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From Monday, 28 September to Thursday, 1 October 2026, AmCham EU led a delegation of members to Washington, DC to bring the views of the business community to policymakers in Congress and the administration. Discussions showed that both sides value the stability the Turnberry framework agreement brings. While parts of the agreement remain to be implemented, meetings pointed to the possibility for cooperation on economic security. Implementation will continue to need dialogue between the two sides, which is expected to carry on after the mid-term elections.

The reform of the Union Customs Code changes who is treated as the ‘importer’ when a non-EU company uses an indirect customs representative. That creates a problem under the EU VAT Directive, which links import VAT deduction to being identified as the importer or consignee. In practice, the non-EU company may no longer meet that requirement, while the customs representative may not qualify for the deduction either.

That could leave import VAT irrecoverable and create uncertainty for businesses using established import models. The Commission should ensure that the non-EU principal can still be identified in customs data for VAT purposes and fix the mismatch between the UCC and the VAT Directive.

Learn more about what changes are needed to keep import VAT deductibility workable under the new customs framework.

"Gold-plating" of EU legislation has become a structural challenge for companies operating across the Single Market. While Member States are often permitted to introduce additional national measures when implementing EU law, these divergences frequently create fragmented compliance requirements, administrative burdens and increased costs for businesses.

Drawing on examples from AmCham EU member companies across digital policy, cybersecurity, data protection, telecommunications, environmental regulation, consumer protection, tax transparency and labour law, the paper shows how national additions to EU rules can result in parallel compliance systems, duplicate reporting obligations, country-specific product adaptations and barriers to cross-border operations.

The paper highlights four key findings:

• Divergence between Member States is often a bigger cost driver than any single regulatory requirement.

• Fragmentation extends beyond directive transposition and also arises through opening clauses, national guidance, administrative practices and regional measures.

• Minimum-harmonisation legislation can still create significant Single Market fragmentation.

• Gold-plating occurs at both national and sub-national levels.

The European Commission should address these issues through greater consistency in implementation, increased transparency around national additions, reduced duplication in reporting and registration requirements, stronger implementation dialogue and the use of Single Market enforcement tools where appropriate. The objective is not to remove legitimate national discretion, but to prevent unnecessary regulatory barriers within the Single Market.