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Ecommerce Europe

Ecommerce Europe represents online retailers in Europe, working to shape EU digital commerce rules.

Lobbying Activity

Meeting with Isabelle Perignon (Director Justice and Consumers)

5 Dec 2025 · Exchange of views on the Digital Fairness Act (DFA) and on the revision of the Consumer Protection Cooperation (CPC)

Ecommerce Europe urges caution on EU postal delivery reforms

14 Nov 2025
Topic — Proposed EU Delivery Act to replace postal services and parcel delivery regulations.
Message — The organization requests that any regulatory intervention be evidence-based and clearly justified by market failure. They advocate for maintaining flexibility for Member States to adapt universal service obligations to national circumstances while preserving minimum basic services. They strongly oppose broadening postal framework definitions to include fundamentally different business models like local commerce platforms and app-based delivery services.1234
Why — This would protect their members from increased compliance burdens and preserve competitive market conditions that enable innovation and affordable services.56
Impact — Consumers and small businesses could lose competitive delivery options and innovation if broad regulations stifle market diversity.7
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Ecommerce Europe urges EU to prioritize product reuse in Circular Economy Act

5 Nov 2025
Topic — New EU Circular Economy Act to enhance economic security and promote sustainable production.
Message — The organization requests specific measures to foster product reuse and prevent waste, noting this aspect is currently absent from planned legislation. They propose an expanded circular economy definition that explicitly covers reuse activities and call for legal clarity on concepts like refurbishment, repurposing, and upgrading. They want products already on the market exempted from EPR fees when resold.1234
Why — This would reduce regulatory burdens and avoid financial penalties on their members' second-hand sales operations.567
Impact — Recycling industries lose priority if reuse activities receive greater regulatory support and funding.8
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Ecommerce Europe urges Commission to abandon Digital Fairness Act

24 Oct 2025
Topic — Proposed EU legislation to strengthen consumer protection against unfair digital practices.
Message — The association argues that existing EU laws already address problematic practices and opposes new legislation. Instead, they request the Commission focus on enforcing current rules, improving cross-border cooperation between authorities, and developing clearer guidance on how existing laws apply to digital practices.123
Why — This would prevent increased compliance costs and regulatory complexity for online merchants.456
Impact — Consumer groups lose additional protections against misleading practices and unfair personalization online.7
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Ecommerce Europe urges alignment of cookie rules with GDPR

14 Oct 2025
Topic — EU simplification of digital regulations including cookies, cybersecurity, data rules, and AI.
Message — The organization requests aligning Article 5(3) of the ePrivacy Directive with GDPR's six legal bases for data processing, moving beyond consent-only requirements for cookies. They seek clear exemptions for low-risk activities like security, fraud prevention, and functional cookies. They also call for streamlined cybersecurity reporting through a single portal and delayed AI Act enforcement until specifications are available.1234
Why — This would reduce cookie consent fatigue and enable use of legitimate interest for tracking technologies, lowering compliance costs.56
Impact — Consumers lose stronger privacy controls as tracking could proceed without explicit consent based on legitimate interest.78
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Ecommerce Europe urges impact assessment for product documentation digitalisation

3 Sept 2025
Topic — A consultation on digitalising product documentation and operator contact points across the EU.
Message — The group requests impact assessments to evaluate costs for small businesses. They also want clear definitions for digital contact requirements. Finally, they advocate for minimum standards for national enforcement authorities.123
Why — This would reduce compliance costs for small businesses and eliminate redundant communication requirements.45
Impact — Consumers may lose guaranteed access to telephone support for product complaints and inquiries.6
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Ecommerce Europe urges transparency in digital product reporting rules

3 Sept 2025
Topic — Aligning EU product legislation with the digital age through digitalised documentation and reporting.
Message — The association requests a thorough impact assessment on the costs of digitising physical documentation. They seek clarification on digital contact definitions and propose replacing mandatory telephone numbers with flexible digital channels.123
Why — The sector would avoid high operational costs and administrative burdens from redundant communication requirements.45
Impact — Consumers may lose access to traditional phone support if businesses switch entirely to digital chat tools.6
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

Ecommerce Europe welcomes the update of the New Legislative Framework to become a model, forward-looking tool supporting a strong Digital and Circular Single Market in the face of global challenges and transitioning economy. Thanks to its multifunctional structure, the framework was successful in setting the vision and general principles of the EU product acquis, and, in parallel, it has served as blueprint for more recent product rules. However, new opportunities and challenges arising in the field of product policy are stress-testing the framework, which was only partly tweaked since its introduction in 2008. In the near future, the adjustment of the NLF provisions will help foster the import of compliant products, fluidify their cross-border movement in the EU, and reinstate a level playing field between law-abiding companies and rogue traders. Given the potential of a fit-for-purpose NLF to address urgent challenges related to the overflow of non-compliant products in the EU, Ecommerce Europe calls on the European Commission to undertake a comprehensive and holistic approach in revising the framework legislation. The aim of the NLF revision should be to tweak the framework in a way that it lives up to current challenges affecting product compliance without overburdening policymakers, enforcers and diligent businesses. Please find our extensive proposals for legislative and non-legislative action attached.
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Ecommerce Europe urges enforcement focus over new consumer laws

28 Aug 2025
Topic — The EU is developing its consumer policy strategy for 2025-2030.
Message — The association opposes a new Digital Fairness Act, arguing the current regime is fit for purpose. They request measures to remove redtape for cross-border business operations and prioritize EU level guidance.12
Why — This would lower compliance costs and allow retailers to maintain flexible business models.34
Impact — Non-European retailers face tougher scrutiny and potential sanctions for unfair commercial practices.56
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Ecommerce Europe warns against reopening GDPR for simplification

