Key data
| Regulation | EU-Pakistan Exchange of Notes Agreement (CELEX:22026A01954), under Article XXVIII of GATT 1994 |
|---|---|
| Publication | 21 August 2026 |
| Entry into force | Following mutual notification of compliance with internal procedures (date not specified) |
| Affected parties | European importers of Pakistani products subject to tariff quotas (TRQs) |
| Category | European Regulation — International Trade |
| Affected list | EU List CLXXV (EU-27 tariff quotas post-Brexit) |
| Key product | Brown rice — tariff code 10062000 |
| Legal framework | Article XXVIII of the General Agreement on Tariffs and Trade (GATT) 1994 |
European importers working with Pakistani suppliers face a relevant regulatory change: the EU and Pakistan have concluded a bilateral agreement that sets out how tariff quotas (TRQs) from the EU List CLXXV are distributed following the United Kingdom's departure. The agreement, published on 21 August 2026 under reference CELEX:22026A01954, was negotiated under Article XXVIII of GATT 1994 and has direct effects on import operations from Pakistan into the EU-27.
The practical question is straightforward: how much quota do I have available now that the United Kingdom is no longer part of the EU? This agreement provides an official answer to that question for Pakistani products included in the TRQs.
What does this regulation establish?
Brexit forced the EU to renegotiate with all countries that had rights over its tariff quotas, because the United Kingdom's departure reduced the EU market and, with it, the volume of quota available to third countries. This agreement with Pakistan closes that bilateral negotiation.
The key points of the agreement are:
- Proportional allocation methodology accepted: Pakistan accepts that the quotas of List CLXXV are divided between the EU-27 and the United Kingdom proportionally, rather than requiring the EU-27 to maintain the total pre-Brexit volume.
- Initial Negotiating Rights (INRs) recognized: The agreement expressly recognizes Pakistan's INRs over brown rice (tariff code NC 10062000). This means that Pakistan has formal rights of consultation and negotiation over that specific contingent.
- Separate negotiations with the United Kingdom: The agreement does not affect Pakistan's rights to negotiate with London independently. Both parties maintain their positions at the WTO.
- Third-party consultation clause: If the EU concludes agreements with other WTO members that have similar rights and those agreements alter the quotas agreed with Pakistan, the EU commits to consulting Pakistan before applying the changes.
- Entry into force: The agreement enters into force following mutual notification of compliance with the internal procedures of each party. The exact date is not specified in the published text.
| Element | Detail |
|---|---|
| Type of instrument | Exchange of Notes (simplified bilateral agreement) |
| WTO legal basis | Article XXVIII of GATT 1994 |
| Affected concessions list | EU List CLXXV |
| Key tariff code | 10062000 — Brown rice |
| Rights recognized to Pakistan | Initial Negotiating Rights (INRs) over tariff code 10062000 |
| Allocation methodology | Proportional between EU-27 and United Kingdom |
| Safeguard clause | Mandatory consultation with Pakistan if agreements with third parties alter quotas |
Economic and operational impact
The direct impact for European importers is the reduction in the volume of quota available under the EU-27 compared to the pre-Brexit period, when List CLXXV also included the British market. By applying the proportional methodology, the quota assigned to the EU-27 is lower than the historical total.
This has concrete operational consequences:
- Importers who operated with quotas calculated on the EU-28 market must recalibrate their purchase volumes to not exceed the available EU-27 contingent.
- Exceeding the contingent means paying the full tariff outside the quota, which can be significantly higher than the preferential rate within the TRQ.
- Recognition of Pakistan's INRs over tariff code 10062000 (brown rice) adds a layer of legal stability for that product: Pakistan has formal rights that the EU must respect, reducing the risk of unilateral quota modifications.
- The third-party consultation clause indirectly protects importers: if the EU negotiates with another country and that affects the Pakistani contingent, it must notify before applying changes.
The agreement does not prejudge the EU's negotiations with other WTO members that have similar rights over the same contingents. This means that the final quota volume may still be adjusted if those parallel negotiations conclude with different results.
Who does it affect?
- European importers of rice from Pakistan, especially those working with brown rice (tariff code NC 10062000), which is the product with expressly recognized INRs.
