Following our recent exchange with the Commission services (DG Trade/TAXUD) on the revised EU Generalised Scheme of Preferences (GSP) this morning, please find attached the notes summarising what was presented and what it means for apparel, footwear and wider sourcing strategies.

Key takeaways (in short):

• ‍Continuity, but higher risk: The 3-tier GSP structure is preserved and the scheme runs to 2036, but the reform increases the risk of sudden preference loss for apparel.‍
• 37% thresholds for apparel: Both graduation and safeguards for textiles/apparel now trigger at 37% of EU imports (down from 47.2%), materially raising the probability of abrupt tariff changes.‍
• No improvement for sensitive products: Apparel and footwear remain “sensitive” with only limited tariff relief, while exposure to safeguards/graduation increases.‍
• Stronger conditionality: Negative conditionality is expanded to cover all 27 conventions (including environment and good governance) for Standard GSP and EBA, and GSP+ obligations are reinforced with new conventions (incl. Paris Agreement). This increases political and compliance risk for sourcing countries.‍
• New urgent withdrawal: A faster suspension tool is added for exceptional cases, introducing additional regulatory uncertainty. This reduces the process from 12 to 7 months but should only be used vers exceptionally. ‍
• Beneficiary countries have to re-apply: GSP+ reapplications and rules of origin/cumulation will be updated via secondary legislation in 2026. Countries will have 2 years to re-apply and address shortcomings.‍
• Country transitions matter: Bangladesh post-EBA, Cambodia, Indonesia (GSP vs FTA), and upcoming LDC graduations (e.g. Nepal/Laos) remain key watchpoints. Bangladesh asked for a likely 3 year postponement of LDC graduation.

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The new rules apply from 1 January 2027. Many practical details will be set via secondary legislation in 2026, so early guidance, transparency and clear timelines will be essential for operators.

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For predictability and data the Commission invited members to closely follow the main sources of information:

The EU GSP Hub https://gsphub.eu/

The UN UNCTAD LDC Portal: https://www.un.org/ldcportal/content/unctad-0

The World Bank Country Classification blog: https://blogs.worldbank.org/en/opendata/world-bank-country-classifications-by-income-level-for-2024-2025

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