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Policy uncertainty cost businesses US$202 billion in 2025 - and the stakes for 2026 are bigger 11 May 2026 Policy uncertainty cost businesses US$202 billion in 2025 - and the stakes for 2026 are bigger A new ICC report with Oxford Economics puts a price tag on policy volatility, for the first time quantifying its impact on real business investment across the world's largest economies - and the value of predictability itself. When the political environment is unstable, business does what business has to do: it waits. Boards delay capital projects, supply-chain decisions are postponed, hiring pauses, and the cost compounds. ICC and Oxford Economics have now put a price tag on that pattern. In a new report published in April 2026, they estimate that the surge in global economic policy uncertainty in 2025, driven primarily by trade policy volatility and culminating in the April 2025 "Liberation Day" tariff package, cost businesses around US$202 billion in lost or delayed investment across ten major economies, equivalent to 0.2% of global GDP. The figure is large in its own right. It is bigger than the entire United States defence procurement budget for FY2025 (around US$167 billion). It is more than double the global capital spend of Alphabet, Google's parent company, in a year of breakneck AI-driven expansion. And it is a conservative estimate — capturing only the direct, measurable impact on real business investment, holding other factors constant. The size of the underlying shock was itself unprecedented. The Global Economic Policy Uncertainty Index in 2025 reached its highest level on record, surpassing both the global financial crisis and the early phase of the COVID-19 pandemic. The damage was unusually broad-based: every one of the ten economies in the sample, Brazil, Canada, China, the EU-4 (France, Germany, Italy, Spain), India, Japan, Mexico, South Korea, the United Kingdom and the United States, together about 70% of world GDP, saw real business investment dragged down. Across the sample, investment grew just 0.4% in 2025. Absent the uncertainty shock, it would likely have grown more than four times faster, at 1.9%. The geographical pattern is instructive. Mexico and Canada were hit hardest in relative terms, with investment 6.8% and 5.3% below their counterfactual paths - losses comparable to a meaningful share of the contractions seen during the global financial crisis and the COVID-19 pandemic. The United States incurred the largest absolute loss, around US$74 billion, although a powerful AI-driven investment boom masked the underlying drag in the headline figures. South Korea, hit simultaneously by a domestic constitutional crisis and intensifying US trade pressure, saw investment 2.9% below the counterfactual. The United Kingdom, with a more services-led economy and lower exposure to US trade policy, was the least affected. The stakes for 2026 are higher still. The report models two scenarios. Under an adverse case - a renewed uncertainty shock of historical magnitude hitting all ten economies in Q2 2026 - real business investment could fall by 2.7%, or roughly US$380 billion, equivalent to 100% of FDI inflows to North America in 2025. Under a favourable case in which policy clarity is restored, investment could rise 1.8%, or US$252 billion. The gap between those two outcomes, more than US$630 billion, is, in effect, the value of policy clarity. The report's policy conclusion is deliberately non-partisan. Reducing the cost of uncertainty does not require policymakers to choose any specific direction; it requires clarity, consistency and predictability in how decisions are designed, sequenced and communicated. As the authors put it, "the way in which governments and international institutions manage the uncertainty that surrounds their decisions may matter as much as the decisions themselves." For Dutch businesses operating internationally, the takeaway is concrete. Predictability has moved from a political ideal to a balance-sheet item: something to be actively managed, monitored and, where possible, defended. ICC Netherlands will continue to advocate for policy stability, both in the global trade conversation and in the rule-making channels where Dutch business is represented. Read the full report → 2026_The_cost_of_policy_uncertainty_on_investment_Full_report_EN .pdf Download PDF • 2.46MB Read the summary → 2026_The_cost_of_uncertainty_on_investment_Executive_summary_EN .pdf Download PDF • 605KB For further details on the modelling or to discuss the findings, please contact Melanie Laloum at ICC.

Sanctions and export controls in 2026: where Dutch business is most exposed 26 Jun 2026 Sanctions and export controls in 2026: where Dutch business is most exposed For Dutch exporters, the trade-compliance landscape has shifted under foot. The Fiscal and Economic Investigation Service (FIOD) set up a dedicated sanctions enforcement team in 2025. Investigations and site visits are on the rise. The 20th EU sanctions package has landed, and the catch-all goods list has widened to a point where common consumer goods sit alongside the obvious dual-use items. At the second ICC Netherlands Digital Business Lunch on 26 June, more than 40 trade and compliance professionals joined Floor Koops, partner at Bennink Dunin-Wasowicz, and Ruud Altena, corporate compliance leader most recently at Braskem, for a practical conversation on where the risks now sit and what business should do about them. The session was moderated by Andrea Cardoso. A widening net The most striking trend, Koops said, is the steady tightening of the EU sanctions framework. Recent measures include new contractual clauses to prevent tankers being resold to Russian buyers, port infrastructure bans (including in Indonesia), restrictions on Russian crypto-asset providers, and an EU activation of its anti-circumvention tool with a full ban on certain exports to Kyrgyzstan. The number of exemptions and derogation options is shrinking. For an audience broadly familiar with sanctions, the most surprising element is how broadly the catch-all goods list now reaches. Typewriter ribbons, used clothes and seats for motor vehicles are now among the items restricted from export to Russia. A common reaction in the audience: we assumed our products were too ordinary to be caught. On Iran, Koops flagged the recent EU framework allowing further restrictive measures in response to actions