COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS A comprehensive EU toolbox for safe and sustainable e-commerce
Date: 2025-02-05
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: consumer information, digital economy, digital single market, ecological footprint, electronic commerce, industrial counterfeiting, market supervision, product safety, restriction on competition, surveillance concerning imports

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.2.2025  COM(2025) 37 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS A comprehensive EU toolbox for safe and sustainable e-commerce  
 
 
A comprehensive EU toolbox for safe and sustainable e-commerce 

E-commerce  has  revolutionised  the  way  consumers  and  businesses  interact,  including 
small  and  medium-sized  enterprises  (SMEs),  bringing  numerous  benefits  to  the  EU 
economy  as  a  whole.  At  the  same  time,  the  recent  surge  of  goods  bought  online  and 
imported into the EU directly to consumers has amplified the challenges associated with 
e-commerce. These include the risk of harm to consumers’ health and safety from non-
compliant products, the risk of irreversible environmental damage and negative carbon 
footprint, and a negative impact on the competitiveness of law-abiding businesses.  

The  EU  promotes  a  vision  of  e-commerce  that  reinforces  sustainability,  convenience, 
safety and reliability, and is a vehicle for the digital transformation in line with the 2030 
Digital Decade targets. E-commerce should foster innovative and responsible businesses, 
while applying fair trade practices and complying with EU laws.  

This Communication outlines the Commission’s comprehensive approach to addressing 
the  challenges  posed  by  e-commerce  imports  across  their  entire  life  cycle.  The 
Commission announces its enforcement priorities, calling for strengthened cooperation 
and  coordination  among  all  relevant  authorities.  This  cooperation  should  ensure  that 
imported products directly shipped to consumers via e-commerce comply with EU rules 
and fair trading practices. To achieve this goal, the Commission calls on Member States 
and their competent authorities to play a proactive role in monitoring and implementing 
the  key  actions  outlined  in  this  Communication. Additionally,  the  Commission  sets  out 
measures  to  make  customs  and  market  surveillance  authorities  more  resilient  and 
effective,  in  particular  through  an  advanced  implementation  of  the  Customs  Union 
Reform,  as  it  would  both  remove  duty  relief  for  low  value  consignments  and  enhance 
control  capacities,  as  well  as  through  a  possible  non-discriminatory  handling  fee  for 
imported  goods  delivered  directly  to  consumers.  The  Commission  invites  market  and 
institutional stakeholders to collaborate in this effort. 

1. 

TRENDS AND CHALLENGES IN E-COMMERCE IMPORTS 

E-commerce  has  become  an  integral  part  of  how  consumers  make  purchases  online. 
70% of Europeans regularly buy products online1, both from sellers’ e-shops and through 
online marketplaces. 76% of consumers think that by 2030, shopping and selling products and 
services online will be among the most important digital technologies in Europe2.  

In recent years, online marketplaces, in particular, have experienced significant growth, 
with  international  players,  and  also  many  European  businesses  emerging  as  regional 
champions.  Offers  on  online  marketplaces  include  a  broad  range  of  products,  often  made 
attractive by their low prices, and simple purchasing process, with rapid and cheap delivery. 
Online  marketplaces  have  opened  up  international  trade  in  consumer  goods:  they  connect 
consumers to a wide variety of sellers, from established brands to small producers and start-
ups in the EU and worldwide. Often, they have a hybrid business model, acting not just as an 
intermediary  between  consumers  and  businesses,  but  also  selling  directly  to  consumers  and 
supporting vast production and distribution channels outside the EU. 

1 Eurobarometer data for 2023, accessible at  E-commerce statistics for individuals - Statistics Explained 

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E-commerce is a space of commercial and digital innovation, with personalised offers and 
recommendations, as well as AI-enabled optimisations, marketing solutions and applications 
for consumers.   

E-commerce  goods  directly  imported  by  consumers  in  the  EU  have  surged  in  recent 
years and are expected to continue growing in volume at a rapid pace benefiting from the 
current  duty  exemption  for  low  value  consignments  (up  to  EUR  150).  According  to  EU 
surveillance data, 4.6 billion of such low value items were imported in the EU in 2024. This is 
almost twice the number recorded in 2023 (2.4 billion), and more than tripled since 2022 (1.4 
billion). This corresponds to up to 12 million small items per day.  

In 2024, 91% of all e-commerce shipments valued up to EUR 150 entering the EU came from 
China and their volume more than doubled between 2023 and 2024 – from 1.9 billion to 4.17 
billion  items.  This  surge  coincides  with  the  extremely  rapid  growth  of  certain  online 
marketplaces. Temu  and  SHEIN,  in  particular,  have  grown  exponentially  in  the  EU  market, 
scaling to over 75 million users in the EU in the space of a few months in 2024. Fuelled by 
pervasive  online  advertising,  low  pricing  and  ultra-fast  delivery,  the  supply  of  low-value 
goods through such online marketplaces has in turn generated strong demand.   

The rapid increase of imports shipped directly to consumers raises significant challenges that 
require  urgent  attention,  in  particular  where  imported  products  may  be  non-compliant  with 
EU  law.  For  example,  around  half  of  the  fake  products  seized  at  EU  borders  that  infringed 
intellectual property rights of SMEs were purchased online2.  

The surging volume of products that are unsafe, counterfeit or otherwise non-compliant 
leads to serious  safety and health risks for consumers, has an unsustainable impact on 
the  environment,  and  fuels  unfair  competition  for  legitimate  businesses,  with  a 
significant  impact  on  EU  competitiveness  in  different  sectors.  The  sheer  number  of 
products imported directly by consumers in the EU also puts an unsustainable strain on 
authorities.   

1.1. 

Safety and product compliance 

Dangerous,  counterfeit  or  otherwise  non-compliant  products  affect  individuals’  daily 
life. Consumers themselves see the presence of non-trustworthy online sellers among the top 

2  EUIPO  &  OECD,  Misuse  of  E-Commerce  for  Trade  in  Counterfeits,  2021,  EUIPO_OECD_misuse-e-
commerce-trade-in-counterfeits_study_en.pdf (europa.eu). Imports of counterfeit goods represent 5.8% of all 
goods  entering  the  EU,  see  EUROPOL  &  EUIPO,  Intellectual  Property  Crime  Threat  Assessment,  2022, 
Report. Intellectual property crime threat assessment 2022_2.pdf (europa.eu). 

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online challenges that have the biggest personal impact on them3. There are serious risks for 
their  health  and  safety,  including  the  safety  of  children,  given  their  specific  needs  and 
vulnerabilities.  

According to Eurobarometer data, Europeans mostly buy clothes, shoes, accessories, but also 
cosmetics  and  beauty  products  online4.  If  such  products  do  not  comply  with  EU  rules  or 
applicable  national  laws,  there  can  be  serious  health  consequences,  for  example  stemming 
from harmful substances in toys or cosmetics, the level of chemicals contained in clothes or in 
furniture, or from falsified medicinal products, illicit (synthetic) drugs and new psychoactive 
substances as well as muscle-building steroids and sexual enhancers. 

There are also  direct  threats  to  security: criminals  take advantage of the  high  volumes of e-
commerce goods imported to distribute illicit goods, such as illicit (synthetic) drugs and drug 
precursors, explosives, firearms or 3D-printed weapons and parts. They often distribute them 
through  small  parcels  sold  on  the  grey  and  dark  web,  and  sometimes  through  open  online 
marketplaces.  Tackling  e-commerce  as  a  distribution  channel  for  criminals  is  important  to 
effectively act against evolving security threats. 

1.2. 

Sustainability aspects 

The  surge  in  e-commerce  imports  directly  shipped  to  consumers  also  has  very  serious 
detrimental  effects  on  the  climate  and  the  environment.  Extremely  low  retail  prices  on 
some  products  sold  online  fail  to  reflect  the  broader  environmental  costs  linked  to  the 
production, the direct shipping, and the complete lifecycle of the product.  

Environmental  costs  also  include  increased  pollution  and  climate  impact  from  the  use  of 
certain materials or fossil fuel energy in the production of goods. In addition, such goods are 
often low-quality, which means they are not energy-efficient, do not last long and cannot be 
repaired easily.  

These  products  are  often  shipped  to  consumers  as  individual  consignments.  The  carbon 
footprint  of  this  practice  is  considerable.  It  is  also  amplified  by  the  short  useful  life  of 
products, commercial practices such as fast fashion, potential returns of the products and high 
volumes of returned or unsold products being destroyed.  

At  the  end  of  their  short  life,  the  non-compliant  products  themselves  and  their  packaging 
generate  problems  for  waste  management.  Likely,  the  fees  for  covering  the  costs  of  waste 
treatment have not been paid and often these products cannot be recycled due to the materials 
they are made of. 

1.3. 