25 Aug 2025
Topic — This consultation proposes reducing record-keeping burdens for small mid-cap companies.
Message — They demand simplification via EU guidance rather than reopening regulations. They argue size-based exemptions create unnecessary regulatory complexity.12
Why — Centralized tools would reduce compliance costs while protecting existing investments.3
Impact — Individuals face higher risks if large-scale data processing firms receive exemptions.4
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Ecommerce Europe urges flexible exemptions to garment destruction ban

8 Aug 2025
Topic — EU consultation on specific cases where destroying unsold clothes remains legally permitted.
Message — They request removing requirements to prove no recipient was found and shortening record-keeping periods. The group also wants to destroy goods failing voluntary company quality standards.123
Why — Retailers would avoid high administrative costs and maintain control over brand quality standards.45
Impact — Sustainability advocates lose as businesses could destroy more items by citing internal quality standards.6
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Ecommerce Europe demands simpler data rules and cookie law reform

18 Jul 2025
Topic — The strategy aims to streamline EU data rules to facilitate sharing while protecting privacy.
Message — The association requests a harmonised data framework that clarifies definitions and simplifies international transfers. They advocate aligning the ePrivacy Directive with GDPR to allow cookie exemptions for low-risk processing.1234
Why — Harmonised rules would lower compliance costs and provide the predictability required for investment.56
Impact — Consumer groups lose easier privacy protections if centralized browser-level consent management tools are blocked.7
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Meeting with Maria Guzenina (Member of the European Parliament)

16 Jul 2025 · Circular economy

Meeting with François Kalfon (Member of the European Parliament)

16 Jul 2025 · Protection des consommateurs

Ecommerce Europe urges simpler reporting on unsold consumer goods

10 Jul 2025
Topic — The Commission is defining how companies must disclose information about unsold consumer products.
Message — The group seeks to minimize administrative burdens and prevent retroactive reporting requirements. They propose that only the product owner making discarding decisions should be responsible. They also suggest using average weight estimates and clear product categories for compliance.123
Why — Streamlined reporting and the use of estimates would lower businesses' compliance costs.45
Impact — Environmental monitoring groups may receive less precise data due to reporting variations.6
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Meeting with Michael McGrath (Commissioner) and

1 Jul 2025 · Exchange of views on simplification, consumer protection and the forthcoming Digital Fairness Act

Meeting with Pierre Jouvet (Member of the European Parliament)

30 Jun 2025 · économie circulaire

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

13 Jun 2025 · Discussion on the future Circular Economy Act, specifically on the role of EPR and the possibility to digitalise the registration and reporting obligations

Meeting with Maria Velentza (Director Competition) and

22 May 2025 · Exchange of views on EU payment markets

Meeting with David Cormand (Member of the European Parliament, Rapporteur)

16 Apr 2025 · New legislative framework

Meeting with Aurore Lalucq (Member of the European Parliament, Committee chair)

10 Apr 2025 · Payments

Meeting with Jessika Roswall (Commissioner) and

9 Apr 2025 · Circular Economy

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Bureau Européen des Unions de Consommateurs and

19 Mar 2025 · Code of Conduct on Online Advertising – Workshop 4

Meeting with Elisabeth Grossmann (Member of the European Parliament, Shadow rapporteur) and Classifieds Marketplaces Europe

19 Mar 2025 · exchange of views on NLF

Meeting with Fernando Navarrete Rojas (Member of the European Parliament, Rapporteur)

14 Mar 2025 · DIGITAL EURO

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Apple Inc. and

13 Mar 2025 · Code of Conduct on Online Advertising – Workshop 3

Meeting with Brando Benifei (Member of the European Parliament)

12 Mar 2025 · E-commerce and product Safety

Ecommerce Europe warns against mandatory cross-border delivery requirements

11 Mar 2025
Topic — This evaluation examines if the Geo-blocking Regulation effectively ensures non-discriminatory access to goods.
Message — The organization strongly opposes any legal obligation for online merchants to deliver goods across all EU countries. They argue that the current regulation is a balanced instrument that does not require reopening. Instead, they urge the Commission to focus on harmonizing rules regarding packaging, labeling, and taxation.123
Why — This approach protects retailers from incurring prohibitive logistical costs and unnecessary technical infrastructure investments.45
Impact — Consumers in specific markets lose access to broader product catalogues and international delivery services.6
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Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné)

11 Mar 2025 · Introduction of the Federation and discussion on the different issues contained in the “Manifesto for European Elections

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

6 Mar 2025 · Code of Conduct on Online Advertising – Workshop 2

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

4 Mar 2025 · Code of Conduct on Online Advertising – Workshop 1

Meeting with Rita Wezenbeek (Director Communications Networks, Content and Technology) and

11 Feb 2025 · Opening Session: DSA roundtable discussions on online advertising (Article 46 DSA)

Meeting with Auke Zijlstra (Member of the European Parliament)

6 Feb 2025 · Cost of payments

Meeting with Eric Ducoulombier (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

5 Feb 2025 · Cost of payments

Ecommerce Europe urges deeper single market integration and digitalization

31 Jan 2025
Topic — The European Commission is seeking evidence for its Single Market Strategy 2025.
Message — The group requests harmonized waste definitions and a digital interface for producer responsibility. They also advocate for a level playing field against non-EU competitors.123
Why — Streamlined reporting and harmonized rules would lower administrative costs for online retailers.45
Impact — Non-EU companies would face stricter enforcement and higher costs to match EU standards.67
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Meeting with Virginijus Sinkevičius (Member of the European Parliament)

