EU customs duties on clothing made in Tunisia: the Association Agreement and rules of origin

The principle: no customs duties on industrial products

The Association Agreement between the European Union and Tunisia was signed in July 1995 and entered into force in 1998. According to the European Commission, it provides for all trade in industrial products between the two parties to be free of customs duties, in both directions. Clothing is among these industrial products.

Duty free entry is not automatic. It applies to products that are "originating" within the meaning of the agreement's rules of origin, and on presentation of a proof of origin. A garment that does not meet these conditions pays the standard EU duty applied to third countries, at a rate that depends on its tariff code.

The rules of origin framework: the Pan Euro Mediterranean Convention

The rules of origin between the EU and Tunisia are based on the Regional Convention on Pan Euro Mediterranean preferential rules of origin, known as the PEM Convention. According to the European Commission, Tunisia joined it on 1 January 2015.

This framework has recently changed:

• The 2012 rules: the original version of the PEM Convention.
• The revised rules: adopted on 7 December 2023 by the Joint Committee of the Convention, applicable from 1 January 2025. According to the European Commission, they have applied between the EU and Tunisia since 1 March 2025.

The Commission states that, during a transitional period, the 2012 rules remain applicable alongside the revised rules. Operators can choose between the two sets of rules, depending on their supply chain. This choice should be confirmed with your customs broker.

What the rules require for a garment

Under the 2012 rules, the basic rule for clothing is manufacture from yarn. The fabric must therefore be made from yarn within the zone, often referred to as "double transformation".

Under the revised rules, according to the guidance published by the European Commission:

• For woven garments (Chapter 62): weaving combined with making up, including cutting of fabric, or making up, including cutting, preceded by printing of the fabric.
• For knitted garments (Chapter 61): knitting combined with making up, including cutting, or spinning of staple fibres combined with knitting.

The revised rules also provide a tolerance for textile materials without originating status, up to 15 % of the weight of the product, under the conditions set out in the notes to the list rules.

In practice: as a general rule, cutting and sewing in Tunisia a fabric woven outside the zone is not enough to make the garment originating. Printing the fabric before making up opens another route under the revised rules. The check is made item by item.

Cumulation: using European or regional fabrics

Cumulation allows materials from partner countries to count as originating. The PEM Convention provides for three forms.

• Bilateral cumulation: materials originating in the EU and used in Tunisia can be taken into account for the origin of the garment.
• Diagonal cumulation: possible with other partners in the zone, provided the countries concerned apply identical rules between themselves. The Commission publishes a cumulation matrix showing, country by country, which combinations are in force.
• Full cumulation: according to the Commission guidance, under the revised rules only bilateral full cumulation applies to textile and clothing products.

Under CMT, the origin of the fabrics supplied by the brand is therefore the first point to document.

Proof of origin: EUR.1, EUR MED, origin declaration

The form of proof of origin depends on the set of rules used.

Under the 2012 rules, according to the Commission:

• a movement certificate EUR.1 or EUR MED, issued by the customs authorities of the exporting country;
• or an invoice declaration, made out by an approved exporter, or by any exporter for a consignment whose total value does not exceed EUR 6,000.

Under the revised rules, according to the Commission guidance:

• a single type of proof: the EUR.1 certificate or the origin declaration, made out by the exporter on an invoice, delivery note or any other commercial document;
• the dual EUR.1 and EUR MED system disappears;
• the validity of the proof of origin is extended from 4 to 10 months.

Points to check before ordering

• The tariff code of each garment, to identify the rule of origin and the standard duty that applies.
• The provenance and origin of the fabrics, with supporting documents from the supplier.
• The set of rules chosen, 2012 or revised, given your materials.
• The no drawback rule: according to the Commission guidance, the revised rules remove it for most products, but keep it for materials used in products of Chapters 50 to 63, which cover textiles and clothing. This technical point should be reviewed with your customs broker.
• Who makes out the proof of origin and who keeps the supporting documents.

At Vestra

Vestra manufactures workwear in Sidi Bou Ali, near Sousse, on a CMT or full package basis depending on the product family. Under CMT, the client supplies fabrics and trims: their provenance has a direct bearing on the origin of the garment. This question is dealt with from the tech pack stage, together with your customs broker. Delivery is FOB or to your warehouse through a freight forwarder, and the documents for each order remain available on the client portal.

To discuss your project, send your tech pack to sales@vestratextile.com.

Frequently asked questions

Is a garment sewn in Tunisia automatically duty free?

No. It must be originating under the rules of origin, and a proof of origin must accompany the import. Otherwise, the standard EU duty applies.

Does fabric bought in Asia allow duty free entry?

As a general rule, no: cutting and sewing a fabric without originating status is not enough. The revised rules provide another route, printing the fabric before making up. The answer depends on the exact product.

Where can I check the rule that applies to my product?

On Access2Markets, the European Commission portal, using the tariff code, and with your customs broker or freight forwarder.

Vestra Manufacturing, workwear manufacturer in Tunisia →

Sources

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