Brussels, 26 March 2025
(An Insight EU e-Summary)
While U.S. President Donald Trump announced punitive import tariffs on European cars and car parts, the American Chamber of Commerce to the European Union (AmCham EU) chose a more constructive path—publishing a position paper on March 26, 2025, outlining how to modernize customs systems in the age of e-commerce.
The AmCham EU paper clearly advocates for free, rules-based trade rather than for punitive trade measures such as penalty tariffs. Nowhere in the document is there a justification for protectionism or tariff escalation. Instead, the paper promotes enhanced enforcement mechanisms, data-driven oversight, and public-private cooperation to improve compliance and safety in e-commerce—not to limit trade.
The organization’s overall position emphasizes:
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A risk-based approach to enforcement rather than blanket restrictions.
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Support for harmonized EU customs reform that ensures fairness and transparency across borders.
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A desire to simplify trade for compliant actors through trusted trader programs, not penalize them.
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Wariness of non-discriminatory handling fees that could act like de facto tariffs, especially if they harm low-value or essential shipments.
In the context of US-EU tensions—such as the announcement of US tariffs on EU cars and car parts by President Trump—AmCham EU’s stance is markedly different. It does not advocate for retaliatory or protective measures. Instead, it reflects the interests of American companies invested in Europe, which depend on stable transatlantic trade relations and a non-punitive regulatory environment.
10 takeaways of the Position Paper
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AmCham EU’s Core Message: The position paper highlights the need to modernize Europe’s customs system in response to the exponential growth of e-commerce. It stresses a balance between open trade and regulatory enforcement, aiming to foster a transparent and safe digital market while avoiding undue burdens on legitimate trade. The chamber calls for updated tools, better risk analysis, and increased cooperation between public authorities and private actors.
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Need for Smarter Customs Enforcement: The rise in low-value shipments directly to consumers has created enforcement challenges. AmCham EU proposes leveraging digital solutions—like blockchain and AI—to enable smarter, risk-based customs enforcement. Such technologies would help prevent counterfeiting, fraud, and safety risks without impeding compliant actors.
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Support for UCC Reform: The paper backs the EU’s Union Customs Code (UCC) reform, especially the central EU Customs Data Hub and the creation of a European Customs Authority (EUCA). These would harmonize enforcement and close regulatory loopholes, particularly regarding operators that exploit inconsistencies between Member States. The emphasis is on data-driven regulation, not protectionism.
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Concerns About Deemed Importer Rules: AmCham EU finds current importer liability rules too complex, particularly for non-EU operators. Rather than creating new responsibilities, it recommends improving the existing “Responsible Person” model under the General Product Safety Regulation (GPSR), which better fits diverse business models and supply chains.
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Handling Fees and Inflation Risks: The chamber expresses concern about proposed customs handling fees, arguing they may disproportionately affect essential goods and lower-value shipments, thus burdening consumers during inflation. It proposes exemptions for trusted traders and those registered under the Import One-Stop Shop (IOSS), encouraging voluntary compliance.
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Priority Control Areas and Risk Loops: The proposal supports enhanced customs controls in specific high-risk areas (Priority Control Areas), provided they are data-driven and do not disrupt low-risk flows. It encourages a “Circular Risk Management Process” where real-time inspection results feed back into continuously evolving risk models for more precise targeting.
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Dutch Warehouse Proposal and Fulfilment Models: The Dutch suggestion to move from direct-to-consumer (B2C) to customs-warehouse-based (B2B2C) trade is cautiously welcomed. However, AmCham EU urges that it should complement—not replace—existing systems like the VAT IOSS model. It calls for maintaining multiple compliance channels to protect operational flexibility and consumer choice.
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Enforcement Capacity and Digital Tools: AmCham EU stresses that national customs and market surveillance agencies lack the resources to meet the demands of modern e-commerce. It advocates increased investment in customs staff, digital infrastructure, and real-time cross-border data sharing. The paper also draws on US Customs’ data science capabilities as a model to follow.
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Consumer Protection and Marketplace Trust: The paper outlines ways to boost consumer trust, including trusted trader programs, certifications for compliant marketplaces, and educational tools to help consumers identify safe online sellers. It also supports web-blocking repeat offenders and integrating enforcement databases into consumer-facing platforms.
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Global Cooperation and Conclusion: Finally, AmCham EU calls for stronger international cooperation, especially between the EU and US, to harmonize standards, share best practices, and coordinate enforcement. The overall message is one of building trust, safeguarding consumer interests, and preserving the fluidity of legitimate trade—through reform and innovation, not trade barriers.
Read the full Position Paper
Source of the PDF – AmCham EU