Implementation of the registered exporter system: extension of the transition period until December 31, 2020

Due to the COVID-19 emergency, Member States have the possibility to extend the transition period for the application of the registered exporter (REX) system until December 31, 2020.


The Commission Implementing Regulation (EU) 2020/750 of June 5, 2020 (“Regulation 2020/750”) establishes the possibility for Member States to notify the need for an extension of the transitional period for the application of the registered exporter (“REX”) system until December 31, 2020. In case of such an extension, the competent authorities will continue to issue certificates of origin at the request of exporters who are not yet registered.

Under the Commission Implementing Regulation (EU) 2015/2447 (“Regulation 2015/2447”), beneficiary countries of the Generalized System of Preferences (“GSP”) were required to apply the REX system as of June 30, 2020, for certification of GSP preferential originating status. However, the spread of COVID-19 and the measures adopted to contain the outbreak had a huge impact on, among other things, staff in companies and public administrations involved in implementing the REX system.

In particular, Regulation 2020/750 expressly refers to the emergency situation and to the difficulties that GSP beneficiary countries faced in (i) providing administrative cooperation within the framework of the REX system (Article 70, Regulation 2015/2447); (ii) fulfilling the notification obligations applicable after the date of application of the REX system (Article 72, Regulation 2015/2447); and (iii) in general, completing the registration process of exporters. Consequently, the Commission considered it appropriate to adjust the transitional period. However, that extension is an exceptional measure and as such is subject to specific requirements and time limits.

Indeed, beneficiary Member States must notify the Commission in writing by July 15, 2020 at the latest. That notification must indicate (i) the reasons why the extension of the transitional period is necessary due to the COVID-19 outbreak; and (ii) a work plan with detailed information on how the notifying Member State will fully apply the REX system by the end of the extended transitional period. In addition to submitting notification, the beneficiary Member State must submit to the Commission a report describing the progress made in implementing the work plan described in point (ii) by September 30, 2020, and, where necessary, the corrective measures necessary to meet the December 30, 2020 deadline.

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