Unfair competition and loss of competitiveness 

The  growth  in  e-commerce  imports  directly  shipped  to  consumers  has  also  increased 
competition,  including  between  EU  sellers  and  those  located  outside  of  the  EU  and 
targeting their offer at consumers in the EU. However, this competition can become unfair 
and hinder the level playing field for legitimate businesses. If some sellers do not comply with 
EU  product  safety  and  consumer  protection  requirements,  they  avoid  costs  for  ensuring  the 
necessary  quality,  safety  of  materials  and  proper  record-keeping  and  reporting.  This  is  also 
true for businesses that do not apply EU environmental standards or circumvent contributing 

3 27% of surveyed consumers identified ‘non-trustworthy online sellers’ as having the biggest personal impact 
on  them,  fourth  on  the  list  of  issues,  preceded  by  the  misuse  of  personal  data,  disinformation  online  and 
insufficient protections for minors. The digital decade - July 2024 - - Eurobarometer survey 

4  44%  of  online  shoppers  bought  or  ordered  clothes,  shoes  and  accessories,  and  18%  bought  ‘cosmetic  and 

beauty products’ E-commerce statistics for individuals - Statistics Explained  

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to  waste  management.  Compliant  sellers,  however,  incur  these  costs  from  a  comprehensive 
legal environment and are placed at an economic disadvantage compared to traders that do not 
follow the rules.  

In addition,  there are direct  losses incurred by law-abiding businesses. When an SME is 
the victim of, for example, counterfeiting or piracy, it has a 34% lower chance of survival than 
SMEs  that  did  not  experience  any  intellectual  property  infringement5.  This  cumulates  into 
high  losses  for  different  branches  of  industry:  the  clothing  industry  loses  close  to  EUR  12 
billion  in  annual  sales  (5.2  %  of  turnover),  the  cosmetics  industry  EUR  3  billion  (4.8  %  of 
sales), and the toy industry EUR 1 billion (8.7 % of sales)6. 

Furthermore,  sellers  of  goods  from  non-EU  countries  benefit  from  an  exemption  from 
customs  duties7  when  the  goods  with  a  value  up  to  EUR  150  (i.e.  low-value  goods)  are 
directly shipped to consumers in the EU. Clothes are a telling example of this discrepancy: 
above  this  declared  value,  they  are  subject  to  an  import  duty  of  12%  of  their  value.  Such 
goods  are  massively  bought  on  fast-growth  marketplaces,  such  as  AliExpress,  Temu  and 
SHEIN, but they are also available on other marketplaces as well as on direct sellers’ e-shops. 

1.4. 

The EU has a comprehensive legal framework 

The EU has a comprehensive corpus of rules regulating the entire life-cycle of a product 
imported in the EU and defining the responsibilities of the actors involved. Several pieces 
of  law  have  recently  been  updated  and  other  changes,  in  particular  on  customs  and 
environmental protection, are currently being negotiated. 

Sellers of products from non-EU countries who directly ship their products to EU consumers 
are  generally  responsible  for  ensuring  the  lawfulness  of  products  they  commercialise  in  the 
EU.  These  must,  for  example,  comply  with  product  safety  regulation,  consumer  protection 
rules,  and  any  other  obligations  based  on  EU  or  national  law.  For  most  consumer  products, 
sellers are also required to have a responsible economic operator in the EU, making it easier 
to enforce EU legislation8.  

All  sellers  must  also  comply  with  extended  producer  responsibility  (EPR)  requirements  by 
contributing  financially  to  the  management  of  their  products  once  they  become  waste. This 
includes electric and electronic equipment, batteries, and packaging. With the adoption of the 

5 OECD/EUIPO (2023), Risks of Illicit Trade in Counterfeits to Small and Medium-Sized Firms, Illicit Trade, 

OECD Publishing, Paris, https://doi.org/10.1787/fa6d5089-en  

6 Economic impact of counterfeiting in the clothing, cosmetics, and toy sectors in the EU - EUIPO (europa.eu) 
7  Article  23  of  Regulation  1186/2009  sets  out  a  EUR  150  threshold  for  customs  duties.  The  Commission 

proposed a revision of these rules – see infra, p. 6 and EU Customs Reform - European Commission 

8  The  Commission  will  soon  publish  a  report  examining  the  implementation  of  the  requirement  to  have  a 
responsible  economic  operator  in  the  EU  for  certain  products,  in  accordance  with  Article  4  of  Regulation 
(EU) 2019/1020 

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amended Waste Framework Directive9, this should be extended to cover textile, textile-related 
and footwear products. 

Online marketplaces, irrespective of whether they are established in the EU or not, are liable 
if they do not comply with their specific obligations as intermediaries in the sale of goods, in 
particular  under  the  Digital  Services Act  (DSA)10,  as  well  as  under  other  laws  such  as  the 
General  Product  Safety  Regulation11    when  it  comes  to  unsafe  products,  the  Directive  on 
Ecodesign12, the Regulation on energy labelling1314, the Regulation on classification, labelling 
and packaging of substances and mixtures15, the Market Surveillance Regulation16, and with 
EU  consumer  protection  rules  whenever  they  target  EU  consumers.  The  largest  platforms, 
designated as ‘gatekeepers’17 under the Digital Markets Act, must also comply with a series of 
‘do’s and don’ts’ for their market behaviour18. 

Under certain conditions, marketplaces can also be held liable for the sale of non-compliant or 
dangerous products. They are exempted from liability for the illegal behaviour of the sellers, 
but  subject  to  certain  conditions  -  if  they  are  not  aware  of  the  illegality  of  the  content  they 
host or, upon gaining such actual knowledge, they act expeditiously to remove the product. In 
any case, the conditional liability exemption applies only when the marketplace intermediates 
the sale of a product, which is not the case, for instance, when the seller acts under the control 
or  authority  of  the  marketplace.  Marketplaces  can  also  be  found  liable  for  violations  of 
consumer  protection  law  when  they  present  the  sellers’  offers  in  a  way  that  could  lead  a 
consumer to believe that the product is offered by the marketplace itself. 

2. 

THE  EU  IS  WELL  EQUIPPED  TO  TACKLE  THE  CHALLENGE  BUT  NEEDS  A  HOLISTIC 
AND WELL-COORDINATED APPROACH 

Europe  is  well  placed  to  tackle  the  challenges  brought  by  e-commerce  imports  shipped 
directly  to  consumers.  But  more  needs  to  be  done  to  ensure  that  EU  rules  are  correctly 
applied, as well as to ensure that the enforcement system is effective and resilient, and is not 
overwhelmed by the volumes of low-value goods sold online and flooding the market. 

With this Communication, the Commission puts forward a holistic approach to address the 
risks  and  distortions  created  by  the  large  volume  of  imports  of  such  products.  This 
approach  needs  to  be  comprehensive  and  include  a  well-coordinated  set  of  actions, 

9  Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  amending  Directive  2008/98/EC  on 

waste COM(2023) 420 final  

10 See more details on the obligations for online marketplaces in Section 2.3.1 
11 Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product 

safety 

12  Directive  2009/125/EC  of  the  European  Parliament  and  of  the  Council  of  21  October  2009  establishing  a 

framework for the setting of ecodesign requirements for energy-related products  

13 Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework 

for energy labelling and repealing Directive 2010/30/EU 

14  Regulation  (EU)  2024/1781  of  the  European  Parliament  and  of  the  Council  of  13  June  2024  establishing  a 
framework  for  the  setting  of  ecodesign  requirements  for  sustainable  products,  amending  Directive  (EU) 
2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC 

15  Regulation  (EU)  2024/2865  of  the  European  Parliament  and  of  the  Council  of  23  October  2024  amending 

Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures 

16  Regulation  (EU)  2019/1020  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on  market 
surveillance  and  compliance  of  products  and  amending  Directive  2004/42/EC  and  Regulations  (EC)  No 
765/2008 and (EU) No 305/2011 

17 DMA designated Gatekeepers 
18 See more details in Section 2.3.4 

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bringing  together  in  particular  the  European  institutions,  the  Member  States  and  all 
national competent authorities. 