30 Jan 2025 · payment systems

Meeting with Dirk Gotink (Member of the European Parliament, Rapporteur) and ECTU - European Shippers' Council

27 Jan 2025 · EU customs legislation, e-commerce

Meeting with Laura Ballarín Cereza (Member of the European Parliament, Shadow rapporteur)

9 Jan 2025 · Green Claims

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

12 Dec 2024 · E-commerce

Meeting with Oliver Schenk (Member of the European Parliament)

3 Dec 2024 · Digitaler Binnenmarkt und Nachhaltigkeit

Meeting with Gilles Boyer (Member of the European Parliament)

21 Nov 2024 · ECON payments files

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

15 Oct 2024 · discussion on Green Claims Directive

Ecommerce Europe urges risk-based rules for protecting minors online

27 Sept 2024
Topic — The Commission is consulting on new safety guidelines for protecting minors online.
Message — The group asks for a risk-based approach using non-mandatory good practices. Measures should be proportionate to the actual risks of a business model. They argue existing EU laws already provide a robust safety framework.123
Why — Online merchants would avoid high costs by not implementing universal age verification.4
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Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

12 Aug 2024 · E-commerce

Response to Interoperable interface of the Safety Gate Portal

19 Feb 2024

Ecommerce Europe welcomes the opportunity to comment on the European Commissions draft Implementing Regulation on the interoperability of the Safety Gate Portal with the interface of providers of online marketplaces. We are committed to supporting the Commissions efforts to enhance efficiency and automation in ensuring that providers of online marketplaces are empowered to take appropriate (voluntary) action in case of dangerous products being offered on their online marketplace. Nevertheless, we would like to address two shortcomings of the current draft act. Please find our full feedback attached.
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Response to Advanced alternative dispute resolution for consumers

14 Dec 2023

Ecommerce Europe welcomes the opportunity to provide additional input to the Commission on the revision of the Alternative Dispute Resolution (ADR) framework. We consider that there is room for improvement in the Commission proposal to alleviate unintended negative consequences (e.g. scope), improve trader participation in ADR schemes and ultimately facilitate better consumer protection. With this paper, we would like to share our views on the current proposal and how it could be improved to benefit all the stakeholders involved.
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Response to Advanced alternative dispute resolution for consumers

14 Dec 2023

Ecommerce Europe welcomes the opportunity to provide additional input to the Commission on the revision of the Alternative Dispute Resolution (ADR) framework. We consider that there is room for improvement in the Commission proposal to alleviate unintended negative consequences (e.g. scope), improve trader participation in ADR schemes and ultimately facilitate better consumer protection. With this paper, we would like to share our views on the current proposal and how it could be improved to benefit all the stakeholders involved.
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Meeting with Laura Ballarín Cereza (Member of the European Parliament, Rapporteur) and European Advertising Standards Alliance and facua - consumidores en accion

5 Dec 2023 · ADR/ODR

Meeting with Petri Sarvamaa (Member of the European Parliament)

14 Nov 2023 · Proposal on Customs Reform

Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and

7 Nov 2023 · Reform of the Union Customs Code

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Eastman Chemical Company and Radisson Hotel Group

23 Oct 2023 · Green Claims Directive

Response to Revision of the Union Customs Code

20 Oct 2023

Ecommerce Europe welcomes the opportunity to provide feedback on the European Commissions proposal for a revision of the Union Customs Code (UCC). This proposal is a clear step forward to strengthening the legal framework for customs and to making it suitable to address the challenges that have emerged in recent years. However, Ecommerce Europe also believes that whether this objective is achieved and whether newly introduced obligations are proportional for e-commerce actors will depend on a lot of operational details which are currently missing. In our attached paper, we have tried to highlight the key points for reflection on all the proposed changes to the UCC.
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Meeting with Deirdre Clune (Member of the European Parliament, Rapporteur) and American Chamber of Commerce to the European Union

17 Oct 2023 · Customs Reform

Response to Revision of the Union Customs Code

5 Sept 2023

Ecommerce Europe welcomes the opportunity to provide feedback on the European Commissions proposal for a revision of the Union Customs Code (UCC). This proposal is a clear step forward to strengthening the legal framework for customs and to making it suitable to address the challenges that have emerged in recent years. In this paper, we have structured our position into a general section on the Customs Reform proposal and some specific sections addressing certain measures of the proposed revision.
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Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur)

23 Aug 2023 · STAFF LEVEL - Customs reform

Ecommerce Europe urges harmonised guidance for green claims rules

21 Jul 2023
Topic — This consultation addresses new rules requiring companies to substantiate their environmental claims.
Message — The group requests clear guidance to avoid overlaps with other sustainability laws. They advocate for a regulation rather than a directive to prevent legal fragmentation. They also suggest exempting second-hand goods and extending the transition period.123
Why — Better harmonisation would reduce legal complexity and administrative costs for cross-border retailers.45
Impact — Smaller manufacturers may be priced out by expensive and slow verification procedures.67
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Ecommerce Europe Urges One-Stop-Shop for EU Packaging Rules

24 Apr 2023
Topic — The Commission proposal seeks to harmonise packaging requirements and reduce waste across the single market.
Message — The group requests a digital one-stop-shop for registration and reporting to streamline producer responsibility across Member States. They propose that the 40% empty space limit be calculated as a company-wide average rather than for individual parcels. Additionally, they argue that waste prevention measures should contribute toward reaching mandatory reuse targets.123
Why — This would significantly lower the administrative and financial costs associated with complying with diverse national rules.45
Impact — Environmental groups lose if flexible averaging allows businesses to avoid strict packaging reduction for specific products.6
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Meeting with Krzysztof Hetman (Member of the European Parliament, Shadow rapporteur)

