American Chamber of Commerce to the EU

Our position Feedback on the Digital Omnibus on AI Regulation proposal AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our position Digital Omnibus Priorities for simplifying the EU’s digital rules AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Circular Economy Act (CEA) represents a crucial opportunity to address longstanding business challenges through simplification and the strengthening of the Single Market. Its success depends on revising the Waste Framework Directive (WFD) and the Waste Electrical and Electronic Equipment (WEEE) Directive, re-opening some provisions of the Waste Shipment Regulation (WSR) and the Single Market Transparency…

Our position An effective, competitive and quality-driven Public Procurement Directive AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

For AmCham EU's full position, please see the attachment. Executive summery: Europe's industrial base faces mounting pressure from high energy costs, global overcapacity, supply chain disruptions and intensifying international competition, while needing to accelerate decarbonisation at scale.

The American Chamber of Commerce to the European Union (AmCham EU) members call for coherence and consistency of all Green Deal legislative proposals and communications, including those that have yet to be released.

The European Commissions targeted revision of the Medical Devices Regulation (MDR) and the In-Vitro Diagnostic Medical Devices Regulation (IVDR) makes progress in addressing longstanding industry concerns through streamlined processes, dedicated pathways for innovations, broader acceptance of non-clinical evidence, regulatory harmonisation, greater clarity for innovative treatments and reducing duplication with…

Our position Digital Networks Act AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe. AmCham EU facilitates the resolution of transatlantic issues that impact business and plays a role in creating better understanding of EU and US positions on business matters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Consultation response Public consultation on the Digital Networks Act (DNA) AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The proposed Packaging and Packaging Waste Regulation (PPWR) presents a significant opportunity to improve the Single Market, align EU packaging regulations and decrease market fragmentation. If well designed, this regulation can be a crucial driver for circularity by promoting economies of scale and ensuring a climate-neutral and circular Europe.

The call for evidences aim to reduce unnecessary reporting burdens is a positive step. The revision of Delegated Regulations (EU) 2021/2139 and 2023/2486 is an opportunity to improve the Taxonomys practical use through quantifiable metrics, voluntary metrics, reduced duplication, risk assessment and simplification.

The call for evidences aim to reduce unnecessary reporting burdens is a positive step. The revision of Delegated Regulations (EU) 2021/2139 and 2023/2486 is an opportunity to improve the Taxonomys practical use through quantifiable metrics, voluntary metrics, reduced duplication, risk assessment and simplification.

To support the EUs industrial competitiveness through the green and digital transitions, the European Commissions proposal for the Critical Raw Materials (CRM) Act must be made workable for industry and respect Single Market principles.

Our position Building blocks for a decarbonised EU AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe. AmCham EU facilitates the resolution of transatlantic issues that impact business and plays a role in creating better understanding of EU and US positions on business matters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The proposed European Competitiveness Fund (ECF) within the Multiannual Financial Framework (MFF) package raises serious concerns about legal certainty, market openness and the proportionality of restrictions. Specifically, the introduction of EU preference in EU funding instruments as currently proposed would negatively impact long-standing cooperation between international companies from allied countries and…

Introduction To be truly future proof and innovation friendly, the EU's proposed pharmaceutical package must address the blocs declining attractiveness for investment. We therefore urge EU co-legislators to secure globally competitive incentives for research and development (R&D) and avoid additional unnecessary administrative burdens on companies.

Introduction To be truly future proof and innovation friendly, the EU's proposed pharmaceutical package must address the blocs declining attractiveness for investment. We therefore urge EU co-legislators to secure globally competitive incentives for research and development (R&D) and avoid additional unnecessary administrative burdens on companies.

The American Chamber of Commerce to the EU (AmCham EU) is committed to the development of a regulatory environment which furthers the capabilities of European healthcare, improving accessibility and ensuring a crisis-resistant medicines regulatory system.

