In a joint statement, the coalition, including the European Apparel and Textiles Confederation (EURATEX), Extended Producer Responsibility Alliance, European Footwear Confederation and Independent Retail Europe, is urging the EU and its Member States to introduce a legal obligation on foreign operators to appoint a legally responsible person or entity in the EU for e-commerce imports without delay.
The call comes amid a surge in low-value e-commerce imports entering the EU, driven by rapid growth in online retail. Since new VAT rules for e-commerce came into force in 2021, each small consignment requires an individual customs declaration. In 2022 alone, almost 1 billion declarations for low-value goods were filed, highlighting the scale of the challenge facing customs authorities.
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According to the coalition, many of these imported products contravene EU rules. Reported infringements include VAT fraud, breaches of health and safety standards, violations of intellectual property rights and misleading claims, all of which are contributing to unfair competition within the Single Market.
The statement warns that such practices are “corroding industrial value chains, eroding our economic strength and resilience and put the consumer health at risk.”
It also highlights the impact on physical retail, with growing volumes of non-compliant imports contributing to the decline of high streets across the region.
While the coalition welcomed the EU’s plan to introduce the new Union Customs Code (UCC) – the ‘deemed importer’ concept, making platforms responsible for ensuring that customs duties and VAT are paid, as well as meeting non-financial obligations – it stressed that implementation in 2028 will be too late to address current challenges.
The coalition stated that in 2025 alone, 5.8 billion parcels were imported into the EU, and warned that pressure on compliant businesses will continue to grow as non-compliant traders face limited accountability.
As an alternative, the group said an obligation requiring foreign sellers to appoint a legally responsible EU-based entity could be introduced much earlier through a dedicated regulation, describing the move as technically feasible and dependent on political will.
They also pointed to the forthcoming European Product Act as a complementary measure to strengthen product compliance and market surveillance and stressed that enforcement of Extended Producer Responsibility (EPR) obligations must apply effectively to online sales and third-country sellers, including requirements covering packaging, WEEE, batteries and textiles.
The statement added that online marketplaces and EU-based representatives should be subject to clear and binding enforcement mechanisms to prevent free-riding and maintain a level playing field.
To conclude, the joint statement stated: “If properly defined and implemented, these new concepts have the potential to help address gaps in online product compliance. We, the undersigned, urge the EU and its Member States to put in place such a regulation without delay.”
