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Call for evidence outcome

Pan-Euro Mediterranean Convention on Rules of Origin (PEM): call for evidence

Updated 26 March 2026

This was published under the 2024 to 2026 Starmer Labour government

Introduction and guidanceÌý

This government wants to find concrete ways to make it easier for UK businesses to trade with our international partners.

One of the major barriers to increasing trade in goods is rules of origin (RoO). RoOÌýare the criteria used toÌýdetermineÌýtheÌý‘economic nationality’Ìýof a product. They define where a product was made (as opposed to shipped from) and,Ìýconsequently, whether imports and exports qualify for preferential tariff rates in trade agreements.

However, RoO can be difficult for businesses across the world to navigate. Different approaches to RoOÌýbetween different countries and between different trade deals can mean a complex patchwork of rules to follow and paperwork to fill out for business. This can be reduced when a bloc of countries aligns their approach on such issues. Across continental Europe, North Africa and parts of the Middle East, the Pan-Euro Mediterranean Convention on Rules of Origin (PEM) does just that.Ìý

The Regional Convention onÌýPEM is a multilateral agreement between 25 contracting parties[footnote 1]Ìý³Ù³ó²¹³ÙÌý±ð²õ³Ù²¹²ú±ô¾±²õ³ó±ð²õÌý³¦´Ç³¾³¾´Ç²ÔÌýRoOÌýamong its members toÌýfacilitateÌýtrade and support the integration of supply chains. It is not a customs union. A more detailed explanation of what PEM is can be foundÌýin Annex A.ÌýOn 26 June 2025, the UK government published its Trade Strategy, and this included a commitment to engage businessÌýto consider the benefits of joining PEM.Ìý

The purpose of this call for evidence is therefore to seek business and partner input on the opportunities and risks that might flow from joining PEM. We are interested in the views and experiences of businesses across allÌýsectors,Ìýsizes andÌýregions thatÌýparticipateÌýin the trade of goods, particularly in the trade of goods with PEM members. It is vital that any decision to pursue accession considers at every stage the UK national interest.Ìý

PEM rules govern preferential trade within a trading bloc worthÌýover £900ÌýbillionÌýof goods tradeÌýinÌý2023[footnote 2].ÌýProximity in trade matters – it is right we consider ways to improve our trading relationships with our closest partners, including the EU. In the continent of Europe, the UK are the only non-members other than Russia and Belarus.

Joining PEM wouldÌýlikely simplifyÌýRoOÌýrequirements across trade agreements with theÌýUK’sÌýnear neighbours, as well as increasing supply chain flexibility for UK exporters through the facilitations it provides, particularly related toÌýcumulation[footnote 3].ÌýThisÌýcould helpÌýfacilitateÌýtrade for UK goods exporters and improve resilience against geopolitical risks.

Additionally, some of the general and product specific rules are more liberal than the equivalent rules in the UK’s currentÌýfree trade agreements (FTAs)Ìýwith the EU and PEM partners and so could be more beneficial for some businessesÌýandÌýsectors.Ìý

However, that is not necessarily true for all. The impact of accession may vary for individual businesses both across and within the same industry. While some businesses are likely toÌýbenefitÌýfrom rules that are easier to meet and greater supply chain flexibility, others might faceÌýadditionalÌýadministrative burdens or face stricter criteria because of the change in rules.

In particular, the UK-EU Trade and Cooperation Agreement (TCA) is more facilitative in certain areas than the PEM convention, including on origin procedures (administrativeÌýrequirements). Accession would also have to be negotiated with the membership, and adapting to further new rule changes can be time consuming and expensive.Ìý

Stakeholders are therefore invited to provide input on:Ìý

  • yourÌýgeneral experienceÌýof engaging with RoOÌýrequirements in the context of trade in goods with PEM members
  • the potential benefit of harmonised rules across FTAs with PEM ³¾±ð³¾²ú±ð°ù²õÌý
  • the impact, if any, of different rulesets (TCA vs PEM) on your ability to access preferential tariffsÌý
  • the value of expanded and stable cumulation opportunitiesÌý
  • the value of other relevant facilitations, such as those related to origin procedures (such as proof of origin) and transhipmentÌý
  • the comparative value and importance of the above factorsÌý

Guidance

The impacts of UK PEM accession are likely to differ depending on the origin of the product and FTA under which it is traded. At times therefore, the call for evidence distinguishes between the EU and non-EU PEM members.

The government is seeking views through . It is possible to save drafts of your responses and return to the survey, provided you use the same browser and device (without having cleared your browser cache and cookies) and complete before the call for evidence closes

Respondents who are able to supply further detail than the survey allows are encouraged to fill out the supplementary table of evidence template and submit it to PEMCallforEvidence@businessandtrade.gov.uk.

The call for evidence will close at 11:59pm on 22 December 2025 and the government cannot guarantee that responses received after this date will be considered. For any questions or queries, includingÌýon technical issues, contactÌýPEMCallforEvidence@businessandtrade.gov.uk.

