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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.

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.

On Wednesday, 2 September 2026, Malte Lohan, CEO, AmCham EU met with Esteban Moctezuma Barragán, Mexican Ambassador to the European Union, Belgium and Luxembourg, for an introductory meeting to exchange views on the transatlantic business relationship. Discussions focused on opportunities to deepen EU–Mexico economic ties following the signature of the Modernised Global Agreement and interim trade agreement earlier this year. AmCham EU looks forward to continued engagement with Ambassador Moctezuma and to supporting closer EU–Mexico economic cooperation.