24 Apr 2023 · Exchange of views on Product Liability Directive (meeting delegated to parliamentary assistant)

Response to VAT in the Digital Age

3 Apr 2023

Ecommerce Europe welcomes the opportunity to provide feedback on the VAT in the Digital Age proposal of the European Commission, which is a big step forward to delivering a simplified and modernised VAT system in the EU. Please find enclosed our comments. Our paper addresses first and foremost the pillar of Single VAT Registration in the EU as this will be a key simplifier for businesses operating in the EU. However, alongside the comments on the changes to the UOSS and IOSS, our paper will also touch upon the main changes proposed by the Platform economy and Digital reporting requirements pillars. As technical discussions progress, we encourage the EU Commission and EU countries to consider a phased approach to adopt the proposal. To strengthen the EU Single Market and remove blockers for cross-border trade, the most urgent action is needed to ensure the implementation of the single VAT registration concept, including the introduction of the transfer module and the expansion of the Union One Stop Shop scheme.
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Ecommerce Europe defends One-Stop-Shop in GDPR enforcement overhaul

24 Mar 2023
Topic — New rules intended to streamline cooperation between national data protection authorities.
Message — The group requests that the initiative focuses exclusively on cooperation between national authorities. They demand that the right to be heard is extended to include the EDPB. They argue against granting official party status to complainants during privacy investigations.123
Why — This approach would provide greater regulatory predictability and lower compliance burdens for businesses.4
Impact — Privacy advocacy groups would be denied legal status and access to investigation files.5
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Meeting with Mairead McGuinness (Commissioner) and EuroCommerce and

28 Feb 2023 · round-table on digital euro

Response to Determination on the equivalence of information exchanged by non-Union Jurisdiction on digital platforms (“DAC7”)

16 Feb 2023

Ecommerce Europe welcomes the opportunity to provide feedback to the European Commission on the DAC7 equivalence. In the attached paper, we have pointed out some key considerations when determining the interoperability of DAC7 with third-country information exchange regimes.
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Response to Advanced alternative dispute resolution for consumers

20 Dec 2022

Ecommerce Europe welcomes the opportunity to provide additional input for the Commissions evaluation process. Overall, we consider that the Directive has successfully created a standard for EU-wide out-of-court commercial dispute resolution mechanisms. Wide-spread infringements have been better tackled thanks to an enhanced cooperation among EU public authorities. However, Ecommerce Europe notes that there is room for improvement in the EU framework which will help trader participation in ADR schemes and ultimately facilitate better consumer protection. With the paper attached, we would like to share our views on the most relevant aspects to include in the ongoing evaluation.
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Ecommerce Europe Urges Dialogue Over Fines in Consumer Law

20 Dec 2022
Topic — EU initiative to update the regulation for cross-border consumer protection cooperation.
Message — The association advocates for a focus on preventing non-compliance through dialogue rather than punitive fines. They request that authorities issue warnings to give traders time to adapt.12
Why — Online retailers would avoid immediate penalties and benefit from reduced compliance costs.3
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Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur) and EuroCommerce and

3 Nov 2022 · Empowering consumers for the green transition

Ecommerce Europe Urges Harmonised Customs and Simpler Trade Rules

19 Sept 2022
Topic — Revision of the Union Customs Code to address e-commerce and technological challenges.
Message — The group calls for harmonised customs processes and expanded benefits for Authorised Economic Operators. They request that data requirements reflect business reality and avoid duplicating existing reporting obligations.123
Why — Greater efficiency would lower import costs and minimize delivery delays for digital commerce.4
Impact — Fraudulent actors would lose the ability to exploit inconsistent customs enforcement between member states.5
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Response to Evaluation of administrative co-operation and fight against fraud in the field of VAT

25 Jul 2022

Ecommerce Europe would like to thank the Commission for the opportunity to participate in this call for evidence. Administrative cooperation and robust enforcement mechanisms are crucial to the fair and effective functioning of the EU VAT system. We therefore understand the purpose of the various VAT reporting regimes in place (recapitulative statements, Intrastat, article 242a) as well as those that are forthcoming – DAC7 (Council Directive 2021/514), Payment Service Provider (PSP), VAT data reporting (Council Directive 2020/284), EU digital reporting regime (DRR) etc. However, as requirements expand, we urge the Commission to consider both the volume of requirements placed on EU taxpayers and how the limitations of those requirements can be minimised. As regards volume, a more holistic approach could be adopted to data sharing, such that, as far as possible, data is shared once within the EU, consolidated and reconciled between sources and then be shared between Member States as needed under administrative cooperation agreements. Continued layering and duplication of VAT (and income-tax) data reporting requirements is not sustainable and places increasing burden on businesses. A review of the current landscape with a view to data minimisation is therefore needed. Regarding limitations, we note that anti-VAT fraud initiatives are only as powerful as the ability to enforce them. We therefore call for regimes to be scoped appropriately, with strong enforcement measures that are not solely reliant on multi-lateral administrative cooperation treaties. An example is the forthcoming PSP data sharing rules (from 2024), which will enable EU governments to ‘follow the money’ in order to identify areas of non-compliance. However, the effectiveness is so far limited as only EU PSPs are in scope. This compromises the effectiveness of the regime against fraud and non-compliance as it limits the data that Member States will receive on non-EU merchants selling in the EU, who will typically use non-EU PSP. We note that administrative cooperation agreements with third countries remain of significance in order to ensure adequate enforcement against non-EU businesses where they are in scope of EU tax rules; in this regard, we reiterate our support to the European Commission in its efforts to find administrative cooperation agreements with third countries. Whilst we urge the Commission to consider how the above challenges can be addressed at national level, we recognise that individual taxpayers will continue to play a key part in the fight against VAT fraud. With this in mind, we provide detailed feedback attached on how the VAT Information Exchange System (VIES) can be strengthened to better support taxpayers in this role. The primary ask within this is that the system is upgraded to keep pace with the increasing number of uses the VIES on-the-web VAT number validation has for taxpayers. Crucially, system capacity should be increased to allow to submit greater numbers of validation requests per day.
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Ecommerce Europe claims existing consumer laws are fit for purpose