threatening the freedom of navigation in the Strait of Hormuz, on top of restrictions tied to UAV manufacture, technical assistance, brokering and intellectual property. The under-prepared side Companies focus heavily on the export side and miss the import restrictions, Koops said. Since January 2026, the EU has restricted the import of petroleum products bought from other countries when they contain Russian-origin oil. Cigars, pebbles, refrigerators and dishwashers are also caught. Services are the other blind spot. EU restrictions cover two categories: outright bans on providing certain services to Russia (engineering, technical, IT and others), and services tied to goods that were previously restricted from export. Koops described seeing cases where a Dutch company owns goods already inside Russia from before 2022, and is now still prohibited from servicing them because of the underlying restriction. “If you do business in Russia or you have a subsidiary in Russia, there is almost no chance that you don’t also provide a service,” she said. Is a ship just a ship? Altena brought a case to the room. A USD 550 million shipbuilding project, financed in part by a Norwegian pension fund, sourced eight vessels from a Chinese shipyard. Due diligence revealed that the shipyard also built military vessels. The vessels were destined for Asia and South America, never the United States, but the team could not fully eliminate the risk that, somewhere in the operating life of the ship, US sanctions would touch the crew, the maintenance, the bunker fuel or the flag. “Is a ship just a ship? It’s much more. It’s by itself a legal entity. It’s a floating village requiring a crew, requiring maintenance of the ship itself, of the equipment on board,” Altena said. Each layer carries its own sanctions exposure. Sanctioned parties can supply bunker fuel, provide maintenance, or sit in the crew roster. The flag adds a diplomatic angle. Asked what he would do differently with the benefit of hindsight, Altena was direct: he would have pushed harder for South Korea over China. More expensive, politically safer, and the project sponsor would have slept better. The spare-parts trap Where Koops sees classification go wrong most often is in the treatment of spare parts. Companies routinely classify spare parts under the same HS code as the main good. The main good ships under its own export licence, but the spare part, taken on its own, may require a separate licence under the EU dual-use regime. A maintenance contract triggers a shipment of spare parts months later, customs treats it as classified, and the company has unwittingly breached. Even within the EU, certain dual-use items require a licence. A common mistake is to assume that intra-EU shipments are out of scope. They are not. Tone from the top On compliance programmes, Koops and Altena converged on the same message: trade compliance can no longer sit only with legal or the compliance function. A workable programme starts with a thorough risk assessment covering sector, goods exported and imported, counterparties (direct and indirect), geographies and modes of transport. From that assessment, a company can design a tailored programme with concrete steps, clear escalation paths, and workflows tailored to sales, procurement and supply chain. “Compliance should not be something that is a legal or compliance thing, but it should really be owned by the business,” Koops said. Sales, procurement and supply chain are the face of the company to the world. They have to own the risk. A clear, communicated risk appetite (what countries, what sectors will we not touch) is, in her view, the single most effective control a business can put in place. Altena added the operational piece. A regular survey of middle management, scoring the compliance posture on tariff classification, valuation, customs management and other dimensions on a one-to-five scale, lets a company track which weak points are improving and which are not. Annual full reviews, quarterly check-ins on the weaknesses. Document everything, train staff, audit at intervals. When the bank calls A significant share of unintentional breaches surface through bank payment screening. Koops urged companies to cooperate fully and document their answers carefully. Reluctance to share creates a worse problem than disclosure does. Banks that do not get clear answers will not process transactions, and over time they will close the account. Reopening an account elsewhere is materially harder than most companies expect. What Dutch businesses can start doing now Asked to close with five practical priorities, both speakers landed on overlapping but complementary lists. From Floor Koops : first, make sanctions and export-controls compliance a tone-from-the-top priority. It is a competitive advantage. Second, run a risk assessment and design a tailor-made compliance programme around it. Third, classify all of your goods, including spare parts. Fourth, set clear escalation paths, with business units owning the risk. Fifth, embed the culture: trade compliance as a strategic capability, not a backstop. From Ruud Altena : first, keep classification up to date, and aim not just for “correct” but for “optimised” for your supply chain. Second, validate your export tools and have a real conversation with your customs broker. Third, go beyond tier-one screening into the supply chain, on both supplier and customer sides. Fourth, take services seriously. They can be sanctioned, and the sovereignty discussion is widening the scope. Fifth, leverage tariff and free-trade agreements. They are also opportunities, and the Finance Director will thank you. The road ahead Through its Business Integrity Commission, ICC Netherlands continues to develop practical guidance across five working groups. The first deliverable, a set of minimum standards and plain-language one-pagers on sanctions compliance, is expected to be published after the summer, with further work underway on anti-corruption, integrated due diligence, and boardroom ethics. ICC Netherlands shares this work openly, and welcomes new organisations to join. The Digital Business Lunch is a monthly online series discussing the issues that move international trade, covering a range of subjects from tariffs and customs reform to AI in trade compliance, sustainability and IFRS. For more information about upcoming Digital Business Lunches: Events & Trainings | ICC WBO Netherlands or our LinkedIn page.