Next stepsÌý

Once the call for evidence has closed, the government will review and analyse the responses received.

Privacy and confidentiality notice

Privacy notice

This privacy notice explains how the Department for Business and TradeÌý(DBT), as a ‘data controller’,Ìýprocesses your personal data for this Call for Evidence investigating stakeholder views on potential UK accession to the PEM convention.Ìý

This notice is supplemented by ourÌýÌýwhich provides further information on how DBT processes personal data and setsÌýour yourÌýrights in respect of that personal data.Ìý

Data DBT ³¦´Ç±ô±ô±ð³¦³Ù²õÌý

This call for evidence intends to collect data from:Ìý

  • businessesÌý(andÌýorganisations or advisorsÌýrepresentingÌýthem) tradingÌýbetweenÌýPEM members

Mandatory information to be collected as part of theÌýCallÌýforÌýEvidence includes:Ìý

  • name (first name and surname)Ìý
  • email addressÌý
  • name of organisationÌýorÌýbusinessÌýorganisation youÌýrepresent, if anyÌý

Why DBT asks for this informationÌý

DBT collects this information as part of the government’s ambitious,ÌýtransparentÌýand inclusive UK trade policy that takes account of the views of all sectors of society and international stakeholders. This includes theÌýgeneral public, devolved governments and the regions, businesses, civil society groups, consumers,ÌýassociationsÌýand any other interested stakeholders.Ìý

In line with this, the government has launched a 4-week public callÌýforÌýevidenceÌýon the potential benefits ofÌýtheÌýUKÌýjoiningÌýthe PEMÌý³¦´Ç²Ô±¹±ð²Ô³Ù¾±´Ç²Ô.

The personal information received in response to theÌýcallÌýforÌýevidenceÌýwill be processed for the purposes of obtaining the opinions of members of the public and representative of businesses and other organisations about the matters referred to in theÌýcallÌýforÌýevidence.Ìý

We may also use your personal data to help usÌýidentifyÌýany responses from bots or other fraudulent sources toÌýmaintainÌýthe integrity of the call for evidence. We may also use your contact details, with your consent, toÌýget in touch withÌýyou to discuss your response to our call for evidence or to get in touch to discuss other trade related issues.

Personal information may also be collected for statistical data, for example in relation to the types of individuals and groups thatÌýparticipateÌýin the callÌýfor evidence. We may also use your contact details to remove your response if you instruct us to do so.Ìý

The lawful basis we are relying on to process your personal data isÌý. The processing of personal information is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested inÌýDBT.ÌýThe task is engaging business on department policies or proposals, or obtaining opinion data, to develop good and effective policies.

How DBT processes personal data it receivesÌý

Once received your data will be:Ìý

  • stored in Qualtrics which has a contract with DBT – it will be held there while the information received for the purpose of theÌýcallÌýforÌýevidenceÌýis independently reviewed and assessedÌý
  • stored by DBTÌýfor review and assessment ifÌýsubmittedÌýas a physical copyÌý
  • once your personal data is no longer needed as part of the call for evidence process, any identifiers will be removed, and a de-identified dataset will remain for auditÌýpurposes

We will only process your personal data for purposes which are compatible with those specified in this privacy notice. This may include archiving in the public interest, or scientific,ÌýhistoricalÌýor statistical research,Ìýin accordance withÌý.

Where your data is further used for research purposes,Ìýappropriate safeguardsÌý(including anonymisation, pseudonymisation and data minimisation techniques) will be used to ensure that your personal data is only processed where it is necessary for us to do so, and that it is processed lawfully and securely.

Compatible research purposes may include analysis to further DBT policy development, or to analyse public consultation responses or similar requests for information from the public.

We are trialling artificial intelligence (AI) solutions to support the delivery of our functions. Unless made expressly clear to you, we will not use AI to either make or inform decisions about you. We will apply effective data minimisation techniques to all such uses of your data.Ìý

Wherever possible, avoid including anyÌýadditionalÌýpersonal data in free-text responses beyond that which has been requested or which you consider it necessary for DBT to be aware of.

Third-party processorsÌý

We use Qualtrics as a third-party data processor. Qualtrics are contracted by DBT which means theyÌýare required toÌýmeetÌýappropriate securityÌýstandards andÌýare not able toÌýuse your data without instruction from DBT.

Your responses, including any personal data, may be shared with a third-party provider, or other government department or organisation acting on behalf of DBT under contract or an equivalent agreement, for the purpose of analysis and summarising responses for us and they may use technology, such as artificial intelligence.