14 Jun 2022
Topic — Evaluation of whether current EU consumer laws effectively protect people in digital markets.
Message — Ecommerce Europe believes the current legal framework is fit for purpose. They urge focusing on improving enforcement and harmonizing interpretation of existing rules. The Commission should avoid 'dark patterns' and use 'online choice architecture' instead.123
Why — This would help companies avoid legal uncertainty and the cost of overlapping rules.4
Impact — Consumers lose specific digital protections if the EU relies solely on existing, poorly-enforced rules.5
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Response to Empowering the consumer for the green transition

29 May 2022

We welcome the opportunity to provide preliminary feedback on the Proposal for a Directive on empowering consumers for the green transition through better protection against unfair practices and better information. Ecommerce Europe welcomes the European Commission’s work on harmonising and clarifying how existing consumer legislation applies to environmental claims and sustainable aspects of products and services. We would first like to stress that this proposal will amend two pieces of legislation not yet implemented by all EU Member States. We therefore strongly urge policy-makers to refrain from adopting any additional requirements not strictly in the scope of this proposal that would amend other aspects of the UCPD and the CRD. This would create significant confusion and considerably impact legal certainty for companies and their ability to prepare and comply with new rules. These new rules should focus on the ultimate objective of this revision which aims to ensure that consumers have access to relevant and understandable information presented in a way that is adapted to the environment they are shopping in. The revision of these Directives should be flexible enough to allow companies to streamline various environmental claims or layer information to cater for different consumer needs and behaviour (i.e., putting the main performance, repairability and durability level of the product on the first layer of information, with additional layers or links for those customers who may want to dig deeper). In this context, we would like to raise a series of concerns about the current proposal, detailed in the paper attached.
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Response to VAT in the Digital Age

4 May 2022

Ecommerce Europe welcomes the opportunity to reply to the call for evidence on the VAT in the Digital Age proposal of the European Commission. Ecommerce Europe fully supports the European Commission’s ambition to reduce VAT-related barriers for cross-border trade in the EU, in particular the work towards a single EU VAT registration. A single VAT ID will be a huge simplifier to reduce the need for costly and time-consuming multiple VAT registrations that are today still required despite the 2021 changes introduced by the VAT E-commerce Package. In the current system, neither movements of retail inventory across EU countries, nor the onward sale of that inventory, are eligible for the VAT One-Stop Shop (OSS) system, resulting in VAT registration requirements for every EU country of storage. This means that, despite the expansion of the VAT OSS scheme on 1 July last year, businesses will still be required to VAT register in every country in which they store stock (even in situations where sales activities are not undertaken in the storage location). Businesses should be able to choose to store inventory closer to their customers to shorten delivery times, and to report VAT on their entire EU logistics chain through a single portal. In particular, it is key that the upcoming VAT in the Digital Age reform extends to: (1) cross-border movement of own inventory across the EU (with no or limited cash-flow cost for businesses), and (2) domestic B2C sales of goods by a seller that is not established in that EU country. It should also be allowed to report domestic B2B sales unless a wide-ranging pan-EU reverse charge mechanism is implemented for domestic sales. Without this change, the EU VAT system will continue to disadvantage European businesses and put administrative borders across the Single Market. Currently, a business must file an average of 13 documents to complete one VAT registration process, wait for 100 days on average to receive a VAT number, submit up to 60 VAT & statistical filings per country yearly, and spend thousands of Euros in compliance costs. The importance of this matter to the European businesses, particularly small and medium-sized enterprises (SMEs), is also highlighted in a dedicated Campaign on this topic that we launched to raise awareness of the need for this reform: https://simplify-vat.eu/ The benefits of a Single VAT ID extend to tax authorities, customs authorities, national treasuries, businesses, consumers and the environment: • Tax authorities will benefit from increased compliance, facilitated reporting and auditing of cross-border goods movements. • National governments will benefit from a more competitive EU market and increased trade, leading to additional tax revenues. • Businesses, particularly SMEs, will gain greater access to intra-EU trade, be more competitive and incur fewer tax compliance fees. Besides e-commerce, benefits extend to other sectors too such as toll manufacturing, leasing of moveable property, wholesaling, manufacturing with movement of machinery etc. • End-consumers will be able to access more competitive prices, faster delivery and a greater choice of goods. • The advantages of a Single VAT ID also extend to environmental concerns. For example, a regime covering pan-EU inventory storage in e-commerce would encourage bulk inventory placements close to customers, which have considerably lower CO2 emissions than orders individually shipped for long distances . • As well as being green, bulk shipments from third countries also reduce burdens on national customs authorities compared to individual packet shipments. Given the wide-ranging benefits, Ecommerce Europe calls on the EU Institutions, and in particular the European Commission, to publish and adopt legislative proposals for a single EU VAT registration number in order to complement the VAT OSS and enable businesses selling online to have a unique VAT ID and report all the VAT through the single digital VAT portal.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Ecommerce Europe welcomes the opportunity to provide feedback to the call for evidence for an impact assessment on the revision of the EU waste framework. Waste management plays a key role in decreasing waste generation but also represents an important tool for the transition to a circular economy. The revision of the Waste Framework Directive (WFD) will give an opportunity to align the rules on future pieces of legislation that will be proposed later this year, such as the Sustainable Product Initiative, the Waste Shipment Directive, the revision of the Packaging and Packaging Waste Directive (PPWD), but also other sector-specific initiatives. We would like to seize this opportunity to present the following priorities for the revision of the WFD, detailed further in the paper attached: • Ensure the alignment of the Waste Framework Directive with the waste hierarchy and upcoming pieces of legislation on sustainable products (as well as sector-specific initiatives) and the promotion of repair and reuse; • Create a real single market for waste intended for reuse, repair and recycling with the harmonisation of legislation and definition in the EU; • Harmonise waste and EPR legalisation to allow companies to operate cross-border and boost compliance; • Re-think the way we communicate and raise awareness about the question of handling of products and waste.
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Response to EU strategy for Customs risk management