ICC Calls for Government Action and Business Expertise to Strengthen Global Cyber Resilience 21 Oct 2025 ICC Calls for Government Action and Business Expertise to Strengthen Global Cyber Resilience On 21 October 2025, the International Chamber of Commerce (ICC) released a statement urging urgent government action and stronger cooperation with business to build cyber resilience. The call comes as the United Nations establishes a new Global Mechanism to continue discussions on responsible state behaviour in cyberspace. Expected to hold its first meeting in March 2026 , the mechanism will determine how governments collaborate to prevent and respond to cyber threats; and how meaningfully non-governmental stakeholders, including business, will be able to participate. Why it matters The stakes could not be higher. Cyber incidents increasingly disrupt economies, critical infrastructure, and essential services worldwide. Yet uncertainty remains around how the private sector, which designs, operates, and defends the digital infrastructure underpinning the global economy, will be included in the new UN process. “Without stronger global cooperation and practical, inclusive approaches to cybersecurity, the digital foundations of growth and trust will remain at risk.” ICC Statement, October 2025 ICC’s position is clear: achieving cyber resilience requires both government leadership and business expertise . The private sector’s evidence-based input is essential to ensure that international policies reflect operational realities and deliver practical, implementable outcomes. The ICC statement: “Cyber resilience needs government action and business expertise” “Ransomware shutting down hospitals. Attacks on energy grids disrupting entire regions. Cyber operations spilling across borders in times of geopolitical tension. These are no longer distant hypotheticals – they are today’s headlines. The accelerating pace and scale of cyber threats is a stark reminder that the resilience of our economies and societies depends on decisions we make now. Without stronger global cooperation and practical, inclusive approaches to cybersecurity, the digital foundations of growth and trust will remain at risk. Over the past five years, the United Nations Open-Ended Working Group (OEWG) has provided a valuable forum for dialogue among states on responsible behaviour in cyberspace. Its work has underscored the importance of consensus in such a sensitive area of international security, while also highlighting the complexity of building common ground in a rapidly evolving threat landscape. Crucially, the OEWG experience has shown that dialogue alone is insufficient. Operational resilience requires deeper engagement with those who build, defend, and innovate within the digital ecosystem every day. The establishment of a new ‘Global Mechanism’ to carry forward these discussions is a welcome step – but its success will depend on embedding inclusivity at its core. That means not only governments, but also meaningful participation from the private sector, civil society and academia. Global business has unique expertise and operational responsibility in this domain. Companies design, develop, build and operate the networks, defend against attacks, and innovate the technologies that power the digital economy. That is why the private sector’s voice is indispensable in shaping solutions that are practical, effective and future-proof. Governments can strengthen global cyber resilience by: Building strong national institutions to reinforce security in the use of ICTs; Developing legislation that supports international commitments while enabling digital trade and innovation; Enhancing resilience to mitigate cyber threats; Strengthening international cooperation and capacity-building, especially for developing economies; Protecting critical infrastructure and improving incident response; Improving supply-chain and product security; and Increasing transparency in the attribution of malicious activities. To realise this vision, we urge UN Member States to: Institutionalise meaningful stakeholder engagement in the design of the Global Mechanism; Leverage industry expertise in developing norms, confidence-building measures, and threat assessments; Prioritise transparency and accountability in negotiations and implementation; and Recognise the vital role of private actors in defending against cyber threats. The cyber domain cannot be secured by governments alone. The new Global Mechanism offers an opportunity to embed multistakeholder participation as a foundation for progress. Only through processes that fully integrate private-sector expertise can international frameworks achieve both legitimacy and operational impact. As global business, we stand ready to contribute constructively to the next chapter of cyber diplomacy. The threats are real, but so is our collective capacity to meet them – if we work together.” A call for Dutch engagement For the Netherlands the UN’s new Global Mechanism offers a critical opportunity to shape the international governance of cyberspace . ICC Netherlands invites its members and partners to help amplify this message by: Sharing ICC’s statement with relevant contacts in government Highlighting the importance of business expertise in cybersecurity and digital infrastructure resilience; Engaging with ICC Netherlands’ Digitalisation working group to explore how Dutch industry can contribute practical insights to global discussions.

New 2024 Preliminary Figures on Dispute Resolution Released 21 Feb 2025 The role of mediation in dispute resolution Wanting to learn more about the role of mediation in dispute resolution, we spoke to dispute resolution expert Jeremy Lack. We quickly discovered that this was a subject that was as complex as it was interesting. That’s why we decided to divide our interview over two editions of the newsletter. You can read part one here . And below is part two, which looks closer at how the three main aspects of mediation – “there’s a social component, an emotional, and a rational component,” says Jeremy – relate to issues such as confidentiality, trust building, and the psychological tools and barriers to mediation. Let’s continue by talking about confidentiality in mediation; how should that be handled? It is important to understand the level of confidentiality required by the parties in each case, as this can vary depending on the nature of the dispute and the individuals involved. In general, there are two levels of confidentiality in mediation to consider. There’s confidentiality vis-à-vis the outside world, which relates to the existence of the dispute, the existence of the process itself and what was said during the process. The principle is that whatever happens in mediation should not be admissible in any other proceedings. And then there’s the confidentiality of what happens within the mediation itself to ensure what is disclosed by one participant in a private session is not repeated to another participant without prior consent. This can include questions relating to the need for confidentiality as between those who attend the mediation and those who do not, even if they are involved. As for mediators themselves, depending on which organisation they are affiliated to or the country they may be regulated by, confidentiality may vary, it being a professional obligation in most countries, but not everywhere. There can also be confusion in some high-profile cases between the desire for transparency regarding the final outcome, and the need for the confidentiality