Open call for evidence

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

Published 17 November 2025

Introduction and guidance 

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). RoO are the criteria used to determine the ‘economic nationality’ of a product. They define where a product was made (as opposed to shipped from) and, consequently, 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 RoO between 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. 

The Regional Convention on PEM is a multilateral agreement between 25 contracting parties^{[footnote 1]} that establishes common RoO among its members to facilitate trade and support the integration of supply chains. It is not a customs union. A more detailed explanation of what PEM is can be found in Annex A. On 26 June 2025, the UK government published its Trade Strategy, and this included a commitment to engage business to consider the benefits of joining PEM. 

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 all sectors, sizes and regions that participate in 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. 

PEM rules govern preferential trade within a trading bloc worth over £900 billion of goods trade in 2023^{[footnote 2]}. Proximity 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 would likely simplify RoO requirements across trade agreements with the UK’s near neighbours, as well as increasing supply chain flexibility for UK exporters through the facilitations it provides, particularly related to cumulation^{[footnote 3]}. This could help facilitate trade 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 current free trade agreements (FTAs) with the EU and PEM partners and so could be more beneficial for some businesses and sectors. 

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 to benefit from rules that are easier to meet and greater supply chain flexibility, others might face additional administrative 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 (administrative requirements). Accession would also have to be negotiated with the membership, and adapting to further new rule changes can be time consuming and expensive. 

Stakeholders are therefore invited to provide input on: 

• your general experience of engaging with RoO requirements in the context of trade in goods with PEM members
• the potential benefit of harmonised rules across FTAs with PEM members 
• the impact, if any, of different rulesets (TCA vs PEM) on your ability to access preferential tariffs 
• the value of expanded and stable cumulation opportunities 
• the value of other relevant facilitations, such as those related to origin procedures (such as proof of origin) and transhipment 
• the comparative value and importance of the above factors 

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 the survey. 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 15 December 2025 and the government cannot guarantee that responses received after this date will be considered. For any questions or queries, including on technical issues, contact PEMCallforEvidence@businessandtrade.gov.uk.

Next steps 

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 Trade (DBT), as a ‘data controller’, processes your personal data for this Call for Evidence investigating stakeholder views on potential UK accession to the PEM convention. 

This notice is supplemented by our main privacy notice which provides further information on how DBT processes personal data and sets our your rights in respect of that personal data. 

Data DBT collects 

This call for evidence intends to collect data from: 

• businesses (and organisations or advisors representing them) trading between PEM members

Mandatory information to be collected as part of the Call for Evidence includes: 

• name (first name and surname) 
• email address 
• name of organisation or business organisation you represent, if any 

Why DBT asks for this information 

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

In line with this, the government has launched a 4-week public call for evidence on the potential benefits of the UK joining the PEM convention.

The personal information received in response to the call for evidence will 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 the call for evidence. 

We may also use your personal data to help us identify any responses from bots or other fraudulent sources to maintain the integrity of the call for evidence. We may also use your contact details, with your consent, to get in touch with you 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 that participate in the call for evidence. We may also use your contact details to remove your response if you instruct us to do so. 

Legal basis for processing your data 

The lawful basis we are relying on to process your personal data is article 6(1)(e) of the UK General Data Protection Regulation (GDPR) on legislation.gov.uk. 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 in DBT. The 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 receives 

Once received your data will be: 

• stored in Qualtrics which has a contract with DBT – it will be held there while the information received for the purpose of the call for evidence is independently reviewed and assessed 
• stored by DBT for review and assessment if submitted as a physical copy 
• 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 audit purposes

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, historical or statistical research, in accordance with Article 89 of UK GDPR on legislation.gov.uk.

Where your data is further used for research purposes, appropriate safeguards (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. 

Wherever possible, avoid including any additional personal 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 processors 

We use Qualtrics as a third-party data processor. Qualtrics are contracted by DBT which means they are required to meet appropriate security standards and are not able to use 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 sharing 

Your data will be processed and shared within DBT and with selected third parties. 

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

• Qualtrics, as the data processor 
• other government departments, public authorities, law enforcement agencies and regulators 
• other third parties where we consider it necessary in order to further our functions as a government department 
• in response to information requests, for example, under Freedom of Information (FOI) law or the Environmental Information Regulations (EIR) 
• to a court, tribunal or party where the disclosure is necessary in order to exercise, establish or defend a legal claim 
• where we are ordered to do so or where we are otherwise required to do so by law 
• third-party data processors as governed by contract 

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) 
• 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 privacy notice.

We will not: 

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

We will also share your data if we are required to do 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 for 

DBT will only retain your 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 only retain your personal data for as long as: 

• it is needed for the purposes set out in this document 
• 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. 

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 rights 

You have a number of rights available to you under UK data protection legislation, including the right to: 

• request copies of the personal data we hold about you 
• request that we rectify information about you which you think is inaccurate or incomplete 
• request that we restrict your data from further processing (in certain circumstances) 
• object to the processing of your data (in certain circumstances) 
• data portability (in certain circumstances) 
• request that we erase your data (in certain circumstances) 
• 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. Contact data.protection@businessandtrade.gov.uk.

You can also submit a complaint to the Information Commissioner’s Office (ICO) at: 

Information Commissioner’s Office
Wycliffe House 
Water Lane 
Wilmslow 
Cheshire 
SK9 5AF 
Website: https://ico.org.uk/ 
Telephone: 0303 123 1113 

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. 

Confidentiality 

Information provided while contributing to this call for evidence, including personal data, may be published, or disclosed in accordance with access to information regimes, primarily the:

• Freedom of Information Act 2000 (FOIA) on legislation.gov.uk
• Environmental Information Regulations 2004 (EIR) on legislation.gov.uk
• Data Protection Act 2018 (DPA) on legislation.gov.uk

If you want the information you provide to be treated confidentially, be aware that, in accordance with the FOIA and EIR, public authorities are required to comply with a statutory regime and code of practice which deals, amongst other things, with obligations of confidence.

In view of this, you will be able to submit to the dedicated call for evidence mailbox (PEMCallforEvidence@businessandtrade.gov.uk) which 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 be maintained in all circumstances. 

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

Ways to respond 

Complete the survey via Qualtrics.

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. ↩

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

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 RoO when 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. ↩