- European importers of any Pakistani product subject to TRQ in the EU List CLXXV, whose quota volume has been adjusted due to Brexit.
- Traders and commodity brokers managing import operations from Pakistan into the EU-27.
- Foreign trade and customs departments of companies with supply chains that include Pakistani suppliers.
- Customs advisors and customs brokers managing import declarations with application of TRQs from List CLXXV.
- CFOs and purchasing directors of industrial or food companies using raw materials or products from Pakistan subject to contingent.
Practical example
Imagine a Spanish company importing brown rice from Pakistan (tariff code NC 10062000). Before Brexit, it operated within the contingent of the EU-28 List CLXXV, which also included demand from the British market. With the proportional allocation agreed, the quota available for the EU-27 is now lower than that historical total.
If this company has not updated its import forecasts and continues to plan volumes based on the pre-Brexit quota, it risks exceeding the available EU-27 contingent. The excess is subject to the full tariff outside the quota, increasing the cost of the goods and reducing the margin of the operation.
Thanks to recognition of Pakistan's INRs over this tariff code, the company can be certain that the quota assigned to Pakistan is legally protected: the EU cannot reduce it unilaterally without consulting Pakistan. This provides predictability for planning medium-term supply contracts.
What should companies do now?
- Review the TRQ quota volumes available under the EU-27 for all Pakistani products you import. The contingents of List CLXXV have been adjusted downward due to Brexit: do not assume that the historical volume remains in force.
- Identify whether your products fall under tariff code NC 10062000 (brown rice). If so, Pakistan's INRs are recognized and the quota has greater legal stability.
- Update import planning models with the new EU-27 quota volumes, to avoid exceeding the contingent and triggering unbudgeted full tariffs.
- Monitor EU negotiations with other WTO members with rights over the same TRQs. If those negotiations conclude, the EU must consult Pakistan before applying changes, but the final volume may vary.
- Coordinate with your customs advisor the correct application of the adjusted TRQ in import declarations, especially if you have multi-year supply contracts signed with Pakistani suppliers.
- Verify the definitive entry into force of the agreement: it enters into force following mutual notification of compliance with internal procedures by both parties. Consult the EU Official Journal to confirm the exact date.
Frequently asked questions
What Pakistani products are affected by this agreement?
The agreement affects all Pakistani products subject to tariff quotas (TRQs) included in the EU List CLXXV. The only product expressly mentioned with Initial Negotiating Rights (INRs) recognized to Pakistan is brown rice, tariff code NC 10062000. For other products under TRQ from List CLXXV, the proportional post-Brexit adjustment also applies, although no additional tariff codes are detailed in the agreement text.
When does the EU-Pakistan agreement on tariff quotas enter into force?
The agreement enters into force following mutual notification of compliance with the internal procedures of the EU and Pakistan. The exact date is not specified in the text published on 21 August 2026. It is necessary to consult the EU Official Journal to confirm when that notification occurs.
What are Initial Negotiating Rights (INRs) and why do they matter for importers?
INRs (Initial Negotiating Rights) are rights recognized under the WTO framework that grant a country the capacity to negotiate and be consulted when tariff quotas in which it has an interest are modified. In this agreement, Pakistan's INRs over tariff code 10062000 (brown rice) are expressly recognized. For importers, this means that the quota assigned to Pakistan in that product has greater legal stability: the EU cannot reduce it unilaterally without consulting Pakistan.
Can the quota volume agreed with Pakistan still change?
Yes. The agreement expressly establishes that it does not prejudge the EU's negotiations with other WTO members that have similar rights over the same contingents. If those parallel negotiations conclude with results that alter the quotas agreed with Pakistan, the EU commits to consulting Pakistan before applying the changes. Therefore, the final quota volume may still be adjusted depending on those pending negotiations.
Does this agreement affect imports from the United Kingdom?
Not directly. This agreement regulates the contingents of the EU-27 with Pakistan. The agreement expressly recognizes that Pakistan maintains its separate negotiation rights with the United Kingdom, which negotiates its own TRQs independently after Brexit. If you import from Pakistan into the United Kingdom, you must consult the bilateral UK-Pakistan agreements, which are independent of this instrument.
Official source
Consult complete regulation at official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:22026A01954