Full cumulation

 

Article 3.5 (“Accumulation”) of the EU-Japan Economic Partnership Agreement and Annex 3-C (“Information referred to in Article 3.5”)

Whereas bilateral cumulation applies only to originating materials, full cumulation allows the working or processing carried out in a preferential partner country to be considered as operations carried out in the EU, regardless of whether the processing is sufficient to confer the origin (and vice and versa).

  • Full cumulation makes it easier to comply with product specific rules by allowing to count together the working or processing conducted in EU and the partner country.
  • It requires tracing back the working or processing through a system of supplier’s declarations.
  • Full cumulation can be applied only in some EU preferential trade agreements:
    • the pan-Euro-Mediterranean cumulation area in certain cases,
    • the EU's Economic Partnership Agreements with African, Caribbean and Pacific countries,
    • EU-Canada Comprehensive Economic and Trade Agreement (CETA),
    • EU- Japan Economic Partnership Agreement.

Example of full cumulation between Tunisia, Morocco and the EU under Pan-Euro-Mediterranean (PEM) Convention

Chinese yarns are imported into Tunisia where they are manufactured into fabric. The fabric does not qualify for preferential origin if exported to the EU as the product specific rule for fabric require manufacture from fibre (double transformation – in this case, from fibre to yarn and yarn to fabric).

The non-originating fabric is exported from Tunisia to Morocco based on a supplier's declaration. The declaration states the goods have undergone working in Tunisia without having obtained preferential originating status.

In Morocco, the fabric is used to make garments. The finished garments obtain preferential origin status because the work done in Morocco is combined with the work done in Tunisia to produce originating garments. The double transformation requirement is then fulfilled in the territory of the countries benefiting from full cumulation.

The final product obtains Moroccan origin and can be exported to the EU under preferential conditions.

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