The European Commissions efforts to simplify the European Sustainability Reporting Standards (ESRS) in the May 2026 publication are constructive and include improved consistency across standards, closer alignment with international frameworks such as the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards and targeted relief for preparers.

The American Chamber of Commerce to the EU (AmCham EU) speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe. AmCham EU facilitates the resolution of transatlantic issues that impact business and plays a role in creating better understanding of EU and US positions on business matters.

AmCham EU commends the European Commission for the extensive consultative process that led to the publication of the Proposal for an ‘AI Act’ . We appreciate having had the opportunity to provide our perspective on this important piece of legislation.

The American Chamber of Commerce to the European Union (AmCham EU) has long called for a risk-based approach to artificial intelligence (AI) regulation, and fully supports the view that AI legislation must be targeted and focused on problems which are not already covered by existing legislation.

The European Commissions proposal to revise the Waste Framework Directive (WFD) rightly aims at reducing food waste as well as better managing textile waste in a more circular and sustainable manner. The proposal is a welcome step towards establishing circularity for textiles by including mandatory extended producer responsibility (EPR) for textiles, incentives for the development and uptake of fibre-to-fibre…

AmCham EU supports an EU wide approach to create a level playing field, with the introduction of mandatory human rights and environmental due diligence that is in line with the political and strategic ambition of the Union. The European Commission’s proposal for a Directive on corporate sustainability due diligence aims to foster sustainable and responsible corporate behaviour throughout global value chains.

Climate change is a pressing global challenge requiring coordinated and sustained action. At the same time the transition to climate neutrality must be grounded in economic reality, technical feasibility and global competitiveness. AmCham EU companies operate extensive industrial assets across Europe.

The European Commissions efforts to ensure adequate substantiation of green claims by creating a minimum level of evidence and harmonising different legislative interpretations in the EU through the proposed Directive on Green Claims are welcome.

The proposal for a new Ecodesign for Sustainable Products Regulation (ESPR) seeks to create a Single Market for sustainable products and improve access to sustainability information through the Digital Product Passport (DPP). The Regulation will only be successful if it ensures full harmonisation across Member States and drives competitiveness for European industry.

We understand that at the heart of the Circular Economy Action Plan, the European Commission aims to develop a product policy framework based on sustainability. While AmCham members fully support and embrace the circular economy transition and are actively committed in closing the carbon loop, we wish to underline the need for maintaining the main principles of a legislative framework that is delivering already…

Consultation response Commission proposal for a carbon border adjustment mechanism AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commissions initiative to develop a European Biotech Act can strengthen its biotech sector. The legislation should achieve this goal by ensuring regulatory coherence, enabling biotech innovation, strengthening supply chain resilience, supporting new technologies and deepening transatlantic cooperation.

Consultation response Proposed revision of the Energy Efficiency Directive AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our position Cybersecurity Act review AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe. AmCham EU facilitates the resolution of transatlantic issues that impact business and plays a role in creating better understanding of EU and US positions on business matters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Consultation response European Commission Cybersecurity Act consultation AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Effectively addressing carbon leakage is essential to maintaining industrial competitiveness while supporting Europes climate objectives. When CBAM enters its definitive phase on 1 January 2026, importers of covered goods will bear financial responsibility for embedded emissions, with payments beginning in 2027. As a first-of-its-kind instrument, CBAMs effectiveness remains uncertain.

AmCham EU welcomes the opportunity to provide feedback on the targeted revision of Regulation (EC) No 1272/2008 for Classification, Labelling and Packaging of substances and mixtures (CLP). This is an important pillar of the Chemicals Strategy for Sustainability (CSS).

Endocrine disruptors (EDs): We supports a horizontal mechanism to identify EDs based on the WHO definition. However, CLP is designed to classify adverse effects, whereas EDs have an endocrine mode of action that is causally linked to an adverse effect. We are concerned about the potential for duplication with existing legislation.

The Biotech Act placed biotechnology high on the EUs competitiveness agenda. The next phase, to be released later in 2026 as per the Commissions work programme, should build on this momentum by completing the pathway from healthcare innovation to a broader, more resilient biotechnology and biomanufacturing industry in Europe.