2 Nov 2021

Ecommerce Europe welcomes the initiative of the EC to gather stakeholders’ feedback on the revision of the EU Strategy for Customs Risk Management. We believe the following elements should be key to such a strategy, while ensuring a level playing field between all stakeholders: 1. Strengthening the EU Authorised Economic Operator (AEO) Programme by fostering process-based controls and pursuing centralised clearance for trusted traders • A key mechanism to increase efficiency of EU customs should be to further facilitate trade by trusted traders, as this will support compliant and legitimate businesses while allowing customs authorities to focus more on fraud and non-compliance risk areas. The AEO programme should be incrementally improved in terms of simplifications and moved from a transaction-based to a process-based approach. In addition, the true potential of centralised clearance for AEO needs to be unlocked by providing unilateral clearance capabilities to the supervising customs office. • Other reforms for AEO traders should include: o Clearance procedures based on entry in declarant’s records needs to become a standard, while other ways of clearing of goods (today’s standard and simplified declarations) only back-up solutions for AEO trusted traders. o Self-assessment needs to become a common feature across the AEO traders, especially in respect of determining the amount of import and export duty payable, as well as performing certain controls under customs supervision. AEO traders should have access to post-entry customs clearance data to identify inconsistencies with e.g. Import One Stop Shop (IOSS) reporting. o The formal process to obtain various AEO authorisations should be incrementally shortened and simplified while maintaining sufficient guardrails. o Further simplifications for other trusted traders should be considered, such as operators / marketplaces using the IOSS to collect and remit VAT on imported consignments not exceeding 150 EUR sold by third parties. o To boost exports out of the EU, consider introducing simplified confirmation of export by an AEO / trusted trader. 2. Harmonisation and simplification of customs processes • Further work is needed to ensure harmonised application of the Union Customs Code, its secondary legislation and local processes/guidelines in Member States. The non-unified approach by the customs authorities of different EU Countries in terms of interpretation and practical application of customs legislation combined with a highly diverging risk perception across member states results in: o very significant differences in pre-clearance and clearance processes as well as average lead times and inspection rates across member states. This is regardless of similar risk elements such as content, origin, valuation, importer and exporter or routing. o a valuation method or classification approved in one Member State is challenged by another Member State’s authorities. This today happens despite a binding tariff information in place. • In light of the above, further efforts by EU policymakers are needed to drive standardisation in the process and approach of the Member States’ authorities. • There is an urgent need for an EU harmonised and transparent list of prohibited and restricted (and excisable) goods, to limit possible unintended use of simplified procedures (either H7 dataset or entry in the declarant's records) for customs clearance of certain goods. 3. Efficiently address the increased e-commerce flows • The EU customs environment should be adapted to the trends and needs in the consumer business, where same/next day deliveries have become industry standards. Customs processes should be simplified, and clearance times should be shortened while ensuring increased risk control capabilities. • The functioning of the IOSS should be evaluated, and misuse of IOSS numbers should be measured and mitigated by implementing end-to-end customs data sharing mechanism.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

20 Apr 2021 · Artificial Intelligence, Platform Workers legislation

Response to Detailed implementing rules for the VAT e-commerce trade

18 Mar 2021

Dear Sir / Madam, Please find enclosed the contribution of Ecommerce Europe on the detailed implementing rules for the VAT e-commerce trade. Our contribution focuses on the data harmonisation and the clarity on the technical requirements for the businesses. Ecommerce Europe is the voice of the Digital Commerce sector in Europe. As a result of joining forces with EMOTA, Ecommerce Europe represents, via its 23 national associations, more than 100.000 companies selling goods and services online to consumers in Europe. Ecommerce Europe has a strong membership basis that involves national associations, company members, business partners (like postal operators, carriers and payment providers), and associative partners. https://ecommerce-europe.eu/
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Response to Digital Levy

10 Feb 2021

Ecommerce Europe, the European Digital Commerce Association, welcomes the opportunity to provide constructive feedback to the European Commission’s inception impact assessment (i.e. roadmap) on the introduction of a European digital tax called “a fair & competitive digital economy – digital levy”, which was published on 14 January 2021. Please refer to the detailed Position Paper attached for further information.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

20 Jan 2021 · DSA, DMA

Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

Please refer to the document attached for detailed feedback from Ecommerce Europe.
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Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

