On 2 June 2026, the European Commission adopted Implementing Regulation (EU) 2026/1183 amending Implementing Regulation (EU) 2015/2447 as regards procedural rules on the preferential origin of goods.
This reform is twofold:
- Gradual dematerialisation of proofs of origin
- and enhanced documentary controls on supply chains.
Naturally, the substantive rules for determining origin remain set by the applicable preferential agreements.
The Regulation is expected to apply from 23 December 2027, although certain provisions, such as those related to the definitions, supplier declarations and the deletion of certain Annexes, will not apply until 23 June 2028.
For companies, the challenge is therefore twofold: benefiting from more dematerialised and harmonised procedures, while preparing for reinforced documentary requirements.
An overhaul of the procedures relating to preferential origin
The Regulation introduces new definitions of key concepts such as ‘document on origin’, ‘supplier’, ‘customer’ and ‘originating status’. For instance, the Regulation now defines a ‘preferential agreement’ as ‘a trade agreement by which the Union applies the preferential tariff measures referred to in Article 56(2), point (d) or Article 56(2), point (e) of the Code‘. It also reorganises the provisions related to preferential agreements, the system of registered exporters (the REX system), and the Generalised System of Preferences, known as GSP.
This clarification is mainly formal, but it will require operators to update their internal procedures, document templates, databases and compliance tools.
The creation of the e-PoC system: towards the gradual dematerialisation of proofs of origin
One of the main innovations of the Regulation is the creation of a central system of electronic Proof of origin Certificates, the EU’s e-PoC system.
This system is intended to gradually replace paper certificates, where the relevant preferential agreements allow it. It will ensure the electronic issuance, exchange and verification of proof of origin certificates between Member States and, where applicable, third country partners.
The e-PoC system will be interconnected with national customs systems through the EU Customs Single Window Certificate Exchange System, EU CSW-CERTEX. This interconnection may allow a better flow of data between authorities and may strengthen verifications.
There will be a gradual deployment schedule. Under the pan-Euro-Mediterranean Convention (the PEM Convention), economic operators will have to use the e-PoC system to submit applications for EUR.1 certificates from 26 June 2030, while the customs authorities of the Member States will have to use it to issue these certificates from the same date. The next steps will be the electronic exchange of EUR.1 certificates with the Contracting Parties to the PEM Convention, from 23 June 2032 at the earliest, followed by the automated exchange of information between national customs systems and e-PoC, scheduled from 29 June 2033.
For operators, this development is a major facilitation, but it requires an adaptation of internal processes and better control of the data transmitted to the customs authorities.
Consolidation of the REX system and the GSP
The Regulation consolidates the rules for the registration of exporters in the REX system.
The threshold in principle remains unchanged: non-registered exporters from the EU or from a GSP beneficiary country must register in the REX system to issue certificates of origin when the total value of the originating products in the consignment exceeds €6 000.
However, this threshold does not apply where the preferential agreement concerned requires the use of a document on origin and the REX system, or where the country concerned uses the REX system under its own GSP scheme.
Regarding exporters who are already registered, they will include their REX number in the documents on origin, regardless of the value of the products.
The Regulation also clarifies the procedures applicable to the GSP. Exporters from beneficiary countries will provide the competent authorities with copies or a list of the certificates of origin they have issued. The authorities of the beneficiary countries will have to carry out regular checks on the origin and controls of registered exporters.
The verification procedure is also streamlined: the text removes the distinction between requests based on reasonable doubts and random requests, in favour of an approach based on risk assessment.
Supplier declarations and administrative cooperation: reinforced control of the documentary chain
Suppliers’ declarations may cover a single shipment or several shipments of identical goods. They may also be transmitted after the goods have been supplied and electronically. To facilitate their processing, they should be based on a list of standardised data provided by the Regulation.
This is change is a significant one for industrial companies and groups with complex supply chains. Suppliers’ declarations are a key element of proof of preferential origin when the final product incorporates components or materials from several suppliers.
The Regulation also strengthens administrative cooperation between Member States. The customs authorities of the customer’s Member State may request assistance from the customs authorities of the supplier’s Member State. Where there is no response or where the response is insufficient within 120 days, the supplier’s declaration will be disregarded.
However, this intra-EU cooperation does not exhaust the subject. The Regulation also includes provisions on administrative cooperation with partner countries, specifically within the framework of GSP and preferential agreements, to improve the verification of the declared preferential origin.
In practice, a lack of cooperation or insufficient documentation further up the supply chain could consequently question the granting of preferential origin further down the chain.
Expired documents on origin and inward processing: additional flexibility
The Regulation also extends the possibility of accepting a document on origin after the expiry of its period of validity.
This possibility is not limited to inward processing. It may also cover goods presented to customs before the expiry of the document at the time of their temporary storage or placement under certain special procedures, such as external transit, inward processing, customs warehousing, temporary admission or free zone, provided that the application for preference can be verified and that it is submitted within the period laid down in the Regulation.
Additionally, the text introduces a rule favourable to operators using inward processing. When non-Union goods with a preferential origin are placed under inward processing, the processed product shall, in principle, be deemed to retain that same preferential origin, subject to the exceptions provided for in the text.
These changes offer more flexibility, but they will have to be secured by precise documentation of the placement under the regime, the date of presentation of the goods, the initial validity of the document on origin and the traceability of the processed products.
Practical implications for operators
We recommend operators not to perceive this reform solely as a technical reorganisation of the implementing regulation of the Union Customs Code. It announces a more profound transformation of the management of preferential origin.
Specifically, operators may need to :
- update their internal procedures on preferential origin;
- check the conditions of use of the REX system and the €6,000 threshold;
- adapt their suppliers’ declaration templates;
- anticipate the gradual dematerialisation of proofs of origin via the e-PoC system;
- secure flows involving several suppliers or several Member States;
- strengthen the traceability of documents used in the context of GSP or inward processing.
In practice, this reform reflects a dual logic: to facilitate trade through the dematerialisation and standardisation of procedures, while strengthening the capacity of the customs authorities to control the reality of the preferential origin declared.
For operators, preferential origin is therefore becoming an even more structuring issue for customs compliance. Not only shall the companies be able to produce or collect the relevant documents, but they shall also be ready to demonstrate the reliability of their entire document chain in the event of an audit.