Digital fairness in the EU must be pursued through coherence, clarity and consistent enforcement rather than through new layers of regulation. Europe already has the worlds most advanced consumer and digital protection framework, strengthened by recent updates including the Digital Services Act (DSA), Digital Markets Act (DMA), AI Act and General Data Protection Regulation (GDPR).

The American Chamber of Commerce to the EU (AmCham EU) shares the objectives of the European Commission to increase access to and further the (re-)use of data through the proposed ‘Data Act’. In order to ensure the Data Act meets its stated objectives, it should focus on promoting greater voluntary data sharing in order to boost economic growth, research and innovation, competitiveness, job creation and to achieve…

The American Chamber of Commerce to the EU (AmCham EU) shares the objectives of the European Commission to increase access to and further the use of data through the proposed “Data Act”. AmCham EU provides below some suggestions and recommendations to ensure that the outcome of the Data Act will be to promote more data sharing and help Europe’s data economy to boost economic growth, research & innovation…

Achieving the Digital Decade targets by 2030 is a crucial milestone to foster innovation across industries and improve the well-being of European citizens. As the recent Letta report and our Agenda for Action 2024 point out, the Single Market must aim to make European industrial capacity compatible with the transformation of our economy.

EuropaBio welcomes the European Commission’s bold ambition to make Europe the most competitive data economy globally. The power of data in the healthcare sphere is evident and realising the potential of healthcare data is a crucial step to ensure the EU is a leader in the development of next generational medicines.

AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe. AmCham EU facilitates the resolution of transatlantic issues that impact business and plays a role in creating better understanding of EU and US positions on business matters.

The American Chamber of Commerce to the European Union (AmCham EU) shares the European Commission’s view that EU-level action is required to address the fragmented environment of European health data, the lack of data available for (re-)use in scientific research and the need for increased uniformity in Member States’ applications of data regulations.

As the European Commission reviews its proposed amendments to Annex I of the EU Deforestation Regulation (EUDR), it must ensure that its requirements provide regulatory certainty and do not create further obstacles to implementation. Specifically, it must ensure consistency, greater clarity and fewer compliance burdens in key provisions.

AmCham EU supports the Commission’s ambition to ensure a competitive, circular, sustainable and safe value chain for all batteries on the EU market. Batteries have a critical role to play in supporting decarbonisation and the EU’s strategic industrial objectives. We consider work remains in aligning product policy with the waste framework and Waste Shipment Regulation.

AmCham EU supports the objectives of the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD). The proposal would improve environmental, social and governance (ESG) disclosures and lead to greater relevance, comparability and reliability of ESG reporting across the EU.

Registration: Quality dossiers are essential to evaluate potential risks and take appropriate regulatory decisions. Requests made by authorities should nevertheless be proportionate and avoid unnecessary burdens. Including information on environmental footprint in registration dossiers could create opportunities to better account for the lifecycle sustainability of substances in regulatory risk management.

As the European Commission aims to strengthen the EUs cybersecurity policy through the Cyber Resilience Act (CRA), it must ensure that all industry concerns are taken into consideration, as these will be key for the successful adoption and implementation of the CRA.

As the European Union’s economy and society continue to embrace digital solutions, there is an urgent need to ensure that the EU’s networks and information systems are resilient against evolving cyberattacks. The American Chamber of Commerce to the European Union (AmCham EU) supports a strong cybersecurity environment in Europe, which is the responsibility of government and industry alike.

While the EU Commissions proposed reforms to the Union Customs Code, such as the introduction of the European Customs Authority, the EU Customs Data Hub and the Trust and Check trader status demonstrate a commitment to improving customs procedures and trade facilitation, there are several aspects that should be further refined.

Consultation response Revision of the Union Customs Code AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Europes electricity grid is rapidly evolving with the growth of inverter-based resources like solar, wind and batteries. These technologies behave differently from conventional generators, introducing more variability and increasing the need for flexibility and system capabilities like inertia and voltage support.

