Cumulation

Cumulation is the term used to describe a system that allows originating materials of country A to be further processed or added to products originating in country B, just as if they had originated in country B. The resulting product may acquire the origin of country B, provided the applicable conditions are met. Cumulation can only be applied between countries operating with identical origin rules.

There are three types of cumulation: bilateral, diagonal and full.

A) Bilateral cumulation

Bilateral cumulation involves two parties: the EU and a partner country. It allows to use materials originating in the EU as materials originating in a partner country and vice versa. This type of cumulation applies to all EU preferential trade arrangements.

B) Diagonal cumulation

Diagonal cumulation is similar to bilateral cumulation but is used in relation to more than two countries. It allows to use materials originating in a defined other country as originating materials. It can only be used where specific provisions exist for such type of cumulation.

Diagonal cumulation can only be applied to materials originating in a defined other country, which are then further processed in one of the parties.

Particular forms of diagonal cumulation are the so-called “regional” and “extended” cumulations, which are specific to the Generalised System of Preferences (Regional + Extended) and the association of the Overseas Countries and Territories of the EU (Extended).

C) Full cumulation

Unlike bilateral and diagonal cumulation, which apply only to originating materials, full cumulation also takes into account the working or processing carried out on non-originating materials. In other words, when full cumulation applies, all operations performed in the partner countries covered by the preferential trade arrangement are considered together when determining the origin of the final product, even if the materials used are not themselves originating.

If the processing carried out in a party is merely falling under the list of insufficient operations, full cumulation cannot be applied.