First,  the  Commission  proposes  a  series  of  structural  changes  to  the  regulatory 
framework,  with  a  particular  focus  on  the  customs  reform  and  on  measures  for 
environmental protection. Calling on the support of the co-legislator for the urgent adoption 
of  the  customs  reform  proposal,  the  Commission  is  hereby  initiating  a  reflection  on  how  to 
further strengthen the proposed measures with  additional support to the customs authorities, 
for example through a new non-discriminatory handling fee for goods imported into the EU 
directly  to  consumers.  (Section  2.1.1)  On  environmental  protection,  the  Commission  will 
support  the  roll-out  of  the  Ecodesign  for  Sustainable  Products  Regulation  and  the  effective 
application  of  existing  extended  producer  responsibility  rules. The  Commission  calls  on  the 
co-legislator  to  adopt  the  targeted  revision  of  the  Waste  Framework  Directive  and  will 
propose further legislation, not least through the Circular Economy Act. (Section 2.1.2) 

Then,  the  Commission  stresses  the  high  priority  of  coordinated  enforcement  actions 
against  the  surge  of  dangerous,  counterfeit  or  otherwise  non-compliant  products  sold  online 
and  imported  in  the  EU.  This  needs  to  make  full  use  of  the  EU  ambitious  regulatory 
framework  and  must  be  well  coordinated  among  customs  authorities,  market  surveillance 
authorities  and  other  competent  national  authorities. The  Commission  puts  forward  specific 
steps to ensure effective cooperation and targeted actions. (Section 2.2) 

Further, Europe has the world’s most robust regulatory framework for the way products are 
presented  to  consumers  online  and  for  setting  clear  responsibilities  for  online 
marketplaces. As stressed in the Political Guidelines of the President19, speed, coherence and 
simplification are key, not  least  for creating a level  playing field  for smaller companies and 
maintaining  a  proportionate  regulatory  burden.  The  Commission  will  focus  on  the  robust 
enforcement  and  the  complementarity  of  digital  rules,  supported  by  well-coordinated 
actions across all competent authorities. (Section 2.3) 

In  addition,  digital  tools  can  be  key  enablers  for  achieving  the  objectives  of  this 
Communication.  The  Commission  announces  measures  to  support  a  modern  and  resilient 
supervisory toolbox, in particular through the use of the Digital Product Passport, AI tools 
for the detection of illegal goods and shared databases. (Section 2.4) 

Not least, awareness raising, and educational efforts are essential to empower and protect 
consumers, including minors, and help legitimate businesses offer compliant products in the 
EU. (Section 2.5) 

Finally, such measures need to be flanked by dialogue with international partners and third 
countries where imported products  originate from.  Moreover, the  Commission  will continue 
monitoring trade practices of third countries and remains vigilant on unfair trade practices. 
(Section 2.6)   

2.1. 

Structural reforms to curb the import of non-compliant products and to protect 
the environment 

2.1.1.  The customs reform package   

The steep rise in e-commerce imports shipped directly to consumers in the EU, who become 
the importers for customs purposes, has not been matched by an increased handling capacity 
at the border. In 2024, authorities in just six Member States20 were responsible for supervising 
89% of directly imported goods sold online. While the customs authorities are the first line of 

19  https://commission.europa.eu/about/commission-2024-2029_en  
20 The Netherlands, Belgium, France, Hungary, Italy and Germany; Source: EU Surveillance data 

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defence at the border against the import of non-compliant and potentially dangerous products, 
they struggle with the sheer amount of e-commerce imports, which already account for over 
97%  of  all  customs  import  declarations21.  It  is  becoming  clear  that  the  current  customs 
processes  and  tools  are  no  longer  fit  for  purpose  and  that  the  resources  available  are  not 
sufficient to handle effectively the sheer volume of parcels generated by e-commerce flows. 

In May 2023, the Commission proposed an ambitious customs reform package22, including (i) 
a new Union Customs Code (UCC), (ii) a proposal23 to remove the EUR 150 duty exemption 
for imports and to introduce a simplified tariff treatment for low-value consignments, and (iii) 
a VAT proposal24 to extend the scope of the ‘Import One Stop Shop’ (IOSS) to cover all goods 
regardless of their value.   

The proposals aim at structurally improving the capabilities of EU customs to supervise 
and  control  the  flow  of  goods  entering  and  leaving  the  Customs  Union,  starting  with 
products  sold  online  and  shipped  directly  to  consumers.    National  customs  authorities 
would be supported by a new EU Customs Authority (EUCA), which would operate an EU 
Customs Data Hub.  

The  EU  Customs  Data  Hub  would  provide  an  EU  electronic  environment  for  operators  to 
report to customs authorities, and would integrate data from other authorities. It would enable 
an EU-level risk management capability. The EUCA would be able to screen the goods based 
on this information, to identify potential risks even before the goods are loaded for transport 
or  their  physical  arrival  in  the  EU  and  to  make  control  recommendations  to  the  Member 
States. This will allow customs authorities to have a complete overview on the supply chains, 
anticipating controls on imports and exports. As a result, the enforcement of compliance with 
product  requirements  will  be  more  targeted  and  effective.  The  EU  Customs  Data  Hub  will 
allow  for  enhanced  cooperation  with  other  authorities  through  data  exchange  and  thus 
facilitate coordinated controls. 

The  proposals  align  the  VAT  and  customs  rules  and  would  establish  that  online 
marketplaces and sellers registered in the IOSS become the ‘deemed importer’ and collect the 
relevant duty and VAT, ensure that goods entering the customs territory comply with other EU 
requirements and provide the data to the customs authorities at the moment of the sale, prior 
to  the  arrival  of  the  goods  to  the  EU  border.  In  2024,  IOSS  holders  accounted  for  92%  of 
imports of goods up to EUR 150. In addition, IOSS holders would report all their EU sales to 
the  EU  Customs  Data  Hub  and  be  supervised  by  their  Member  State  of  registration  (as 
opposed to 27 potential Member States of destination), both for VAT and customs purposes.  

The Commission calls on the co-legislator to swiftly adopt the Customs Reform proposal 
and is ready to work with the co-legislator to explore further measures to better address the 
overwhelming volume of small consignments and support customs authorities.  

First, the Commission is  willing to explore with  the co-legislators  the introduction of a 
non-discriminatory  handling  fee  on  e-commerce  items  imported  in  the  EU  directly  to 
consumers,  to  address  the  scaling  costs  of  supervising  the  compliance  of  such  

21 Source: EU Surveillance data 
22  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  establishing  the  Union  Customs 
Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013 COM(2023) 
258 final 

23 Proposal for a Council Regulation amending Regulation (EEC) No 2658/87 as regards the  introduction of a 
simplified tariff treatment for the distance sales of goods and Regulation (EC) No 1186/2009 as regards the 
elimination of the customs duty relief threshold  

24 Proposal for a Council Directive  amending  Directive 2006/112/EC as regards VAT rules relating to taxable 

persons who facilitate distance sales of imported goods  

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consignments with EU rules. Such a handling fee should allow for a major externality of this 
new business model, i.e. the need for a different, intensified approach to ensuring compliance 
of  huge  amounts  of  individual  parcels,  to  be  internalised  by  the  retailers  and  intermediaries 
that  benefit  from  it.  Thus,  such  a  handling  fee  should  be  incurred  by  the  importer,  i.e.  the 
online retailer or intermediary, and not by consumers at the point of delivery of the imported 
package.  

In addition, the lessons learned from the risks identified in the priority control area25 should 
be  considered,  as  well  as  whether  EUCA  could  support  more  efficient  customs  controls,  in 
line  with  its  mission  in  terms  of  operational  support  to  the  Member  States’  customs 
authorities. To that aim, EUCA will have to  be adequately equipped in  terms of operational 
capacity to address the e-commerce needs, to increase the compliance of the goods imported 
via e-commerce.   

In light of the enormous increase in volumes in a short space of time, which continues to grow 
and shows no sign of abating, the Commission stands ready to work with the co-legislators to 
‘frontload’  to  2026  the  customs  reform,  including  the  preparation  of  the  establishment  of 
EUCA  and  the  preparations  for  the  EU  Customs  Data  Hub,  in  due  consideration  of  the 
financial limitations of the current Multiannual Financial Framework.  

2.1.2.  Clear rules and responsible practices to protect the environment 

It  is  also  necessary  that  the  EU  steps  up  its  efforts  to  reduce  the  climate  and 
environmental impact of imports of low-value products shipped directly to consumers.  

EU  ecodesign  and  energy  labelling  requirements  encourage  manufacturers  to  innovate  and 
deliver more efficient products, enable consumers to make informed choices, and contribute 
to reducing overall energy consumption and emissions. It is estimated that more than EUR 10 
billion of benefits are lost every year due to non-compliance26.  

More  ambitious  sustainability  requirements  for  products  placed  on  the  EU  market  will  be 
rolled out under the Ecodesign for Sustainable Products Regulation27 (ESPR). The first ESPR 
working  plan  is  planned  for April  2025  and  will  determine  priority  product  groups  for  the 
adoption of sustainability requirements, including aspects related to sustainable delivery and 
return transport options. It will be followed in July 2025 by rules on the destruction of unsold 
consumer  products,  including  on  the  prohibition  of  destruction  of  unsold  textiles  and 
footwear. Textiles will be  among  the first  product  groups to  be addressed under a delegated 
act.  

Requirements  on  extended  producer  responsibility  (EPR)  are  included  in  the  Regulation  on 
packaging and packaging waste28, the Regulation on batteries and waste batteries29 and in the 
Directive on waste electrical and electronic equipment30, and in the Regulation on fluorinated 

25 See Section 2.2.1 
26  See,  e.g.    European  Court  of  Auditors  2020/1,  Special  report  on  EU  action  on  Ecodesign  and  Energy 
Labelling:  important  contribution  to  greater  energy  efficiency  reduced  by  significant  delays  and  non-
compliance   

27  Regulation  (EU)  2024/1781  of  the  European  Parliament  and  of  the  Council  of  13  June  2024  establishing  a 
framework  for  the  setting  of  ecodesign  requirements  for  sustainable  products,  amending  Directive  (EU) 
2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC 

28 Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging 

and packaging waste 

29  Regulation  (EU)  2023/1542  of  the  European  Parliament  and  of  the  Council  of  12  July  2023  concerning 

batteries and waste batteries 

30 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and 

electronic equipment (WEEE) (recast) 

8 

 
 
 
greenhouse  gases31.  The  Commission  calls  on  the  co-legislator  to  swiftly  adopt  the 
targeted  revision  of  the  Waste  Framework  Directive,  which  notably  introduces  EPR 
requirements for textiles and footwear. 