Information sharingÌý

Your data will be processed and shared withinÌýDBTÌýand with selected third parties.Ìý

Third parties with whom information and personal data may be shared with are:Ìý

  • Qualtrics, as the data processorÌý
  • other government departments, public authorities, law enforcementÌýagenciesÌýand regulatorsÌý
  • other third parties where we consider it necessaryÌýin order toÌýfurther our functions as a government departmentÌý
  • in response to information requests, for example, under Freedom of Information (FOI) law or the Environmental Information Regulations (EIR)Ìý
  • to a court,ÌýtribunalÌýor party where the disclosure is necessaryÌýin order toÌýexercise,ÌýestablishÌýor defend a legal claimÌý
  • where we are ordered to do so or where weÌýare otherwise required toÌýdo so by lawÌý
  • third-party data processors as governed by contractÌý

Aggregated analysis of responses may be shared with

  • the Information Commissioner’s Office (ICO)
  • the Government Internal Audit Agency (GIAA)
  • the National Audit Office (NAO)Ìý
  • central government departments

Should there be a requirement to share your personal data with third parties not included in this list, you will be notified beforehand via a revised privacyÌýnotice.

We will not:Ìý

  • sell or rent your data to third partiesÌý
  • share your data with third parties for marketing purposes

We will also share your data if weÌýare required toÌýdo so by law or regulation – for example, by a court order, or to prevent fraud, or other crime.

How long DBT will hold your data forÌý

DBT will onlyÌýretainÌýyour personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will onlyÌýretainÌýyour personal data for as long as:Ìý

  • it is needed for the purposes set out in this documentÌý
  • the law requires us to

If we decide that we need to process your personal data for a reason which is incompatible with the purposes for which we collected it for, we will contact you to explain why we are doing this and why it is lawful to do so.Ìý

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use of disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rightsÌý

You haveÌýa number ofÌýrights available to you under UK data protection legislation, includingÌýthe right to:Ìý

  • request copies of the personal data we hold about youÌý
  • request that we rectify information about you which you think is inaccurate or incompleteÌý
  • request that we restrict your data from further processing (in certain circumstances)Ìý
  • object to the processing of your data (in certain circumstances)Ìý
  • data portability (in certain circumstances)Ìý
  • request that we erase your data (in certain circumstances)Ìý
  • not be subject to a decision based on solely automated data processing

You can contact DBT’s Data Protection Office for further information about how your data has been processed by the department or to make a complaint about how your data has been used.ÌýContactÌýdata.protection@businessandtrade.gov.uk.

You can alsoÌýsubmitÌýa complaintÌýto the Information Commissioner’s Office (ICO) at:Ìý

Information Commissioner’s Office
Wycliffe HouseÌý
Water LaneÌý
°Â¾±±ô³¾²õ±ô´Ç·ÉÌý
°ä³ó±ð²õ³ó¾±°ù±ðÌý
SK9 5AFÌý
°Â±ð²ú²õ¾±³Ù±ð:ÌýÌý
Telephone: 0303 123 1113Ìý

You can find out more about your rights as a data subject, and details of how to contact our Data Protection Officer and the ICO in our main privacy notice.Ìý

ConfidentialityÌý

Information provided while contributing to this call for evidence, including personal data, may be published, orÌýdisclosedÌýin accordance withÌýaccess to information regimes, primarily the:

If you want the information you provide to be treated confidentially, be aware that,Ìýin accordance withÌýthe FOIA and EIR, public authoritiesÌýare required toÌýcomply withÌýa statutory regime and code of practice which deals, amongst other things, with obligations of confidence.

In view of this,Ìýyou will be able toÌýsubmitÌýto the dedicated call for evidence mailbox (PEMCallforEvidence@businessandtrade.gov.uk)Ìýwhich information in your response you would like to be treated as confidential and explain the reason for your request (for example, due to reasons of commercial sensitivity).

If the information is commercially sensitive, explain why this is the case. If we receive a request for disclosure of information that has been provided, we will take full account of your explanation, but we cannot give an assurance that confidentiality can beÌýmaintainedÌýin all circumstances.Ìý

By answering these questions, you give your consent for the contents to be used for the purposes of thisÌýcallÌýforÌýevidence. This includes this data being shared with other UK government departments as necessary to complete thisÌýcallÌýforÌýevidence.Ìý

Ways to respondÌý

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You can view the questions online or have the option to download and print the questions in PDF.

  1. The 25 contracting parties to PEM are Albania, Algeria, Bosnia and Herzegovina, the EU27, Egypt, Faroe Islands, Georgia, Iceland, Israel, Jordan, Kosovo, Lebanon, Liechtenstein, Moldova, Montenegro, Morocco, North Macedonia, Norway, Palestine, Serbia, Switzerland, Syria, Tunisia, Turkey, and Ukraine.Ìý↩

  2. Source: DBT calculations based on total imports from UN Comtrade where contracting parties have a free trade agreement in place.Ìý↩

  3. Diagonal cumulation arrangements in the PEM zone mean inputs from a PEM member can be incorporated in products manufactured by another member and used to meet the RoOÌýwhen exporting to a third member (so long as they all have FTAs with each other). A full explanation of diagonal cumulation, with examples and diagrams, can be found in Annex A.Ìý↩