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Position paper - Wise Persons Group feedback

15 Dec 2021
Customs & 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.