customs authorities will use the e-PoC system, or interconnected national systems, for certain administrative cooperation procedures within the European Union, including the verification of documents on origin and supplier’s declarations.
The Regulation also provides for the electronic exchange of EUR.1 movement certificates with contracting parties to the PEM Convention once the necessary arrangements are in place.
This cross-border electronic exchange will be introduced progressively and, under the Regulation, cannot begin before 23 June 2032.
Companies using EUR.1 certificates under the PEM Convention should therefore monitor the gradual rollout of e-PoC and prepare their customs procedures for the transition towards electronic proofs of origin.
Key dates for the new preferential origin rules
Businesses involved in preferential trade should include the following dates in their customs compliance planning:
- 23 December 2027: most of the new procedural rules on preferential origin and the updated REX provisions become applicable.
- 23 June 2028: the new supplier’s declaration framework and associated verification procedures become applicable.
- 26 June 2030: use of e-PoC begins for certain EU administrative cooperation procedures.
- From 23 June 2032 at the earliest: electronic exchanges of EUR.1 certificates with PEM contracting parties may progressively begin where the relevant agreements provide for them.
The phased timetable gives companies time to prepare, but the scale of the changes makes an early review of internal preferential origin processes advisable.
How importers and exporters should prepare for the new origin rules
The changes introduced by Regulation (EU) 2026/1183 will affect companies throughout international supply chains, from suppliers providing origin information to exporters issuing proofs of origin and importers claiming preferential tariff treatment.
Businesses should review in particular:
- Their procedures for determining preferential origin
- Use and management of REX numbers
- Socuments on origin issued to customers
- Supplier’s declarations and supporting evidence
- Cumulation procedures
- Accounting segregation arrangements
- Approved exporter authorisations
- Document-retention procedures
- IT systems used to manage origin information
Preferential origin can result in significant customs-duty savings, but incorrect or insufficient supporting documentation may lead to preferential treatment being refused or subsequently withdrawn.
Customs advice on preferential origin, REX and proofs of origin
The reform of the preferential origin of goods represents an important move towards a more harmonised, traceable and digital customs environment in the European Union.
The changes to the REX system, the new supplier’s declaration and the gradual deployment of e-PoC will require many businesses to review their customs and origin-management procedures over the coming years.
Arola’s customs department remains available to assist companies with preferential origin rules, REX registration and use, supplier’s declarations, approved exporter authorisations and the customs requirements arising from EU preferential trade agreements.