The  targeted  revision  of  the  Waste  Framework  Directive,  together  with  the  upcoming 
delegated  act  under  the  ESPR  on  sustainability  criteria  for  textiles,  will  lay  down  the 
necessary  elements  for  the  eco-modulation  of  the  financial  contributions  by  those  placing 
textiles on the market to EPR schemes: the higher the sustainability, the lower the fees will be. 
E-commerce players from outside and within the EU would be subject to the same rules, with 
a level playing field and the same incentives for placing on the EU market of more sustainable 
products. 

The Commission plans to propose a Circular Economy Act and will explore in this context 
options  to  further  develop  EPR  solutions,  including  a  one-stop-shop  for  the  registration  of 
producers,  the  further  harmonisation  of  EU  rules,  and  the  extension  of  the  EPR  schemes  to 
other  product  categories.  In  working  towards  the  proposal  for  a  Circular  Economy Act,  the 
Commission  will  pay  particular  attention  to  measures  for  effective  enforcement  on  the 
ground. 

Requirements  applicable  for  products,  packaging  and  waste  management  should  be 
effectively enforced also when goods are placed on the market through e-commerce. For this, 
a  strong  network  of  environmental  enforcers  is  required  across  the  EU,  including 
inspectors and police. Enforcement efforts and cooperation among European enforcers should 
be stepped up. 

The Commission will explore ways to ensure that the prohibition of the destruction of certain 
consumer  products  and  the  related  transparency  obligations  to  e-commerce  are  applied 
effectively,  including  by  third-country  platforms.  It  will  also  support  Member  States  and 
economic  operators  in  ensuring  that  counterfeit  goods  are  disposed  of  only  as  a  last  resort, 
focusing instead on their preparation for re-use or recycling32. 

The Commission: 

-  Calls on the co-legislator to swiftly adopt the Customs Reform proposal, and is ready to 
work  with  the  co-legislator  to  explore  further  measures  to  help  address  the  costs  of 
supervising  the  overwhelming  volumes  of  small  consignments,  in  particular  through  a 
new non-discriminatory handling fee on e-commerce items.  

-  Plans  to  adopt  the  first  action  plan  under  the  Ecodesign  for  Sustainable  Products 

Regulation by April 2025. 

-  Calls  on  the  co-legislator  to  swiftly  adopt  the  targeted  amendment  to  the  Waste 
Framework  Directive. The  Commission  will  work  closely  with  the  Member  States  for  a 
more effective enforcement of this Directive, the Single Use Plastics Directive, the Waste 
Electric  and  Electronic  Equipment  Directive  and  the  Regulations  on  Ecodesign  for 
Sustainable Products, on Packaging and Packaging Waste and on Batteries vis-à-vis third-
country e-commerce retailers. 

-  Plans to propose a Circular Economy Act which will explore to further develop Extended 

Producer Responsibility and how to strengthen enforcement. 

31 Regulation (EU) 2024/573 of the European Parliament and of the Council of 7 February 2024 on fluorinated 

greenhouse gases, amending Directive (EU) 2019/1937, and repealing Regulation (EU) No 517/2014 

32 Commission Recommendation (EU) 2024/915 of 19 March 2024 on measures to combat counterfeiting and 

enhance the enforcement of intellectual property rights 

9 

 
 
 
2.2. 

Targeted measures: increased coordinated controls for imported goods   

As an urgent priority, the Commission will support a series of targeted actions that  leverage 
the capabilities of multiple authorities in the coordinated enforcement of all the relevant EU 
rules, leading to immediate results, as well as further evidence gathering and sustained efforts 
to ensure long term compliance. 

2.2.1.  Customs  Priority  Control  Area  (PCA)  for  short-term  results  and  coordinated 

enforcement actions 

The Commission will coordinate customs controls under a priority control area (PCA)33 
focused  on  third-country  products  with  significant  safety  hazards  and  risk  of  non-
compliance purchased through online marketplaces and shipped directly to consumers 
in the EU34.  

Under this time-limited action, customs authorities in collaboration with market surveillance 
and other competent authorities will intensify import controls on these products to assess their 
safety and conformity with internal market legislation, detect potential trafficking of illicit and 
dangerous goods, and will exchange information on non-compliance.  

The immediate purpose is to address the lack of compliance and ensure that those dangerous 
and  non-compliant  products  are  not  placed  on  the  market,  as  well  as  deterring  criminal 
organisations from using e-commerce as a trafficking route. The action should gather further 
evidence  about  the  non-compliant  products  and  operators  involved.  The  action  should 
immediately  lead  to  results  in  addressing  the  lack  of  compliance  and  ensuring  that  those 
dangerous and non-compliant products are not placed on the market.  

Commitment and coordination between authorities will be key factors for the success of the 
PCA.  Customs  authorities  will  target  and  suspend  the  release  of  the  relevant  consignments. 
The  market  surveillance  authorities  will  determine,  as  experts  in  their  respective  product 
areas, and, where  needed, together with  other specialised authorities, whether the controlled 
products comply with all the relevant legislation. All existing tools and systems will need to 
be  used  in  a  coordinated  way  to  select  consignments,  process  cases,  determine  non-
compliance  and  carry  out  subsequent  assessments35.  On  the  basis  of  the  risk  analysis  from 
these  findings,  future  controls  will  be  intensified  for  certain  operators,  goods  or  trade 
flows,  as  appropriate,  on  a  rolling  basis.  The  higher  the  rate  of  non-compliance,  the  greater 
should  be  the  level  of  vigilance  in  subsequent  stages,  in  order  to  enhance  enforcement  and 
deterrence,  and thus contribute to a level playing field for businesses which incur the costs of 
compliance. 

Where  the  economic  operator  has  failed  to  take  appropriate  and  proportionate  corrective 
action  to  bring  the  non-compliance  to  end  and  non-compliance  appears  to  be  systematic, 
market  surveillance authorities are called to  have recourse to  the available corrective means 
under  the  Market  Surveillance  Regulation,  including  the  withdrawal  and  recall  of  products, 
the prohibition that they are made available in the market, as well as well as the imposition of 
penalties reflecting also the systematic nature of non-compliance36. 

33 As provided for in Article 46(3) of the Union Customs Code 
34 The precise list of products will be determined in agreement with Member States.  
35  E.g.  Customs  Risk  Management  System  (CRMS2),  the  Import  Control  System  (ICS2),  the  EU  SafetyGate, 
the  Information  and  Communication  System  for  Market  Surveillance  (ICSMS),  the  computerised  system 
referred to in Article 133(4) of Regulation (EU) 2017/625 (TRACES) and the Rapid Alert System for Food 
and Feed (RASFF).  

36 Cf Articles 16, 19 and 41 of Regulation 2019/2020 on market surveillance. 

10 

 
 
 
This  PCA  action  would  be  supported  by  the  Customs  Expert  Group37,  in  close  cooperation 
with  the  competent  market  surveillance  authorities  and  the  new  expert  team  in  the  EU 
Customs Alliance for Borders (EUCABET). 

In parallel, actions such as those by the European Anti-Fraud Office to combat fraud patterns 
in e-commerce, such as the abuse of rules related to the IOSS, will continue. 

In the medium-term, the facts and evidence collected under the PCA should be shared across 
a  wider  set  of  authorities,  and  support  coordinated  enforcement  actions  between  customs, 
market  surveillance,  environmental,  consumer  protection  and  digital  services  authorities.  In 
particular, the PCA could support the enforcement of the Digital Services Act and actions by 
the Consumer Safety Network (CSN). 

Findings  from  the  PCA  should  also  inform  the  third  multi-annual  Work  Programme  of  the 
Customs  Control  Equipment  Instrument38  planned  to  be  adopted  in  2025,  including  a 
dedicated call on e-commerce with a budget of EUR 100 million39. 

The Commission calls on all Member States to participate in the PCA and will publish a 
public report on the lessons learnt and findings. 

2.2.2. 

Joint  enforcement  actions  on  product  safety,    combatting  counterfeiting  and 
enhancing security 

The  Market  Surveillance  Regulation  and  the  General  Product  Safety  Regulation  provide 
market surveillance authorities in the Member States with the necessary enforcement powers, 
including with respect to products sold online. They can, for example, issue take-down orders 
for  removal  of  dangerous  or  non-compliant  products  from  online  shops  and  online 
marketplaces.  Products  investigated  and  the  related  measures  must  be  communicated  in  the 
Information  and  Communication  System  for  Market  Surveillance  (ICSMS)  and  measures 
taken concerning unsafe products shall be notified by Member States to the EU Safety Gate40, 
the rapid alert system for dangerous non-food products managed by the Commission. 