Ecommerce Europe welcomes the opportunity to provide its feedback on the implementation of the GDPR. Ecommerce Europe is the sole voice of the European Digital Commerce sector. As a result of joining forces with EMOTA, Ecommerce Europe now represents, via its 24 national associations, more than 100,000 companies selling goods and services online to consumers in Europe. Ecommerce Europe acts at European level to help legislators create a better framework for online merchants, so that their sales can grow further. Please find our feedback attached.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

24 Jan 2020 · Max harmonisation to support single market, platforms relations with traders, ePrivacy, eCommerce Directive revision, digital taxation

Response to A new Circular Economy Action Plan

20 Jan 2020

Ecommerce Europe welcomes the opportunity to contribute to the consultation on the European Commission’s Roadmap for the New Circular Economy Action Plan. The transition towards a sustainable, climate-neutral European economy requires full involvement of all actors, as well as clear, harmonized and forward-looking policies. This transition necessitates a cross-cutting approach to policymaking to ensure that all the value-chains can contribute to reaching ambitious and achievable objectives. The digital commerce sector has embraced the transition towards a circular economy as both a necessity and an opportunity to continuously innovate. Online merchants know the role they can play in the transition of our economy and have been developing new solutions and business models, implementing best practices on the ground for years to reduce the impact on the environment, and proactively offer consumers more sustainable options. Naturally, online merchants also recognize that there is a long way to go to ensure the transition of our economy. Therefore, Ecommerce Europe welcomes the European Commission’s ambition to further accompany these changes. Regarding the Roadmap, Ecommerce Europe would like to highlight certain preliminary principles that should be at the core of any future policy developments on circular economy in the attached contribution.
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Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip)

11 Jun 2019 · DSM

Response to Exchange of VAT-relevant payment data

4 Feb 2019

Ecommerce Europe, the European e-commerce association, welcomes the opportunity to provide feedback on the different VAT proposals put forward by the European Commission in December 2018 with new rules for e-commerce including a new role for online marketplaces with the VAT collection on internet sales (COM(2018) 819 final and COM(2018) 821 final) and introducing certain requirements for payment service providers to tackle VAT fraud (COM(2018) 812 final). Ecommerce Europe fully supports the stated objectives to fight against VAT fraud and to improve VAT collection on internet sales, whilst easing administrative burden for businesses selling online. However, in order to achieve these policy objectives and ensure a smooth transition into the new VAT rules, Ecommerce Europe wants to stress the importance of adopting a channel-neutral approach on electronic interfaces that facilitate sales of goods or services. Without a broad and future-proof definition of “facilitation” and a set of appropriate enforcement measures, there is a high risk of creating an unfair framework, which would be open to loopholes and of not achieving the objectives of simplifying VAT compliance and improving VAT collection. This document provides further guidance to policymakers in order to achieve these important goals. We look forward to supporting the European Commission and the Council in ensuring an effective implementation of VAT legislation that will contribute to the creation of a level playing field.
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Response to Implementation of the VAT e-commerce package

4 Feb 2019

Ecommerce Europe, the European e-commerce association, welcomes the opportunity to provide feedback on the different VAT proposals put forward by the European Commission in December 2018 with new rules for e-commerce including a new role for online marketplaces with the VAT collection on internet sales (COM(2018) 819 final and COM(2018) 821 final) and introducing certain requirements for payment service providers to tackle VAT fraud (COM(2018) 812 final). Ecommerce Europe fully supports the stated objectives to fight against VAT fraud and to improve VAT collection on internet sales, whilst easing administrative burden for businesses selling online. However, in order to achieve these policy objectives and ensure a smooth transition into the new VAT rules, Ecommerce Europe wants to stress the importance of adopting a channel-neutral approach on electronic interfaces that facilitate sales of goods or services. Without a broad and future-proof definition of “facilitation” and a set of appropriate enforcement measures, there is a high risk of creating an unfair framework, which would be open to loopholes and of not achieving the objectives of simplifying VAT compliance and improving VAT collection. The attached document provides further guidance to policymakers in order to achieve these important goals. We look forward to supporting the European Commission and the Council in ensuring an effective implementation of VAT legislation that will contribute to the creation of a level playing field.
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Meeting with Andrus Ansip (Vice-President) and

20 Sept 2018 · GDPR, privacy shield, e-privacy

Response to Detailed measures for the Definitive VAT System

24 Aug 2018

Through its 20 national e-commerce associations, Ecommerce Europe represents the interests of more than 75,000 companies selling goods and/or services online to consumers in Europe. Ecommerce Europe would like to share with the European Commission its views regarding the Commission’s Proposal for a Directive on the Definitive VAT System (DVS) and, in particular, on the detailed technical amendments for the DVS included in COM (2018) 329 FINAL. As the voice of the European e-commerce sector, Ecommerce Europe considers that VAT compliance and administrative costs for businesses should be minimized as much as possible. As also confirmed by Ecommerce Europe’s surveys performed in 2015 and 2016, the complexity of VAT obligations across the Member States is one of the critical reasons why many businesses decide not to engage in EU cross-border trade, in particular online sales of goods. This means that the Single Market cannot be fully accessed by many businesses, in particular SMEs. The growth of the EU and the rise of omni-channel retail require an internal free market able to make it easy to do business between the Member States. In this regard, the introduction of the Definitive VAT System (DVS) for goods aims to remove certain VAT obstacles for businesses, including reduced reporting obligations and simplification of invoicing requirements. Ecommerce Europe considers that the DVS proposals have the real potential to help foster growth of the European economy, by creating a stronger EU Single Market and increased revenues for the Member States. In the paper attached, Ecommerce Europe elaborates its views on some key points covered in the DVS proposals. We hope these points resonate with you and trust that, by doing so, they will be taken into consideration in moving towards a proper single EU VAT area by 2022. We remain available for any questions you may have.
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Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