of the negotiations that led to that outcome. By belonging to the International Mediation Institute, for example, a mediator is automatically bound by a code of conduct that automatically entails strict confidentiality worldwide. Besides professional affiliations, in your opinion, what character traits does a good mediator possess? Inquisitiveness, curiosity and the ability to ask open-ended questions are important attributes for a good mediator, along with the ability to leave your ego at the door and truly listen with an open mind. There is also a social component: one of the most difficult things can be getting meaningful conversations going between people who haven’t spoken much or who greatly distrust or are angry with one-another, to help them get through the process together. This is particularly important if the disputants may need to continue working together in the future, or if they work in a close-knit ecosystem where they are likely to meet again. A mediator must also know when to follow and when to lead. A good mediator is analogous to a good bus driver: they need to make sure they know where the travellers are headed, that all the passengers are on board, and that everyone reaches their intended destination. And what methods do you use to create an environment of trust and collaboration? In a mediation, you want to come with open questions and have all of the participants feel equally seen and heard. You want to find out as much as you can about the needs, interests, concerns, and motivations of everybody involved. This is because, the more you understand their underlying goals, beyond the positions they may have taken, the more room there is for a solution. Exchanging information on such subjective factors often helps promote a sense of trust and collaboration. There’s an arsenal of tools you can use; the more you know when and how to use all the tools, the better off you are, adjusting to whatever is needed, which calls for flexibility. Is mediation almost a psychological exercise? Yes. I am not a psychologist, but for me, there are three different aspects to mediation that could be described as psychological. There’s a social component, an emotional component, and a rational component. The mediator has to build on all three of these aspects, which can require different psychological approaches. Mediation is not a form of therapy, however. We don’t try to change people or their behaviour. We try and help focus their attentions in situations of conflict on what truly matters now, what their alternatives are, and what options are available and most likely to better resolve the conflict more holistically, keeping an eye on the future. Is mediation suited to everyone? Are there any psychological barriers to overcome? It is rare that mediation is ill-suited to a dispute. It is an excellent complement to litigation and arbitration in almost all cases. There are all sorts of psychological barriers to mediation, however. First, people tend to think they are good negotiators, and if they could not reach a settlement, a mediator is unlikely to add any value. The statistics, however, are that over 70% of mediations (which almost always involve failed past negotiations) settle. Another of these is the fear of looking weak, the concern that: “If I say I want to mediate, it looks like I want to settle”. There can also be the belief that the other party will act in bad faith; or that mediation simply entails replacing one already-breached agreement with another. Mediated settlement agreements are rarely not complied with, however, and there is growing interest in being able to have them recognised and enforced internationally under the Singapore Convention or under the New York Convention. There may also be a general feeling of distrust of the mediation process from lawyers and judges who are not used to it, and a preference for more traditional procedures, but the reality is that most lawyers and judges agree that traditional access to justice on its own tends to take too long, be too expensive or destructive. Where does conciliation fit into the dispute resolution mix? How does it differ from mediation? Conciliation and mediation both involve negotiation facilitated by a neutral third party, yet they differ significantly in role, structure, impact, and focus. They are ‘first cousins’ rather than ‘siblings’,each suited to distinct contexts and objectives. Conciliation is typically a structured, evaluative process, often mandated by courts, particularly in civil-law jurisdictions, aimed primarily at financial settlements without ongoing relationships. The conciliator assesses legal merits, reality-tests positions, and frequently proposes settlements. This formal structure tends to activate competitive dynamics (‘out-of-group’ heuristics), prompting parties to position themselves strategically, anticipating and trying to influence the conciliator's recommendations. Conciliation usually yields lower settlement rates (50–60% in court-mandated settings). In contrast, mediation is facilitative, flexible, and less formal, emphasising dialogue and self-determination. Mediators typically refrain from proposing settlements, instead activating ‘in-group’ heuristics that encourage empathy, collaborative behaviour, and greater mutual understanding. Mediation effectively addresses emotional and relational elements, making it ideal for commercial, family, or complex cross-border disputes where ongoing relationships matter, often achieving higher settlement rates (70–90%). In summary, conciliation assesses positions and is mainly appropriate for resolving purely financial disputes without future relationship considerations, while mediation fosters collaboration, empathy, and durable agreements, particularly when relationships and subjective interests are important. When combined using two separate ADR neutrals, they provide almost 100% settlement rates. We understand that you have participated in research into the neuroscience of mediation. Can you tell us more about that? I am fortunate to have collaborated with a group of neuroscientists at the University of Geneva's Centre for Interdisciplinary Affective Sciences (CISA) to help them design and implement experiments related to neuroscience and mediation. Although the neuroscience of mediation is very much in its early days, the more we look at the human brain, we are discovering a whole new understanding of human behaviour, in particular social, emotional and rational heuristics, particularly in the context of conflict, negotiation and mediation. As an example: the results of experiments where couples with recurring conflicts were asked to negotiate with each other or with a mediator present showed measurable differences in social and brain behaviour. This demonstrated that mediation, compared to negotiation, leads to higher satisfaction rates, settlement rates, and a greater sense of inclusion. How can findings from neuroscience help mediators and the mediation process? This increased understanding definitely has the potential to change the dynamics of mediation. I believe that as we learn more from neuroscience, mediators should be made aware of the concepts of social, emotional and cognitive plasticity, to better understand and help parties to understand and manage their emotions, social behaviour and cognitive biases in situations of conflict. For mediators working today, understanding these systems and techniques may facilitate more skilful interventions, allowing what seemed impossible before to become possible now.

Dispute Resolution Best Practices: Insights from Recent ICC Trainings in the Netherlands Ulrich Kopetzki 3 Apr 2025 Emphasizing early assessment, tailored approaches, and proactive use of ICC support services, the sessions highlighted ICC arbitration’s flexibility, global reach, and practical tools to streamline and enhance cross-border dispute resolution. Ulrich Kopetzki ICC Dispute Resolution Services recently delivered a specialized training program across major Dutch companies and law firms. Ulrich Kopetzki, Acting Director for Europe and Central Asia, shared insights into advanced dispute resolution strategies over two intensive days of sessions. The program brought together over 40 experienced legal and business professionals interested in expanding their dispute resolution toolkit. Through collaborative workshops and discussions, we explored nuanced approaches to complex commercial disagreements and exchanged perspectives on optimizing dispute management processes. This initiative supports our ongoing dialogue with the Dutch business community and highlights the evolving landscape of international dispute resolution. Frequently Asked Questions How can we draft more effective dispute resolution clauses? Arbitration offers flexibility to tailor proceedings to your specific needs. Starting with the ICC model clause, consider key strategic choices like seat of arbitration, expedited procedures, confidentiality requirements, and multi-tiered dispute resolution steps. Sometimes leaving certain issues undetermined maintains valuable flexibility. These customizations create a dispute resolution process aligned with your business relationship and industry needs, potentially saving significant time and costs if a dispute arises. What are the advantages of ICC arbitration specifically? ICC arbitration stands out for its global reach (operating in 140+ countries and multiple languages), institutional neutrality, and exceptional quality control through the Court’s award scrutiny process. Its century of experience, client-centric case management, and innovative rules create a level playing field for parties worldwide. This combination makes ICC particularly valuable for complex cross-border disputes requiring efficient, predictable, and enforceable outcomes. How can parties make best use of the ICC Court and Secretariat in an arbitration? The ICC Court and Secretariat offer comprehensive support beyond what’s explicitly stated in the Rules. Some valuable ways to leverage the Court and Secretariat include: 1. Seeking arbitrator selection assistance - When parties need help identifying potential arbitrators, the Secretariat or ICC Court can provide lists of candidates, initiate communication with potential arbitrators about their availability, or establish a list procedure where parties rank their preferences. 2. Requesting specific arbitrator criteria - Parties can jointly agree on criteria they want the ICC Court to consider when appointing an arbitrator, such as nationality, language proficiency, or particular industry expertise. 3. Understanding ICC Court decisions - Any party can request that the Court communicate its reasoning for decisions on jurisdiction, consolidation, arbitrator challenges, or replacements, enhancing transparency in the process. 4. Using the Secretariat as an intermediary - The Secretariat can facilitate communication between parties and the tribunal, especially for sensitive issues like concerns about fees, delays, or case management challenges. 5. Utilizing escrow services - Beyond holding the advance on costs, the Secretariat can provide escrow services for VAT payments, expert fees, or security for costs. 6. Document handling and confidentiality - The Secretariat can serve as a neutral depository for confidential documents, including sealed settlement offers, and ensure they’re only released at appropriate times. 7. Getting logistical support - Leverage the ICC Case Connect platform for document sharing, get help with hearing arrangements through the ICC Hearing Centre, or obtain assistance with visa applications for participants. 8. Requesting advance notice of awards - Parties can arrange to receive alerts when an award notification is imminent, or request specific timing for award delivery. 9. Post-award assistance - The Secretariat continues to provide support after the award is issued, including certified copies of documents, notarization, and letters reminding parties of compliance obligations.

The new EU Customs Code 14 Apr 2026 The new EU Customs Code What business needs to know — a practical guide to the most ambitious EU customs reform since 1968 https://video.wixstatic.com/video/bd3753_c95a2909e63249fa9674a797a5c27d3d/480p/mp4/file.mp4 In late March 2026, the European Council and Parliament reached political agreement on a new Union Customs Code (UCC) — the most ambitious reform of EU customs since the Customs Union was established in 1968. The reform replaces a fragmented, paper-and-declaration-based system with a fully digital, data-driven one, centred on a single EU Customs Data Hub and a new EU Customs Authority based in Lille. This guide pulls together what is changing, when, and what it means in practice for any company that imports, exports, or moves goods across EU borders. It is based on the agreed legislative text and on public information from the Commission, Council and Parliament. Latest procedural update: the IMCO Committee of the European Parliament endorsed the provisional agreement on 16 April 2026 (38 in favour, 2 against, 3 abstentions). A plenary vote is expected by September 2026, with publication in the Official Journal targeted for October–November 2026. The Regulation will then enter into force approximately 12 months after publication. Changes at a glance Why this matters for business Customs is no longer only about collecting duties. It increasingly polices product compliance — safety, sustainability, sanctions, forced labour, deforestation, CBAM, digital product passports. At the same time, e-commerce volumes exploded from a few hundred million items a few years ago to 4.6 billion items in 2024 and around 5.8 billion in 2025 (DG TAXUD figures), making the current model unsustainable. This reform is the EU's response. Two consequences for any company that imports, exports, or moves goods across EU borders: Your customs data will be used far more intensively — for risk analysis, for non-customs regulatory compliance, and across the whole supply chain, not just at the border. How you organise customs operations will change. IT systems, contracts with carriers/brokers, internal data governance, and the choice of trusted-trader status all need to be revisited. Timeline — what to put in the diary Date Milestone What it means for business 1 July 2026 Interim €3 flat customs duty on low-value parcels; customs handling fee introduced for e-commerce Council agreed (12 Dec 2025) to levy a €3 duty on small parcels as a transitional measure pending the full UCC reform. A per-parcel handling fee applies to e-commerce consignments. Oct–Nov 2026 (expected) Formal adoption of the new UCC Regulation; publication in the Official Journal; EU Customs Authority (EUCA) legally established (based in Lille) Political agreement reached 26 March 2026; IMCO Committee endorsement 16 April 2026; plenary vote expected by September 2026. Once published in the OJ, EUCA starts setting up — it can hire, procure, and begin building the Data Hub. November 2026 Commission adopts delegated act on the handling fee amount Final clarity on the e-commerce handling fee amount. ~2027 New UCC enters into force (~12 months after OJ publication); delegated & implementing acts for the e-commerce Data Hub adopted (target March/July 2027) The detailed rules (data elements, processes) for e-commerce become final — companies can start IT build and testing. 