Learning  from  the  first  experiences  of  the  PCA,  the  Commission  will  launch  a  special 
Coordinated Activity  on  the  Safety  of  Products  (CASP),  open  to  all  Member  States,  to 
improve  structural  cooperation  between  customs  and  market  surveillance  authorities 
regarding products or product categories sold online, to jointly assess the risks and to identify 
the appropriate corrective measures.  In addition, the Commission will also propose in 2025 
within  the  framework  of  the  Consumer  Safety  Network  to  conduct  joint  product  testing 
activities  of  the  Consumer  Safety  Network,  that  would  also  allow  market  surveillance 
authorities  to  sample  products  online,  under  a  cover  identity.    The  Commission  calls  on 
Member States to ensure their active participation in these activities. 

In the second quarter of 2025, the Consumer Safety Network will carry out its first product 
safety sweep41 to check and enforce compliance of product listings in product categories that 

37 The Customs Expert Group – Controls and Risk Management section, composed of risk management experts 

of Member States, meeting together with the participation of Market Surveillance Authorities. 

38  The  Commission  already  allocated  more  than  EUR 550  million  as  part  of  the  first  two  Multi-Annual  Work 
Programmes (2021-2022 and 2023-2024 respectively) to Border Crossing Points and Customs Laboratories. 
With  more  than  EUR  440  million  still  available  under  the  current  MFF,  the  programme  will  continue  to 
support and prioritise e-commerce. In order to further strengthen such controls, the interoperability (exchange 
of  information)  and  the  co-sharing  of  equipment  with  other  authorities  (in  particular  Market  Surveillance 
Authorities) will also be emphasised.  

39  The  envelope  is  intended  to fund  e-commerce  control by the  EU  customs  authorities,  but  equipment  jointly 

used by customs and market surveillance or health authorities is also eligible. 

40 https://ec.europa.eu/safety-gate/#/screen/home  
41 Simultaneous coordinated control actions 

11 

 
 
 
are  most  frequently  ordered  online.  Using  the  EU  eSurveillance  tool  provided  by  the 
Commission,  the  authorities  will  focus  on  the  completeness  of  the  safety  information  in  a 
product  listing,  including  the  details  of  the  EU  responsible  person,  and  on  the  detection  of 
products that were already notified to the EU Safety Gate.  

The  Commission  is  also  working  to  strengthen  the  Customs  Laboratories  European 
Network (CLEN)42, essential to support the work of market surveillance, health and customs 
authorities.  It  is  also  setting  up  EU  Testing  Facilities  under  the  Market  Surveillance 
Regulation  to  enhance  product  testing  capacity  for  market  surveillance  authorities  in  the 
Member States43.  

Among the novel actions against counterfeit and other illicit products, the Commission is 
supporting  preparations  for  the  new  European  Multidisciplinary  Platform  Against 
Criminal  Threats  (EMPACT)  for  2026  to  2029.  This  should  leverage  the  coordination 
between  enforcement  authorities,  including  the  police,  customs,  prosecutors,  to  tackle 
harmful,  non-compliant  and  illicit  products  linked  to  criminal  activities.  In  addition,  the 
European  Anti-Fraud  Office  (OLAF)  continues  to  investigate  fraudulent  imports  via  e-
commerce of counterfeit goods harmful to the health and safety of consumers. 

The Commission is also supporting European innovation (Consortia of European innovators, 
industry  and  authorities)  to  develop  innovative  European  technologies  for  the  security  of  e-
commerce.44  

The Commission: 

-  Proposes  a  priority  control  area  (PCA)  on  e-commerce  imports  shipped  directly  to 
consumers,  with  the  cooperation  of  market  surveillance  authorities,  and  a  medium-term 
objective  to  feed  the  coordinated  application  of  a  wider  set  of  rules,  including  digital 
regulation.  The  Commission  calls  on  Member  States’  participation  and  will  release  a 
public report on the lessons learned and findings. 

-  Supports  a  new  Coordinated  Activity  on  the  Safety  of  Products  and  other  market 
surveillance  joint  actions  focused  on  product  safety  in  e-commerce  and  calls  on  the 
Member States to actively participate. 

-  Address  the  fight  against  trafficking  of  illicit  goods  as  well  as  goods  breaching  the  law 
linked  to  circular  economy  including  e-commerce,  in  line  with  the  priorities  of  the  next 
EMPACT cycle.  

2.3. 

Strong enforcement of EU legislation protecting consumers online 

The EU has  a comprehensive set  of rules, unique in  the world,  to  protect  consumers online 
and  set  out  very  clear  responsibilities  for  online  marketplaces.  The  enforcement  of  the 
consumer protection acquis, as well as the new Digital Services Act and Digital Markets Act, 
are  a  high  priority  for  the  Commission.  Coordinated  actions  and  tight  cooperation  is  key  - 

42  Rationalising,  coordinating  and  optimising  the  use  of  human  and  technical  resources  among  EU  customs 
laboratories,  dealing  mostly  with  illicit  drugs  and  narcotics,  but  also  food  and  beverages,  textile  or  other 
manufactured articles, plastics and other chemicals. 

43 EU testing facilities have been designated under Article 21 of Regulation (EU) 2019/1020 in several product 

sectors, including toys, radio equipment and ecodesign/energy labelling.  

44  This  includes  EU-funded  research  projects  PARSEC  (Parcel  and  Letter  Security  for  Postal  and  Express 
Courier  Flows),  iFLOWS  (Advanced  technologies  for  scanning  and  detection  of  illicit  material  for  postal 
services and express courier flows), and ODYSSEUS. 

12 

 
 
 
across authorities, as well as all stakeholders, as illustrated by recent investigations45, as well 
as frameworks such as the EU toolbox against counterfeiting46. 

2.3.1.  Responsibilities of online marketplaces: the Digital Services Act 

The  Digital  Services Act  (DSA)  sets  EU-wide  rules  for  online  intermediaries,  including  for 
online marketplaces that connect sellers with consumers. The rules seek to ensure that traders 
can  only  sell  products  on  online  marketplaces  that  are  compliant  with  the  relevant  product 
safety and other requirements.  

Online marketplaces have an obligation to counter illegal goods offered through their service. 
This includes, for example, the obligation to put in place user-friendly notice-and-action and 
complaint  mechanisms,  a  duty  of  cooperation  with  trusted  flaggers,  a  ban  on  dark  patterns, 
rules  on  advertising,  and  detailed  transparency  obligations,  including  how  products  are 
recommended to consumers. 

They  also  have  a  ‘know  your  business  customer’  obligation  that  should  dissuade  non-
compliant  sellers  from  offering  their  products  in  the  EU  through  marketplaces,  and  bring 
practical support in tracing traders that do not apply EU rules. In practice, marketplaces have 
to  gather  information  about  traders  before  they  offer  their  products  on  the  platform.  This 
includes,  for  example,  the  identity  and  contact  details  of  the  trader,  information  on  their 
payment account, their trade registration details, and a self-certification committing the trader 
to only offer products that comply with EU rules. By 17 February 2025, marketplaces should 
have  completed  their  best  efforts  to  gather  and  assess  the  information  from  traders  already 
present  on  their  platform  one  year  beforehand,  i.e.  on  17  February  2024.  They  must 
continuously request the information and perform similar checks for every trader that joins the 
platform before they can offer products in the EU. 

In  its  supervisory  role,  the  Commission  is  particularly  attentive  to  the  application  of  this 
obligation, as a key instrument for deterring rogue sellers from targeting consumers in the EU. 
The  information  collected  from  the  trader  is  essential  for  consumers,  but  also  for  the 
platform’s  own  corrective  actions,  for  example  in  suspending  traders  that  repeatedly  offer 
illegal goods. In addition, it can also serve competent authorities for example in supervising 
product  safety  rules.  The  DSA  facilitates  the  enforceability  of  orders  issued  by  competent 
judicial  or  administrative  authorities  to  remove  illegal  content,  including  illegal  products 
offered by sellers. 

Marketplaces  are  also  required  to  ensure  ‘compliance  by  design’,  i.e.  their  interface  must 
enable  traders  to  provide  all  the  required  pre-contractual  information  and  other  compliance 
and  product  safety  information  under  applicable  Union  law.  They  also  need  to  inform 
consumers in case they have purchased an illegal product through their service. 

Twenty-five online platforms, including several online marketplaces47, were designated by the 
Commission as very large online platforms and search engines48 after reaching more than 45 
million average monthly recipients in the EU. They need to put in place robust measures to 
assess and mitigate the risks posed by the design, the functioning and the use made of their 
services.  This  includes  the  need  to  assess  and  mitigate  risks  related  to  the  dissemination  of 

45 See the coordinated investigation against Temu by the European Commission, under the Digital Services Act, 

and the Consumer Protection Cooperation (CPC) Network, under consumer protection rules, infra,p. 16 

46 Commission Recommendation (EU) 2024/915 of 19 March 2024 on measures to combat counterfeiting and 

enhance the enforcement of intellectual property rights 

47 Amazon, AliExpress, Apple AppStore, Booking, Google Shopping, Google Play, SHEIN, Temu and Zalando. 
48 https://digital-strategy.ec.europa.eu/en/policies/list-designated-vlops-and-vloses  

13 

 
 
 
non-compliant goods, risks to a high level of consumer protection in the EU, or risks related 
to public health, minors, and the physical well-being of individuals. 

