Dear Commissioner Malmström,

Dear Commissioner Hogan,


The EU has concluded many important FTAs over the last five years under your mandate. Nevertheless, the recently published FTA implementation report for 2018 shows that the Preference Utilization Rate (PUR) for EU exports continues to leave a significant margin for improvement. PURs differ widely between countries and agreements, also for the new generation of FTAs, resulting in unnecessary levies and friction.

A straightforward way to increase the uptake rate would be enhancing existing and setting up new tools to help Small- and Medium-sized Enterprises (SMEs; which account for no less than 86% of EU exporting firms) to take better advantage of the opportunities created under FTAs. As the implementation report rightly remarks, “the cost of entering new markets weighs more heavily on SMEs than on larger firms”. One major hurdle for SMEs to increase their PUR is the compliance with rules of origin (RoO) requirements. As our trade agreements proliferate, so do the RoO – leading to increased complexity. While a Single Rulebook for international trade is not on the multilateral horizon, the Trade for All Strategy rightly aimed to “strive for simplicity and consistency of rules of origin and provide user-friendly information on trade opportunities”.

Even though the systematic inclusion of SME-chapters in new FTAs, as well as the inclusion of a specific SME section in the FTA implementation report are welcome steps in the right direction, we need to go beyond just making new information and guidelines on rules of origin available to companies. A more interactive, free of charge, web-based origin selfassessment tool is urgently needed as an additional first line of support for European SMEs in order for them to assess whether their specific product can profit from the preferences of a given EU trade agreement.

The necessity for a Rules of Origin Calculator has been voiced on numerous occasions by business organizations representing SMEs. However, in spite of the Commission’s commitment to develop new digital outreach tools in the implementation report of 2017, no operational tool other than a pilot in the context of a survey has been delivered. Taking into account that the total cost for an operational web-based self-assessment tool has been estimated at less than 1 million EUR – which would amount to an investment of a little more than one Euro per exporting SME – and the undeniable added value for SMEs – and hence jobs and growth -, we believe that it is high time to prioritize the development and delivery of this tool, including promptly allocating the needed resources for this purpose.

This initiative should become an important tool in the toolbox for the effective implementation (and enforcement) of concluded trade and investment agreements. We strongly encourage you to set up this Rules of Origin Calculator as soon as possible and remain at your disposal if further information would be required.




Christophe Hansen – EPP INTA Coordinator

Bernd LANGE – S&D – INTA Committee Chair

Heidi HAUTALA – Greens/EFA INTA Coordinator

Geert BOURGEOIS – ECR INTA Coordinator

Karin KARLSBRO – Renew INTA Coordinator

Kathleen VAN BREMPT – S&D INTA Coordinator

Helmut SCHOLZ – GUE/NGL INTA Coordinator

Antonio TAJANI – AFCO Committee Chair & President of the Conference of Committee Chairs

Jörgen WARBORN – EPP INTA vice-Coordinator

Markus FERBER – EPP ECON Coordinator


Danuta HÜBNER – EPP AFCO Coordinator & EPP INTA Member

Massimiliano SALINI – EPP INTA Member

Markus PIEPER – EPP Group SME Circle Chairman

Daniel CASPARY – EPP INTA Member

Enikő GYŐRI – EPP INTA Member

Reinhard BÜTIKOFER – Greens/EFA INTA Member


Liudas MAZYLIS – EPP INTA Member