On 26 May 2025, the European Commission announced that Ukraine has officially held ‘CR’ preferential status in trade with the European Union since 23 May 2025.
Both sets of rules can be applied
In concrete terms, this means that companies are free to decide whether to apply the old rules of origin or the revised rules to their goods. This parallel application is particularly relevant for diagonal cumulation, i.e. when raw materials from different countries with preferential agreements are combined. The ‘CR’ status is preferential because it allows the application of preferential rules of origin, but with more flexibility than the pure “C” or ‘R’ statuses.
Parallel application of old and revised rules of origin
Under the PEM Agreement, it is currently possible to apply the old and revised rules of origin in parallel. The reason for this is that not all contracting states have fully implemented the new rules. In order to continue to enable preferential trade and diagonal cumulation, a transitional arrangement has been introduced. This allows companies to choose between the two sets of rules as required. In the PEM matrix, this status is marked with ‘CR’. The measure is limited until the end of 2025 and is intended to avoid trade barriers during the transition phase.
Links:
The Pan-Euro-Mediterranean cumulation and the PEM Convention
Sources: