There are questions that resonate more strongly in the world of international trade, and in these lines the focus is on answering the following question: "Can I use an input imported from a third country not part of the Agreement, and not lose the negotiated tariff preference?"
The answer, many times, is as simple as the rule to be followed indicates in the agreement in question, but other times it is necessary to delve into the provisions of the agreements until finding other, somewhat less well-known tools such as extended accumulation to third countries.
The legal framework already exists, it is more developed than many assume, and the task ahead is to bring it closer to those who can benefit from it in their daily operations.
What do we mean when we talk about extended accumulation?
In simple terms, extended accumulation allows a producer-exporter to consider as "originating" materials supplied by a country that is not part of the preferential agreement being used, when qualifying the origin of the final good.
The operation always involves three actors: a first country that exports the good, a second country that imports it with tariff preference, and a third country that provides a material that, without this provision, would work against the origin criterion of the final product.
The benefit is twofold. On the one hand, the exporter gains competitiveness: they can source from more advantageous markets without losing the preferential tariff treatment under the agreement used to reach their destination. On the other hand, it enables the formation of broader regional value chains, because the third-country supplier becomes integrated into the production chain and indirectly gains access to the importing market.
For this to work in practice, any agreement needs to answer five basic questions: which countries can participate as third parties, which materials are eligible, how that eligibility is verified, what rules of origin those materials must meet, and how compliance is certified. Clarity (or the lack thereof) on these five points determines the viability of the agreement.
The landscape under the ALADI framework 1 and the different levels of maturity
Based on the information provided in the report 2 Regarding the accumulation with third countries in the rules of origin of the member countries of ALADI, published on its official website, it is clear that, from ALADI's survey of its 51 current agreements, only 15 agreements contemplate some mechanism of accumulation with third parties.
Of that universe, only four have the five elements mentioned above fully defined and operational: ACE 18 of MERCOSUR, ACE 36 of Mercosur with Bolivia, ACE 46 between Ecuador and Cuba, and ACE 75 between Chile and Ecuador.
If we focus on the Mercosur analysis, one point worth highlighting is that the bloc's four member countries participate as cumulative contributors in six different agreements. In other words, the bloc already frequently opens its doors to materials from other countries in the region.
The most complete case is that provided for in ACE 18, specifically in DEC. CMC N°5/23 3 “ROM” in its article 12, which establishes that materials originating from Bolivia, Peru, the Andean Community and Colombia may be considered as originating from Mercosur, provided they meet four conditions:
- that respect the originating regime of the corresponding bilateral agreement
- that this origin requirement be definitive (not temporary)
- that the preference reaches 100% without quotas in the four States Parties, and
- that there are no quota-linked origin restrictions.
The contrast is evident with ACE 35, the Mercosur-Chile agreement. Its Article 10 4 It expressly provides for the possibility of incorporating accumulation with third countries, but does not define the conditions, leaving the provision for a later stage.
As a side note, and outside the scope of ALADI, there is a more sophisticated precedent within the framework of the Mercosur-EFTA Agreement
In the extended accumulation section of the MERCOSUR-EFTA agreement 5 (Switzerland, Norway, Iceland and Liechtenstein), the use of materials from the European Union as originating is enabled.” The logic responds to a concrete production reality on the EFTA side: the value chains are strongly integrated with the European ones, and on the other hand, it opens a window of opportunity for the integration of inputs from European countries into production processes also on the Mercosur side.
These inputs are specified in a positive list: that is, only the materials expressly included can be accumulated, and each subheading has a specific rule assigned to it (change of classification, value rule, or a combination of both). Furthermore, there is the criterion of equivalence of rules of origin, where an exact match between the regimes is not required; instead, the Joint Committee of the Agreement can establish equivalent rules, always subject to periodic review and risk assessment. There is also an express exclusion of sensitive products—those with quotas, those not offered, or those with fixed preferences in either of the two agreements involved. The mechanism must also be reviewed five years after its entry into force, unless the Joint Committee decides otherwise.
An example to bring the hypothesis down to earth.
Let's consider a hypothetical case: a Brazilian company that manufactures audio equipment for export to Argentina under ACE 18. Some of the integrated circuits it uses as inputs are imported from Peru. Without extended cumulation, this non-regional input could cause the company to lose its qualification due to the regional content percentage required by the product's rule of origin. With the cumulation allowed under Article 12 of ACE 18, and provided the Peruvian input qualifies as originating under ACE 58, the company could qualify. 6 and meets the four conditions of the agreement, that material is counted as if it originated in Mercosur.
The result: the company retains the preferential tariff at destination, and the Peruvian supplier is, in fact, integrated into a regional value chain that it would hardly be able to access otherwise.
It's a simple example, but it illustrates a key point: extended accumulation is not a minor customs technicality. It's the difference between a procurement decision being commercially viable or not.
Some conclusions
The legal tools already exist: the challenge is not to design new instruments but to encourage greater use of those already in place. The data analyzed shows that these mechanisms are underutilized.
Looking ahead, the expectation is that as practical experience accumulates, the fear of triangulation—that often unfounded suspicion that extended accumulation is a gateway to fraud of origin—will recede, and that real access to broader value chains will open up.
The next step involves dissemination. Many exporters who could benefit from extended cumulation are still unaware that the clause exists in the agreement they already use, or are unclear about which certificate they should request from their non-regional supplier.
Bringing this information closer to the operators is, in line with the regional trend towards trade facilitation, the natural next step after the legal consolidation of the instrument.
In that sense, the Mercosur-EFTA case sets a baseline of technical sophistication that is worth looking at closely: clear positive lists, equivalence of rules assessed by a joint body, and mandatory periodic reviews.
With a legal framework, accumulated experience, and dissemination among operators, extended accumulation can cease to be a tool for specialists and become another piece of information in the logistics planning of any exporter in the region.
Highlighted
1 ALADI: Latin American Integration Association www.aladi.org
2. ALADI Report: https://biblio.aladi.org/cgi-bin/koha/opac-detail.pl?biblionumber=99869
3 DEC 05/23 ROM https://normas.mercosur.int/simfiles/normativas/95567_DEC_005-2023_ES_Regimen%20Origen%20MCS.pdf
4. RO ACE 35 https://www2.aladi.org/biblioteca/publicaciones/aladi/acuerdos/ace/es/ace35/web/ACE_035_Anexo_13.pdf
5. RO MCS-EFTA https://www.cancilleria.gob.ar/userfiles/2017/02.EFTA-Mercosur annex_i rules_of_origin_16-1718 final-formatted.pdf
6. RO ACE 58: https://www2.aladi.org/biblioteca/publicaciones/aladi/acuerdos/ace/es/ace58/ACE_058_Anexo_05pdf
Recommended reading
- Self-certification of origin in MERCOSUR: a necessary step that requires acumen and learning for Argentine exportersBy Andrea Russo, published on May 3, 2026. Available at: https://aduananews.com/autocertificacion-de-origen-en-el-mercosur-un-paso-necesario-que-requiere-agudeza-y-aprendizaje-para-los-exportadores-argentinos/
- MERCOSUR and the new scenario with the European Union: a 35th anniversary with objectives achievedBy Andrea Russo, published on March 20, 2026. Available at: https://aduananews.com/mercosur-y-el-nuevo-escenario-con-la-union-europea-un-35-aniversario-con-metas-cumplidas/