2027 Old UCC progressively repealed; EUCA operational Transition period begins. E-commerce operators must start preparing for new obligations. 1 July 2028 EU Data Hub goes live for e-commerce; full €150 de minimis abolition; Trust & Check trader applications open E-commerce data flows centrally. The €150 duty-free threshold is fully abolished under the UCC. Platforms and importers can apply for Trust & Check status. 2031 Data Hub opens on a voluntary basis to all operators Companies may start using the Data Hub for any customs procedure. Delegated acts must be ready ~2 years before (around 2029). 1 March 2034 Data Hub mandatory; national customs IT systems switched off End-state: a single EU-wide customs data environment. All companies must be connected to the Data Hub by then. Note: Delegated and implementing acts (the detailed rules) are still being drafted. Business needs to engage now — once adopted they define what systems and data companies must build. The four pillars of the reform Pillar What changes Business impact 1. EU Customs Data Hub A single EU-wide digital platform replacing 111 national/EU systems. 'Submit data once' — same data reused across entry, import, transit, export. Consignment-centric (not declaration-centric). Potentially huge simplification: one interface instead of 27 national systems. But requires new IT investment, new data formats, and close attention to the delegated acts that define the data model. 2. EU Customs Authority (EUCA) New EU agency based in Lille (confirmed 25 March 2026). Starts with ~250 staff, scaling to ~500 long-term. Owns the Data Hub, runs centralised risk analysis, monitors AEO/Trust & Check. A single point of escalation for cross-border interpretation issues. Business can engage via the Advisory Board. Does NOT replace national customs — first contact remains local authorities. 3. Trust & Check trader (new) Goes beyond AEO. Requires giving customs real-time access to company data. In return: self-assessment, self-release, fewer controls. Highest simplification tier, but very high bar. AEO is retained for companies that can't/won't go that far. Concern: requirements may be too heavy for SMEs. 4. Liability & responsibility There is always an EU-established 'importer' (non-EU sellers must use an EU-established indirect representative). Each party is responsible for the data they own. More clarity on who is liable for what. Carriers become 'gatekeepers' — they must verify the importer has filed data before loading. Platforms get 'deemed importer' responsibility for e-commerce. E-commerce: the urgent file E-commerce gets its own regime and it starts first. Key changes: €150 de minimis abolished. A transitional €3 flat customs duty applies from 1 July 2026 (Council decision of 12 Dec 2025). The €150 duty-free threshold is fully abolished under the UCC reform when the e-commerce Data Hub goes live on 1 July 2028. Normal duties apply thereafter. Customs handling fee. A per-parcel fee is introduced (amount set by November 2026 delegated act). Platforms become importers. Marketplaces that sell to EU consumers become responsible for customs compliance of the goods they sell — including data, duty and VAT. No simplified treatment for the platforms themselves. The co-legislators explicitly refused to grant extra facilitation to e-commerce flows. T rust & Check available for e-commerce operators. Major e-commerce players can apply from July 2028 and benefit from a reduced handling fee. Strategic implication: the reform is expected to level the playing field between traditional retail and cross-border e-commerce platforms. Some Chinese platforms have already anticipated — Shein alone has 740,000 m² of warehousing in Poland. Expect internal EU competition for e-commerce distribution hubs (Poland, Netherlands, Belgium). Operational impact — what changes day-to-day Data: from declarations to continuous data sharing Today, you file a set of declarations (entry, import, transit, export). Tomorrow, you push data about the consignment into a shared hub and customs "consume" the events in the goods' life cycle. The same data should only be submitted once. Data quality becomes critical — poor data means controls and delays. The Commission is asking companies to start improving data quality now, in existing systems. 'Submit once' only works if companies adopt unique identifiers that track a consignment across its whole journey. This is one of the biggest practical challenges. Carriers will become 'gatekeepers': they must check the importer has filed the data before loading. Expect new contractual and operational arrangements with carriers and brokers. IT and systems Companies will need to interface with the EU Data Hub (directly or via brokers/software). Member State national systems will coexist until 2034 but progressively disappear. Short timelines are a real risk. Industry has flagged that testing phases must be foreseen — ICS2 has had documented service interruptions and readiness concerns. A dedicated test environment is expected. Data sovereignty is a priority: the Commission is assessing sovereign EU cloud vendors for hosting. Customs representatives / brokers Role shifts from filing declarations to data management and compliance advisory. An EU-established customs representative is required when the importer is non-EU. Brokers with strong data capability can consolidate operations — no need for a legal presence in each Member State. VAT, excise and other legislation Centralised clearance for imports is introduced — but NOT for VAT. Industry has flagged this as a missed opportunity; misalignment with VAT remains a source of fragmentation. Penalties are only partially harmonised (minimum common core of infringements and non-criminal sanctions); Member State national sanctions are retained. Trust & Check vs. AEO — what to choose Good news: AEO is retained. It was a real concern that AEO would disappear; business pushed back and won. But Trust & Check is the new top tier: Entry requirements: Full AEO-equivalent plus real-time access to your customs-relevant data by authorities. Practically a major IT and governance project. Benefits: Self-assessment (file periodically, not per transaction), self-release (release goods without prior customs intervention), reduced handling fee in e-commerce, priority treatment. Open question: Will the benefits justify the investment? Industry worries the balance between simplification and controls still isn't right — and that SMEs will struggle to qualify. SME angle: Brokers are expected to step in, providing Trust & Check status to their SME clients as a service. Recommendation: If your company already holds AEO-F, start mapping the Trust & Check delta now and