The Commission considers as a high priority enforcement actions related to such risks 
on designated online marketplaces, and is  enhancing the cooperation and coordination 
with national competent authorities.  

The Commission has launched investigative actions under the DSA in relation to SHEIN49 
and  Amazon50  and  has  formally  initiated  proceedings  against  AliExpress  on  14 March 
202451  and Temu  on  31  October  202452. The  latter  investigation  is  also  complemented  by  a 
coordinated action under the Consumer Protection Cooperation (CPC) network53. 

The  Commission  will  continue  to  monitor  compliance  and,  where  needed,  initiate 
proceedings in the framework of which it could focus on the most impactful measures, such 
as  the  ‘know  your  business  customer’  obligations,  the  systematic  compliance  by  online 
marketplaces  with  removal  or  information  orders  received  from  competent  authorities, 
supporting their coordinated actions and the application of the legislation they are enforcing. 
The  Commission  is  particularly  attentive  to  the  hybrid  business  model  of  certain 
marketplaces,  i.e.  instances  where  they  act  as  intermediaries  and  are  also  themselves  direct 
sellers or exert control over sellers54. 

The  Commission  will  also  build  on  coordinated  actions  such  as  the  PCA  and  those 
carried out with the Consumer Protection Cooperation (CPC) Network and take note of 
their findings relevant to its investigations under the DSA. 

It will further seek to enhance its capability through  agreements with other Union bodies, 
offices  and  agencies  with  relevant  expertise,  such  as  a  working  arrangement  with  the  EU 
Intellectual  Property  Office  (EUIPO)  to  support  its  enforcement  actions  regarding  e-
commerce platforms that may represent a systemic risk of a flood of counterfeit goods into the 
Union. 

It is essential that a strong network of enforcers is built across the EU, aligning their efforts, 
sharing  information,  streamlining  actions  and  amplifying  the  overall  impact  of  enforcement 
actions  and  regulatory  oversight.  Within  the  Member  States,  Digital  Services  Coordinators 
(DSC) are competent for the enforcement of the DSA. Other competent authorities should 
also  be  effectively  involved,  in  particular  those  with  expertise  and  related  competences  in 
product  safety,  compliance  and  consumer  protection.  Since  it  started  its  work  in  February 
2024, the European Board for Digital Services  became an essential network of regulators 
fostering  cooperation  and  has  a  dedicated  working  group  for  consumer  protection,  ensuring 
the link with the Consumer Protection Cooperation (CPC) Network. 

49  https://digital-strategy.ec.europa.eu/en/news/commission-requests-information-online-marketplaces-temu-

and-shein-compliance-digital-services-act  

50  https://digital-strategy.ec.europa.eu/en/news/commission-sends-request-information-amazon-under-digital-

services-act  
https://digital-strategy.ec.europa.eu/en/news/commission-requests-information-amazon-under-digital-
services-act. 

51  https://digital-strategy.ec.europa.eu/en/news/commission-opens-formal-proceedings-against-aliexpress-under-

digital-services-act.  

52  https://digital-strategy.ec.europa.eu/en/news/commission-opens-formal-proceedings-against-temu-under-

digital-services-act.  

53  See below and at https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5707  
54  For  products  sold  directly  by  the  online  marketplace  or where  it  exerts  control  over  the  seller,  the  provider 

could be found liable for the sale of illegal products, in accordance with Article 6 DSA 

14 

 
 
 
To gather evidence in a more meaningful way, some Member States have taken the initiative 
of  establishing  cross-sectorial  cooperation  through  an  e-commerce  task  force  at  national 
level, including DSCs, the consumer protection, market surveillance and customs authorities. 
The Commission is ready to support the creation of such task forces in all Member States in 
2025 with the help of the DSA officers placed in the Commission Representations and ensure 
that  they  feed  the  work  of  the  European  Board  for  Digital  Services  and  the  national  and 
Commission enforcement actions under the DSA. 

In parallel  to  these efforts,  the Commission  will also  evaluate, by  November 2025, the way 
that the DSA interacts with other legal acts, such as the consumer acquis and the product 
safety  rules55.  Where  appropriate,  this  report  may  be  accompanied  by  a  proposal  of 
simplification of existing rules.  

2.3.2.  Responsibilities  of  traders  and  other  online  businesses:  furthering  and  enforcing 

consumer protection rules 

Whether or not they sell through online marketplaces, traders who offer their goods and 
services in the EU, including those established in third countries, have to respect the EU 
consumer protection laws56. The rules  apply  online as they do offline, and they ensure the 
highest standard of consumer protection, for instance by shielding consumers in the EU from 
deceitful practices and scams, and allowing consumers to make informed decisions and avoid 
hidden costs or risks. 

In addition, online marketplaces can affect consumer decisions through their interfaces, 
including by determining the ranking of search results, providing recommendations, but also 
by  using  dark  patterns,  addictive  design,  and  aggressive  or  unsolicited  personalised 
advertising.  The  DSA  prohibits  dark  patterns  on  online  marketplaces  and  regulates  other 
practices, imposing obligations for example as regards the design of their interfaces and their 
recommender  systems,  imposing  disclosures  towards  consumers,  and  prohibiting them  from 
presenting certain types of personalised ads. 

Online marketplaces are also subject to the general EU consumer law provisions that apply to 
all traders and prohibit unfair commercial practices that interfere with the consumers’ choices. 
The Digital Fairness Fitness Check57 concluded that the largely principles-based approach of 
the  consumer  protection  laws  does  not  provide  sufficient  legal  certainty  regarding  their 
application in the digital environment, beyond the DSA. The Commission plans to propose a 
Digital  Fairness Act  to  reinforce  consumer  protection  in  a  targeted  manner,  making  more 
concrete  the  principles  in  the  existing  consumer  protection  rules  and  filling  the  identified 
gaps. 

National  consumer  protection  authorities  or  national  courts  are  responsible  for 
enforcing consumer protection laws. They can, for example, order websites or social media 

55 As mandated by Article 91 DSA. 
56 E.g. Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair 
business-to-consumer  commercial  practices  in  the  internal  market,  Directive  2011/83/EU  of  the  European 
Parliament  and  of  the  Council  of  25  October  2011  on  consumer  rights,  Council  Directive  93/13/EEC  of  5 
April 1993 on unfair terms in consumer contracts, Directive 98/6/EC of the European Parliament and of the 
Council  of  16  February  1998  on  consumer  protection  in  the  indication  of  the  prices  of  products  offered  to 
consumers,  Directive  (EU)  2019/771  of  the  European  Parliament  and  of  the  Council  of  20  May  2019  on 
certain  aspects  concerning  contracts  for  the  sale  of  goods,  amending  Regulation  (EU)  2017/2394  and 
Directive 2009/22/EC, and repealing Directive 1999/44/EC,  

57  Commission  Staff  Working  Document  Fitness  Check  on  EU  consumer  law  on  digital  fairness  |  European 

Commission. 

15 

 
 
 
accounts containing scams to be corrected, disabled or removed, and can order the closure of 
accounts of non-cooperative traders. 

The  Commission  works  with  the  Consumer  Protection  Cooperation  (CPC)  Network  of 
authorities responsible for the enforcement of EU consumer protection laws. The Commission 
can alert the CPC Network when there is a reasonable suspicion that an infringement of EU 
law  has  occurred.  The  Commission  coordinates  such  actions  when  a  large  portion  of  EU 
consumers are concerned. The CPC Network has carried out several actions58 and can initiate 
new  actions  against  e-commerce  traders  under  the  Consumer  Protection  Cooperation 
Regulation. In this context, there is an ongoing action against Temu. 

On 3 February 2025, the CPC Network and the Commission also informed SHEIN about 
the  launch  of  coordinated  action  to  investigate  the  compliance  of  the  online  marketplace 
and  e-retailer  with  certain  obligations  under  EU  consumer  laws59.  The  ongoing  joint 
investigation of the CPC Network is coordinated by the Commission. 

Coordinated efforts: the DSA and CPC cases against Temu  

The  recent  investigations  concerning  Temu  showcase  how  the  DSA  and  the  CPC  and 
regulatory instruments can reinforce each other, and how the authorities can leverage their 
powers for effective actions. 

On  31  October  2024,  the  Commission  opened  an  investigation  into  Temu60  for 
suspected violations of the DSA, including the risk identification and the lack of mitigation 
measures  to  limit  the  reappearance  of  previously  suspended  rogue  traders  or  the 
reappearance of non-compliant goods; the risks linked to the addictive design of the service, 
including game-like reward programmes, and the systems Temu has in place to mitigate the 
risks  stemming  from  such  addictive  design  and  pressure  selling,  including  through  dark 
patterns, which could have negative consequences for a person’s physical and mental well-
being; recommender systems, including the provision of at least one easily accessible option 
that is not based on profiling; and the obligation to give researchers access to data. 