18 Jul 2018 · Online platforms

Response to Fairness in platform-to-business relations

29 Jun 2018

You will find attached the Position Paper of Ecommerce Europe. We overall welcome the publication of the European Commission’s Proposal for a Regulation on fairness and transparency in online platform trading. In particular, the European e-commerce association appreciates and supports the soft-touch and principle-based approach proposed by the Commission. Online platforms, such as e-commerce marketplaces, are engines of growth and Ecommerce Europe wants to stress that this Regulation should struck the right balance between their interests and the interests of online merchants, especially SMEs that sell via marketplaces. Well balanced also in redress rights which, in the view of Ecommerce Europe, are best served by a transparent complaints-handling completed by a fair mediation system, however not by the proposed representative court action which in our view lacks the balance between collective redress and individual redress. This position paper analyzes in detail the proposed Regulation and gives specific recommendations on how to improve it and achieve this fair balance. We look forward to working together with all EU policymakers on this important legislative file and we remain available for any questions or remarks.
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Response to Targeted revision of EU consumer law directives

21 Jun 2018

Ecommerce Europe overall agrees with the Commission on the fact that EU Consumer Law is generally already fit for purpose and need only some targeted adjustments. Some amendments proposed in the New Deal for Consumers are likely to foster online sales in the European Union by removing current burdensome obligations on online merchants. Nevertheless, Ecommerce Europe questions other adjustments that may ultimately harm businesses. In order to give feedback in an appropriate and comprehensive way, we published a position paper (please see attached) that covers the first proposed Directive to amend the Council Directive on unfair terms in consumer contracts, the Directive on consumer protection in the indication of the prices of products offered to consumers, the Directive concerning unfair business-to-consumer commercial practices and the Directive on consumer rights. The proposed Collective Redress Directive will be covered in a second position paper that will be published in the coming weeks and will be sent to all relevant policymakers. We look forward to continuing working with all EU stakeholders on this important package and we remain at your disposal for any questions you may have on our position paper.
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Response to Measures to further improve the effectiveness of the fight against illegal content online

30 Mar 2018

Ecommerce Europe, the European association representing 75.000+ companies selling online in Europe through its 20 national e-commerce associations, welcomes the opportunity to comment on the European Commission’s initiative for measures to further improve the effectiveness of the fight against illegal content online. Ecommerce Europe shares the Commission’s concern with regard to the dissemination of terrorist content, illegal hate speech, child sexual abuse material. We also agree on the fact that concrete actions are needed to improve outcomes against these pressing issues. As indicated in a joint letter sent to the European Commission on 13 February 2018 together with several stakeholders (see attached), in our understanding, the initial plan of the Commission was to have a targeted instrument to tackle the issue of terrorism-related content. Nevertheless, it is now clear that the Commission’s Recommendation covers also other types of illegal content. Having seen the policy options included in the Inception Impact Assessment (Ref. Ares(2018)1183598 - 02/03/2018), Ecommerce Europe recommends the European Commission to refrain from proposing horizontal legislation that would capture also other types of illegal content such as counterfeiting or product safety. The inclusion of all types of illegal content within the scope of an eventual legislative initiative would not help address the key issues (terrorist content, illegal hate speech, child sexual abuse material) and would make the adoption of such a law more complicated. In the e-commerce sector, such a horizontal legislative initiative could force online marketplaces to be much stricter and quicker in taking down products by third party sellers, without additional verifications that marketplaces run today or without giving the possibility and sufficient time for sellers to appeal any counterfeit notices launched against them. As a consequence, this would be ultimately counterproductive for online merchants and lead to over-takedown from the marketplace. Current acts like the German Netzwerkdurchsetzungsgesetz (NetzDG), in force since January 2018, show already - in some cases - erroneous results in the assessment of suspicious content, leading in some cases to overzealous removals of unproblematic content. Ecommerce Europe welcomes the European Commission’s plans to launch a public consultation and specific stakeholder consultations in the follow-up to the publication of Recommendation C(2018)1177 and would be pleased to be involved in this process.
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Meeting with Andrus Ansip (Vice-President) and

30 Jan 2018 · GDPR, e-privacy

Meeting with Andrus Ansip (Vice-President) and

24 May 2017 · GDPR Implementation and Privacy Shield

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

12 Jan 2017 · Geo-blocking

Meeting with Andrus Ansip (Vice-President) and

19 Dec 2016 · Discussion with industry on general data protection regulation implementation

Meeting with Kilian Gross (Digital Economy)

5 Apr 2016 · geoblocking, online platforms

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

8 Dec 2015 · General data protection regulation and the upcoming review of the E-Privacy directive

Meeting with Renate Nikolay (Cabinet of Commissioner Věra Jourová), Simona Constantin (Cabinet of Commissioner Věra Jourová) and

27 Nov 2015 · Digital Single Market: digital contracts proposal

Meeting with Jasmin Battista (Cabinet of Vice-President Andrus Ansip), Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip) and

24 Nov 2015 · Digital contracts

Meeting with Linsey Mccallum (Cabinet of Commissioner Margrethe Vestager)

10 Feb 2015 · Introduction to Ecommerce Europe

Meeting with Eric Mamer (Digital Economy)

6 Feb 2015 · e-Commerce