American Chamber of Commerce to the EU

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…

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 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 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.

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 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.

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.

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.

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.

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.

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.

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.

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.

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.

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.