The  Commission’s  investigation  is  ongoing  and  is  supported  by  customs,  market 
surveillance authorities and consumer protection authorities through the European Board for 
Digital  Services.  It  is  also  informed  by  Temu’s  replies  to  the  Commission’s  requests  for 
information, as well as evidence from mystery shopping and consumer complaints submitted 
by  third  parties61.  Should  the  Commission  conclude  that  the  platform  is  in  breach  of  the 
DSA, the provider would face, among other sanctions, potential fines that could go up to 6% 
of its global turnover. 

On 8 November 2024, following a joint investigation carried out by the CPC Network 
and coordinated by the Commission, the CPC Network notified 62 Temu of a number of 
practices that were considered as infringing EU consumer laws. These include practices 
related to fake discounts, dark patterns to pressure consumers, forced gamification, missing 
and  misleading  information,  fake  reviews  and  hidden  contact  details.  The  CPC  Network 

58  e.g.  CPC  coordinated  actions  against  AliExpress  or  Wish:  https://commission.europa.eu/live-work-travel-
eu/consumer-rights-and-complaints/enforcement-consumer-protection/coordinated-actions/market-places-
and-digital-services_en#aliexpress-and-wish  

59 Unfair Commercial Practices Directive, the Consumer Rights Directive, the Unfair Contract Terms Directive, 
the  Price  Indication  Directive,  and  the  E-commerce  Directive.  The  launch  of  such  a  coordinated  action  is 
without prejudice to the conclusions subsequently reached. 

60 See supra, p.14  
61 Taming Temu | BEUC 
62 https://ec.europa.eu/commission/presscorner/detail/it/ip_24_5707.  

16 

 
 
 
directed Temu to propose commitments on how the company will address the issues. 

In  addition,  the  CPC  Network  requested  information  from  Temu  to  assess  the  company's 
compliance with other obligations under EU consumer law, such as the obligation to inform 
consumers clearly whether the seller of a product is a trader or not, to ensure that product 
rankings, reviews, and ratings are not presented to consumers in a misleading way, that price 
reductions  are  announced  and  calculated  correctly,  and  to  ensure  that  any  environmental 
claims are accurate and substantiated. 

Temu’s  replies  to  the  findings  and  questions  addressed  by  the  CPC  Network  are  currently 
being assessed.  

The Commission remains committed to supporting and coordinating the enforcement work of 
the CPC Network using all tools available.  For example, the AI capabilities of its evidence-
gathering  toolbox  eLab  will  be  used  to  carry  out  simultaneous  automated  checks  on  major 
online marketplaces. The Commission plans to share the results of such checks with the CPC 
Network,  which  may  decide  to  follow-up  with  enforcement  actions  under  the  CPC 
Regulation. 
In line with the findings of its recent report63 on the application of the Consumer Protection 
Cooperation  (CPC)  Regulation,  the  Commission  is  reflecting  on  a  review  of  the 
Regulation64, in order to further strengthen the enforcement of EU consumer law, in particular 
as regards widespread illegal practices, irrespective of whether the perpetrators are established 
within or outside the Union, with a view to ensuring a level-playing field. 

2.3.3.  Dispute resolution for e-commerce  

Despite all efforts, some situations where non-complaint goods are purchased in the EU will 
inevitably occur, and it is important for consumers to have access to meaningful redress. The 
new  product  liability  framework  for  defective  products  adopted  in  October  2024  will  be 
applicable from end 202665 and ensure that there is always a person liable for products where 
the manufacturer is not established in the EU. The DSA also provides tools for consumers and 
their representatives to flag illegal goods to online marketplaces and seek redress. 

In  addition,  the  Commission  proposed  a  review  of  the  Alternative  Dispute  Resolution 
(ADR) directive66 to ensure that out-of-court dispute resolution legislation is fit for the digital 
age,  including  when  disputes  involve  non-EU  traders.  The  Commission  calls  on  the  co-
legislators  to  swiftly  adopt  the  revised  ADR  directive,  and  calls  for  the  take-up  of  the 
accompanying  Recommendation  promoting  high  quality  criteria  of  the  dispute  resolution 
procedures offered by online marketplaces and Union trade associations.67 

63https://commission.europa.eu/document/download/569266a1-22d9-4871-a143-

a3671b417507_en?filename=Report%20B3%20cpc.pdf.  

64https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13535-Consumer-protection-

strengthened-enforcement-cooperation_en.  

65 Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability for 

defective products and repealing Council Directive 85/374/EEC. 

66  Proposal  for  a  Directive  amending  Directive  2013/11/EU  on  alternative  dispute  resolution  for  consumer 

disputes, as well as Directives (EU) 2015/2302, (EU) 2019/2161 and (EU) 2020/1828.  

67  Commission  Recommendation  (EU)  2023/2211  of  17  October  2023  on  quality  requirements  for  dispute 

resolution procedures offered by online marketplaces and Union trade associations.   

17 

 
 
 
2.3.4.  Opening  business  opportunities  for  alternative  operators  to  reach  EU  consumers 

online: the Digital Markets Act 

European  SMEs  have  become  heavily  dependent  on  online  platforms,  including  online 
marketplaces.  The  Digital  Markets  Act  (DMA)  opens  up  possibilities  for  alternative 
businesses, including small online marketplaces, to become the next go-to platform. For this 
to  be  a  real  possibility,  businesses  need,  for  example,  to  be  able  to  move  across  platforms 
without losing their data. The DMA obliges gatekeepers68 to provide real-time and continuous 
data  portability  to  end  users  and  authorised  third  parties,  and  data  access  for  business  users 
and authorised third parties. 

The  Commission  will  prioritise  the  effective  enforcement  and  supervision  under  its  DMA 
powers  vis-à-vis  gatekeepers,  including  for  practices  that  impact  the  European  e-commerce 
sector, to  ensure that  those gatekeepers respect  their obligations to  put  in  place measures to 
comply with the DMA. The Commission will use all DMA tools, including where appropriate 
hiring  of  experts  and  auditors  to  access  gatekeepers’  algorithms  and  supervise  their 
compliance. 

The Commission: 

-  Will  continue prioritising enforcement actions under the Digital  Services Act  (DSA) on 
the  compliance  by  major  online  marketplaces.  The  Commission  will  intensify  its  DSA 
supervisory actions, reinforce its capabilities and partnerships with EU agencies, such as 
EUIPO, and participate in coordinated actions with competent authorities.  

-  Calls  on  the  Member  States  to  appoint  competent  authorities  and  establish  e-commerce 
task  forces,  supporting  the  enforcement  of  the  DSA  and  the  coordinated  actions  under 
other  legal  regimes.  The  Commission  will  support  the  Member  States  through  the  new 
DSA officers in its representations, and through coordination in the European Board for 
Digital Services.  

-  Will evaluate the way that the DSA interacts with other legal acts. 

-  Will  continue  to  support  the  Consumer  Protection  Coordination  Network,  including 

through its evidence-gathering eLab toolbox.  

-  Will  continue  the  work  on  a  possible  review  of  the  Consumer  Protection  Cooperation 

Regulation.  

-  Calls  on  the  co-legislators  to  swiftly  adopt  the  revised  Alternative  Dispute  Resolution 

Directive.  

-  Will  prioritise  the  enforcement  of  the  Digital  Markets  Act  vis-à-vis  the  way  digital 

gatekeepers impact the e-commerce sector. 

2.4. 

Better supervisory capability through digital tools  

Digital  solutions  can  be  key  enablers  for  the  supervision  of  the  e-commerce  landscape, 
supporting authorities and legitimate market players ensuring compliance with EU law. 

First, the Commission is prioritising the effective implementation of the Digital Product 
Passport  (DPP)  as  provided  for  by  the  Ecodesign  for  Sustainable  Products  Regulation 
(ESPR),  the  Batteries  Regulation  and  other  relevant  sectoral  legislation.  Over  time,  most 
physical  goods  placed  on  the  EU  market  or  put  into  service  will  require  a  DPP. The  ESPR 

68 Including, for example, Google Shopping, Amazon Marketplace, Meta Marketplace. See full list of designated 

gatekeepers at DMA designated Gatekeepers  

18 

 
 
 
envisages  the  adoption  of  sectoral  delegated  acts  that  will  gradually  set  ecodesign 
requirements  and  introduce  the  DPP  for  specific  product  groups.  The  first  working  plan, 
setting out which products will be prioritised over the coming years, will be adopted in April 
2025. This will bring unprecedented transparency and traceability across product value chains 
and provide relevant  information such as product’s technical  performance, origin, materials, 
environmental impact, and repair, recycling and disposal recommendations, through a system 
that imposes minimal administrative burden on participating businesses. 

The Commission will also seek to propose re-using the DPP system in other policy areas, 
using it as an entry point for further product-specific information and documents such 
as conformity certificates.  