decide whether to aim for it. Applications open July 2028. Risks for business Short and unclear timelines. Delegated and implementing acts are still in drafting; businesses are being asked to build IT for rules that aren't final. Data explosion. Despite the 'submit once' promise, each new EU regulation adds data requirements. Without active pushback, the Data Hub could become another reporting burden on top of CBAM, CSRD, deforestation etc. Integration with national systems. During the 2026–2034 transition, companies will deal with the Data Hub AND national systems in parallel. Risk of double-filing if not well designed. Uneven enforcement. The final text introduces a minimum common core of sanctions, but Member States can still add national sanctions. Interpretation differences will persist. EU competition. More uniform rules could accelerate a shift of distribution flows towards lower-cost Member States. System resilience. ICS2 has had documented service interruptions at today's volumes. With ~18 million daily e-commerce declarations projected, business continuity is a real concern. Opportunities for business Single EU interface. A real chance to cut IT and compliance cost if delivered well — one connection instead of 27. Self-assessment. For compliant traders, the end of transaction-by-transaction filing can free significant resources. Predictability through data. Real-time visibility of consignment status, earlier notification of controls — fewer delays at the border. Level playing field on e-commerce. Traditional retailers and EU manufacturers benefit from tighter controls on cross-border platforms. Sustainability link. The Data Hub can connect to the Digital Product Passport, opening room for differentiated tariffs (e.g., refurbished vs new) and simpler compliance for green products. Shape the rules. The Commission is actively calling for business input on delegated acts, data elements and the Data Hub design. Early movers influence the detail. What business should do in the next 12 months Map exposure: which flows, which Member States, which product categories are most affected (especially e-commerce, low-value consignments, non-EU sellers). Start cleaning customs data quality in existing systems — the Commission has explicitly asked for this, and it will ease the Data Hub transition. Assess Trust & Check readiness vs. AEO: what would real-time data access require on your side? Run a gap analysis. Review contracts with carriers, customs representatives and platforms in light of the new 'gatekeeper' and importer-responsibility concepts. Engage: through industry chambers, federations, national trade facilitation committees, or directly with your national customs authority. The delegated acts for e-commerce will be published in draft in the coming weeks. Budget: plan IT investment for 2026–2028 covering data model changes, interfaces with the Data Hub, and potentially a Trust & Check programme. Bottom line The reform is ambitious and broadly supported: Council and Parliament reached political agreement on 26 March 2026 on what both institutions are calling the most significant customs reform in decades. But success depends on the detail — delegated acts, Data Hub design, EUCA governance. For business, now is the moment to build internal awareness, engage with the Commission on the secondary rules, and start the IT/data homework. 1 July 2028 is closer than it looks. Sources & further reading European Commission DG TAXUD — EU Customs Reform European Commission press release IP/26/735 on the political agreement (26 March 2026) Council of the EU press release — "EU customs: Council and Parliament agree on landmark reform" (26 March 2026) Council press release on interim €3 duty on small parcels from 1 July 2026 (12 December 2025) Council press release on selection of Lille to host the EU Customs Authority (25 March 2026) DG TAXUD — "Goods bought online" statistics (for e-commerce volumes) Note: the legislative text was politically agreed on 26 March 2026 and endorsed by the IMCO Committee on 16 April 2026, but had not yet been formally adopted in plenary or published in the Official Journal at the time of writing (May 2026). Some details may evolve during legal-linguistic finalisation and in the delegated and implementing acts.

Trading Blows or Building Bridges? Navigating Global Trade in a Multipolar World 20 May 2025 On May 20, ICC Netherlands brought together members, partners, and experts for its 2025 General Assembly and a high-level discussion on the future of trade in an increasingly fragmented world. Hosted by Rabobank in Utrecht, the event gathered perspectives from leading voices across business, government, finance, and international institutions, reflecting the urgency, complexity, and strategic opportunities facing global trade today. Setting the Stage: From Strategic Priorities to Strategic Action The afternoon opened with the ICC Netherlands General Assembly, where Director Laure Jacquier presented the organisation's achievements in 2024 and outlined strategic priorities for the years ahead. Key themes included digitalisation, sustainability, dispute resolution, and business integrity. Importantly, the General Assembly also marked the formal welcome of three new board members: Shashank Jhawar (ING), Marhijn Visser (VNO-NCW), and Rogier Schellaars (Van Doorne). Their addition reflects ICC's commitment to broad-based expertise and diverse sectoral representation. Following the formal session, attention turned to the broader landscape of international trade through two expert panel discussions moderated by Jasper van Schaik, ICC Board member and an Agricultural Program Expert, with Rabobank Partnerships. The core question at the heart of the event: Are we trading blows in a fractured world—or still intend on building bridges? Panel 1: Global Trade in Transition The first panel, "Global Trade in Transition," offered a macroeconomic view of the shifts redefining trade. Otto Raspe, Chief Economist at Rabobank, opened the session by posing a critical question: “Are we resilient enough?” Drawing from 8 trade war scenarios, Raspe emphasised a fundamental shift from prioritising growth to ensuring risk resilience, particularly in the face of increasing protectionism and geopolitical tensions. Daan Vriens, CEO of Cefetra Group, illustrated how these dynamics are already affecting agri-trade. Using soy as a case study, he highlighted how sourcing decisions are being reshaped by geopolitics. “Every trade has its own dynamics—especially in agriculture,” he noted, urging companies to proactively reassess their supply chains, especially SMEs. Andrew Wilson, Deputy Secretary General for Policy at ICC Global, delivered a powerful reminder that many of the rules underpinning today’s global trade regime were written in the mid-20th century. “Most of the rules we still rely on were written in the 1950s,” he said, referring to the outdated nature of WTO regulations and the growing disconnect between markets and the real economy. Wilson warned of systemic risks and stressed the urgency of reforming multilateral frameworks, a key agenda item of ICC. Energy markets added another layer to the discussion. Coby van der Linde, Senior Fellow at CIEP, challenged prevailing optimism around energy transitions. “Europe