Wise Persons Group feedback
Position Paper
14 Dec 2021
Customs and trade facilitation

 

The establishment of the European Commission’s Wise Persons Group on Challenges Facing the Customs Union (WPG) is a valuable initiative. AmCham EU welcomes it and takes this opportunity to provide the WPG with our ideas for customs reforms that we believe would benefit the European Union (EU) Member States, the EU as a whole and society at large.

The withdrawal of the UK from the EU, the new e-commerce VAT rules and COVID-19 have caused an uncontrolled explosion in the number of customs declarations. Historically, customs clearance processes were covering Business to Business (B2B) transactions. Within this framework, importers, exporters and customs brokers were familiar with the rules.

Today the supply chain has changed. In a Business to Consumer (B2C) environment, the regulatory framework is not always understood. Economic operators find it challenging to comprehend and apply very complex customs rules, while the complexity of the rules makes it challenging for customs authorities to control economic operators. 

An effective Customs Union should have simple, clear and easily understandable rules that anyone can apply and control.

 

In this paper we present our recommendations on the different topics that are being reviewed.

Related items

Position Paper
16 Oct 2026

Export controls fit for today's economy

The Dual-Use Regulation gives Europe a common framework for economic security, but divergent national implementation is weakening it. The same transaction can be assessed differently depending on the Member State, with guidance on cloud and software-as-a-service transfers remains unclear. Licensing processes, meanwhile, still assume a physical consignment rather than digital workflows, which sits poorly with how integrated global businesses operate. Companies bear the added cost and legal uncertainty, while the security benefit is limited. A single EU-wide approach to intangible transfers and closer alignment with the US and UK would make controls more predictable and let authorities focus on genuine risks. Read how the revision of the Dual-Use Regulation can deliver a harmonised and future-proof framework for Europe.

Trade
Customs and trade facilitation
Read more
Read more about Export controls fit for today's economy
News
30 Mar 2026

MC14: deep concern over e-commerce moratorium deadlock

The American Chamber of Commerce to the EU (AmCham EU) is deeply concerned by World Trade Organization members’ failure to reach agreement on the moratorium on E-Commerce at the 14th Ministerial Conference (MC14) in Cameroon. The absence of an agreement undermines legal certainty for businesses and consumers worldwide. This deadlock further underscores the need for significant WTO reform.

Since its introduction, the moratorium on customs duties on electronic transmissions has played a vital role in enabling the global digital economy by ensuring the smooth cross-border exchange of digital goods and services. In an increasingly digitalised global economy, predictability remains essential for companies of all sizes operating across borders.

WTO members must now renew efforts to re-instate the moratorium at the next General Council meeting as a matter of priority. Delivering such an outcome would strengthen the multilateral trading system and better reflect the realities of modern trade.

Trade
Customs and trade facilitation
Read more
Read more about MC14: deep concern over e-commerce moratorium deadlock
News
12 Mar 2026

Statement on Section 301 investigations

On Wednesday, 11 March, the United States Trade Representative launched Section 301 investigations into structural production overcapacity against a range of economies, including the European Union.  We understand that this decision is part of a larger attempt to stabilise the US tariff system in the wake of the Supreme Court ruling striking down the International Emergency Economic Powers Act (IEEPA) tariffs. 

The American Chamber of Commerce to the European Union (AmCham EU) is concerned about the continued uncertainty of the current trade environment. Companies still lack clarity over future tariff rates in both the short- and long-term. We continue to oppose broad-based tariffs as they raise costs for businesses and consumers and disrupt supply chains. 

With potential measures against the EU under consideration, AmCham EU calls on the EU and the US to avoid escalation in the trade dispute. The priority must be to restore stability and predictability in transatlantic trade. The deal struck in the summer is not a perfect solution, but it offers the most realistic path forward given political priorities on both sides. We look to the parties to honour their commitments under the EU-US Framework Agreement. 

The US Administration rightfully identifies overcapacity as a critical issue in the global economy which also affects the European market. We see the EU as part of the solution, rather than the problem. The EU and the US must work together to tackle the real issue at hand: unfair trading practices from non-market economies.  

Trade
Customs and trade facilitation
Transatlantic
Trade tensions
Read more
Read more about Statement on Section 301 investigations