The  DPP,  together  with  the  EU  Single Window  Environment  for  Customs  and  later  the  EU 
Customs  Data  Hub,  will  also  simplify  the  work  of  customs  authorities,  market 
surveillance  authorities,  and  economic  operators  when  a  product  enters  the  EU  market. 
With  relevant  conformity  assessment  and  traceability  information  consolidated  into  a  single 
identifier,  customs  authorities  can  more  efficiently  verify  that  all  necessary  product 
information has been provided in the DPP. Customs authorities will also use the information 
made  available  through  the  DPP  for  risk  management  purposes  and  to  target  their  controls. 
This  will  not  only  cut  costs  for  national  enforcement  bodies  but  also  significantly  improve 
product safety across the single market and simplify life for compliant businesses. 

Moreover, a number of IT tools and databases support competent authorities and sometimes 
online  marketplaces  in  the  detection  of  illegal  products.  The  Commission  is  preparing  a 
project  to streamline the existing databases,  including, as  a first  step,  the EU Safety  Gate 
and  the  Customs  Risk Management  System,  into  a  unified,  interoperable  system  that  will 
increase  synergies  in  the  information  gathered  by  the  different  authorities  and  ensure 
interoperability  with  the  DPP.  This  should  facilitate  quicker  detection  of  non-compliant 
products  and  tracking  by  relevant  authorities.  It  should  enable  online  marketplaces  to  react 
more efficiently to threats and to put in place random checks on products. 

Finally, the Commission is putting at the disposal of market surveillance authorities new AI-
enabled web crawlers. The E-Surveillance WebCrawler is already available and used to flag 
reappearing  dangerous  products  already  listed  in  the  Safety  Gate  and  generates  automated 
take-down  requests.  The  Commission  has  developed  web  crawlers  to  identify  products  that 
are  non-compliant  with  ecodesign  and  energy  labelling  requirements.  The  Commission  also 
plans  on  making  available  another  web  crawler  in  2025  to  perform  automated  searches  for 
potentially non-compliant products on online marketplaces69. 

The Commission: 

-  Will prioritise the implementation of the Digital Product Passport across different product 

categories. A first action plan will be adopted by April 2025. 

-  Aims  at  streamlining  existing  databases  into  an  interoperable  system,  focusing  on  the 
Safety  Gate  and  the  Customs  Risk  Management  System  (CRMS2)  as  a  first  step,  early 
2025. 

-  Will continue to provide to market surveillance authorities the e-Surveillance WebCrawler 
for  reappearing  dangerous  products,  and  will  make  available  another  web  crawler  for 
detecting new listings.  

69 It should screen product offers and consumer reviews,  using keywords indicating potential non-compliance, 

selected by market surveillance inspectors, and computing lists of potentially non-compliant products. 

19 

 
 
 
2.5. 

Empowering  consumers,  providing  better 
encouraging voluntary actions 

information  for  traders  and 

Awareness raising, education and information are strong tools for empowering consumers to 
make choices aligned with their interests and values, as well as effective tools to deter traders 
from engaging in the sale of dangerous, counterfeit or otherwise non-compliant products. 

The  Commission  is  supporting  a  series  of  measures  to  inform  consumers  online.  For 
example, the ecodesign requirements for textiles and other products under the Ecodesign for 
Sustainable  Products  Regulation  will  better  inform  consumers  about  sustainability  aspects 
such  as  environmental  impacts,  energy  use,  repairability  or  durability.  In  addition,  the 
Commission will support the training of consumer professionals in Member States through 
the  upcoming  phase  of  the  ‘train-the-trainer’  ConsumerPRO  programme,  enabling 
consumer  organisations  to  provide  more  personal  advice  on  the  ground  on  sustainable 
purchasing habits. 

Furthermore,  the  Commission’s  proposed  regulation70  on  CountEmissions  EU  aims  to 
improve  the  transparency  on  the  performance  of  deliveries  by  setting  common  rules  on  the 
accounting of greenhouse gas emissions of transport services. 

For  the  last  20  years,  the  European  Consumer Centres  Network  (ECC-Net),  co-founded 
by the Commission,  has been educating EU consumers on their rights  in  the single market 
and  assisting  them  in  resolving  cross-border  disputes71.  The  ECC-Net  will  step  up  its 
awareness-raising  campaigns  on  consumer  rights,  potential  risks  and  redress  mechanisms 
when purchasing online, with a focus on non-EU traders. They could also engage with the 
online marketplaces. 

The EU also has a number of other frameworks for awareness raising, mutual assistance and 
voluntary  actions  taken  up  by  online  marketplaces  and  other  online  platforms,  civil  society 
and industry representatives. This  includes, for example, the Product  Safety  Pledge+72, with 
11  participating  platforms,  the  Memorandum  of  Understanding  against  counterfeit  products, 
bringing together online marketplaces and brands, as well as the EU Internet Forum, initially 
focusing on terrorist content online, but also incorporating actions and a Knowledge Package 
on  Combating  Drug  Sales  Online,  providing  intelligence  on  keywords  and  tactics  used  by 
online drug traffickers. 

The Commission: 

-  Will  support,  including  through  the  European  Consumer  Centres  Network  (ECC-Net), 

further awareness-raising campaigns, with a focus on non-EU traders. 

-  Will  support,  through  the  ConsumerPRO  programme,  the  training  of  consumer 

professionals in Member States to provide more personal advice to consumers. 

-  Calls on the co-legislator to adopt the proposed regulation on CountEmissions EU.  

-  Will continue to support and incentivise voluntary cooperation of online marketplaces and 
other stakeholders through forums such as the Product Safety Pledge+, the Memorandum 
of Understanding against Counterfeit Products or the EU Internet Forum.  

70 Count your transport emissions – ‘CountEmissions EU’ 
71https://commission.europa.eu/live-work-travel-eu/consumer-rights-and-complaints/resolve-your-consumer-

complaint/european-consumer-centres-network-ecc-net_en.  

72 Product safety pledge - European Commission 

20 

 
 
 
2.6. 

Bilateral cooperation and trade considerations 

The  concerns  highlighted  by  the  Commission  in  this  Communication  and  stemming  from 
imported low-value shipments are shared across the globe. Other jurisdictions are exploring or 
have already applied measures such as reductions or removals of de minimis exemptions on 
customs tariffs, introducing VAT for de minimis shipments, or enhancing their own regulatory 
framework for e-commerce platforms. 

Better educating sellers in third  countries is  also  an extremely  important measure.  For 
example,  given  the  high  number  of  products  imported  from  China,  the  Commission  will 
continue  the  awareness  raising  and  training  activities  on  EU  product  safety  rules  targeting 
Chinese companies via the SPEAC (Safe non-food consumer Products in the EU and China) 
project, which has had over 800,000 participants since 2021. 

More  broadly,  the  Directorate  General  for  Justice  and  Consumers  of  the  European 
Commission  and  the  General Administration  of  Customs  of  the  People’s  Republic  of  China 
have  signed  an  administrative  arrangement  on  product  safety  cooperation  and  an 
accompanying action plan on the safety of non-food consumer products sold online. 

At the same time, the Commission stands ready at all times to take the appropriate measures 
to ensure that EU standards are being complied with and to protect European consumers and 
businesses. 

Should an EU industry provide sufficient evidence of dumped or subsidised imports causing 
injury,  the  Commission  will  examine  the  options  available,  including  under  trade  defence 
instruments. Furthermore, the Commission will assess any evidence on the existence of illegal 
subsidisation  regimes,  in  particular  export  subsidies  to  goods  and  subsidies  to  relevant 
services offered in the EU, in light of the appropriate rules. In this context, the Commission 
will consider all avenues for redress under international rules and EU law. 

The Commission: 

-  Will  continue  the  bilateral  cooperation  with  countries  of  provenance  of  imported  goods 
through awareness raising and training activities on EU product safety rules for third-party 
sellers and bilateral cooperation with third-country authorities. 

-  Will  assess  any  evidence  relating  to  the  existence  of  dumping  or  illegal  subsidisation 

regimes in third countries.  

3. 

CONCLUSION 

In  July  2024,  President  von  der  Leyen  announced  the  Commission’s  priority  of  ‘tackling 
challenges  with  e-commerce  platforms  to  ensure  consumers  and  businesses  benefit  from  a 
competitive e-commerce based on effective customs, tax and safety controls and sustainability 
standards’73.  With  this  Communication,  the  Commission  puts  forth  a  comprehensive  EU 
toolbox, including a series of coordinated measures to achieve this objective. Their urgency is 
confirmed by the surge of non-compliant products imported into the EU, the harms they cause 
to consumers and businesses, the impact they have on the environment and the strains placed 
on authorities in the Member States. 

The Commission stresses the need for joined-up and urgent action, with the active support of 
the co-legislators, the Member States and their national authorities, as well as of responsible 
industry players, consumer associations and international partners. 

73 Political Guidelines 2024-2029 | European Commission 

21 

 
 
 
The  Commission  will  assess  within  a  year  the  effect  of  the  actions  announced  in  this 
Communication. In light of the results and in consultation with the relevant authorities of the 
Member States and stakeholders, the Commission will consider whether existing frameworks 
and  enforcement  activities  applicable  to  imported  e-commerce  goods  delivered  directly  to 
consumers are adequate, or whether further actions and proposals are necessary for coherent 
implementation and solid enforcement of EU rules. 

22