The American Chamber of Commerce to the EU (AmCham EU) supports the EU’s ambition for low-emission mobility. The review of the Alternative Fuels Infrastructure Directive (AFID) as part of the Green Deal will be instrumental in meeting this goal. AmCham EU recognises that the current level of deployment of alternative fuels infrastructure in the EU is uneven across Member States.

In the face of major systemic shocks and rapidly evolving passenger expectations, Europe's aviation and aeronautics industry requires a renewed EU Aviation and Aeronautics strategy that is pragmatic and forward-looking.

Sustainable aviation fuels (SAF) are one of the most direct ways to make substantial reductions in net carbon emissions for aviation across all market segments and aircraft sizes. AmCham EU members representing key players along the aviation value chain have been committed to the development and the scaling up of SAF.

As the EU considers how best to design the DMA, it is vital that any such new tool is clear in terms of its scope, including the companies to which it may apply; the obligations they may be subject to; and the DMA’s interaction with existing legislation at both EU and Member State level. It is also important that the DMA contains appropriate procedural safeguards.

The European Commission's proposal to promote the repair of goods is practical, proportionate and ambitious. It can help achieve sustainable consumption by increasing the repair and reuse of viable defective goods while securing high skilled jobs.

Representing American companies operating in the EU, AmCham EU is well aware of the differences and respective strengths of innovation ecosystems on both sides of the Atlantic. The options laid out in the inception impact assessment (IIA) risk undermining an EU framework that has proven largely successful, rather than preserving the EU’s strengths and incorporating learnings from other regions.

Our position Feedback on Product Liability Directive Proposal AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On 12 June 2025, the European Commission published the draft implementing act under the Ecodesign for Sustainable Products Regulation (ESPR) concerning the reporting of unsold consumer goods. Despite recommendations from industry, Article 4 introduces a requirement for third-party verification through a limited assurance process.

A predictable and reliable intellectual property system is necessary for companies to innovate. The existing systems of national compulsory licensing already create an appropriate IP environment, and an EU-wide Compulsory License would create unnecessary burdens for businesses.

The American Chamber of Commerce to the European Union (AmCham EU) recognises the contribution the FASTER Proposal would make to simplifying withholding tax (WHT) procedures for cross-border investments in the EU. Please find our consultation response attached.

The American Chamber of Commerce to the EU (AmCham EU) welcomes the opportunity to provide feedback on the Proposal for a Regulation on foreign subsidies distorting the internal market. As an association we strive to facilitate business relations between the US and the EU. We represent American companies committed to and invested in Europe, advocating for their fair treatment across the EU single market.

Dear Sir or Madam, Please find attached AmCham EU's response to the call for evidence. AmCham EU has closely followed and participated in discussions on the General Data Protection Regulation (GDPR) throughout its legislative adoption and implementation processes.

The American Chamber of Commerce to the EU (AmCham EU) welcomes the opportunity to contribute to the European Commission’s consultation on the proposal for a ‘Regulation on the protection of the Union and its Member States from economic coercion by third countries’.

Consultation response Proposal for a new regulation on the screening of foreign investments AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The American Chamber of Commerce to the EU (AmCham EU) welcomes the Commission’s initiative to evaluate the performance of the Restriction of Hazardous Substances (RoHS) Directive. Our members have been implementing the directive since its inception in 2003, this has given them the practical experience in effectively evaluating which aspects of the directive have worked well and where improvements are needed.

The European Economic Security Strategy underscored the need for coordinated EU action on export controls to protect national and EU security interests while preserving industry competitiveness. This was further stressed in the Commissions recent White Paper on export controls.

The American Chamber of Commerce to the European Union (AmCham EU) welcomes the opportunity to provide our views on the European Commission’s roadmap on strengthening the mandate of the European Union Agency for Law Enforcement Cooperation (Europol).