thinks it’s already in 2050,” she remarked, cautioning against overreliance on LNG and the need for cost competitiveness in alternative energy sources. Dirk Klaassen of the Dutch Ministry of Foreign Affairs added a pragmatic policy view, noting that the Dutch and EU approach remains rooted in dialogue and negotiated solutions. “Let’s keep talking—that’s still our strength,” he concluded. Panel 2: Navigating Complexity: A Business View If the first panel focused on systemic shifts, the second panel—"Navigating Complexity"—zoomed in on the day-to-day realities facing businesses operating in this uncertain landscape. Rico Luman, Senior Economist at ING, dubbed 2024 “the year of uncertainty for supply chains,” referencing geopolitical flashpoints and a likely uptick in tariffs. He called on businesses to prepare for a prolonged period of disruption and to invest in resilience. Esther Berkelaar, Head of Trade & Commodity Finance at Rabobank, echoed this concern, describing the current moment as “a bit paralysed.” With fewer trades being recorded and shifting market dynamics, she stressed the importance of scenario planning and legal clarity in cross-border transactions. Rogier Schellaars, Partner at Van Doorne, offered a legal perspective on governance challenges. He warned that many boardrooms still lack a realistic view of today’s trade risks, saying, “Realism is not what I always see in the Dutch boardroom.” He stressed the importance of aligning contracts with new realities. Marhijn Visser of VNO-NCW concluded the session with a strategic policy lens. Representing over 90% of Dutch businesses, he called for stronger internal alignment between public affairs and executive leadership. His standout message: "Every company should be asking: how does geopolitics affect our business?", taking geopolitics into consideration in your strategy is good business while mayny corporate see this as a cost post. He even suggested appointing a "Chief Geopolitical Officer" to ensure this question is no longer overlooked. A Shared Sense of Urgency Across both panels, one theme resonated clearly: we are entering a new era of trade. One where adaptability, geopolitical awareness, and collaboration are no longer optional, but essential. Whether facing outdated regulatory frameworks or navigating supply chain disruption, companies and institutions must think ahead, act together, and communicate across borders. The event closed with informal networking, but the conversations are set to continue—at upcoming ICC Netherlands working groups, international forums, and future events aimed at turning insights into impact. As one participant aptly summarised: "The system may be strained, but it's not broken. There is still time to build the bridges we need." ICC Netherlands would like to thank Rabobank for hosting the event and all speakers, participants, and partners for contributing to an insightful afternoon of dialogue and action. Read more about ICC Netherlands here

European Commission Withdraws Green Claims Directive — ICC Welcomes Opportunity for Constructive Recalibration 30 Jun 2025 After months of uncertainty, the European Commission has formally withdrawn the Green Claims Directive. ICC invites members to shape the next phase of environmental marketing policy. Brussels, June 2025 – In a significant development for sustainability regulation and business communication, the European Commission has announced the withdrawal of its proposal for a Green Claims Directive. The decision, shared during the Commission’s midday press briefing, comes amid growing concern over the administrative burden the legislation would have imposed—particularly on Europe’s 30 million micro-enterprises. The Directive, originally introduced in 2023, aimed to tackle greenwashing by requiring businesses to substantiate environmental claims—such as “climate neutral” or “100% recycled”—through detailed criteria and mandatory third-party verification. While widely supported in principle, the approach raised major concerns across the business community for its potential to hinder innovation, create disproportionate compliance costs, and undermine existing good practices. A milestone for business engagement ICC has consistently supported the goal of credible, science-based sustainability communication, while also advocating for a more balanced, proportionate approach. As ICC noted in its response to the proposal, mandatory ex-ante verification risked penalising responsible companies and disincentivising voluntary leadership, particularly among SMEs. Thanks to continued feedback and coordinated outreach from ICC members across Europe, these concerns were heard. Today’s withdrawal marks a milestone in collaborative advocacy—and opens the door for a more workable path forward. What comes next? While the Commission has withdrawn the Green Claims Directive, existing EU consumer protection legislation remains in place: · The Unfair Commercial Practices Directive (UCPD) already prohibits misleading environmental claims and will remain a key enforcement tool. · The Empowering Consumers for the Green Transition Directive, adopted earlier this year, will also enter into force in 2026 with new requirements around environmental marketing. These frameworks continue to provide a baseline for action against greenwashing, and ICC will work to support their consistent and practical implementation. More importantly, this moment provides an opportunity to co-design better solutions. As the Commission considers future steps, ICC encourages a renewed focus on: Supporting self-regulatory mechanisms , such as the ICC Marketing Code and Environmental Claims Checklist Promoting clear, scalable guidance that builds trust without excessive red tape Ensuring that frameworks are workable for all business sizes , especially SMEs ICC’s call to members This is not just a regulatory win—it’s a call to action. ICC is inviting members to help shape the next phase of policy by sharing real-world examples, common challenges, and practical alternatives. Constructive engagement now can ensure the next iteration of EU policy supports credible sustainability claims—while enabling business innovation and competitiveness. Once again, ICC thanks its network for the active engagement that helped deliver this outcome. The work ahead is equally important—and we look forward to continuing the conversation with you. 📄 Read ICC’s response to the Green Claims Directive

CBAM enters a definitive phase: what businesses need to know Nina Wildemast 25 Feb 2026 CBAM enters a definitive phase: what businesses need to know As of 1 January 2026, the EU Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase. After two years of transitional reporting, the system is now moving to a stage in which financial consequences will occur over time for importers of CBAM-covered goods. During the transitional period, companies were mainly required to report the embedded emissions of certain imported products. From 2026 onwards, CBAM shifts from simply reporting to a financial mechanism. Importers will ultimately need to purchase and turn in CBAM certificates that correspond to the embedded emissions of their goods. The price of these certificates is linked to the EU Emissions Trading System. CBAM currently applies to iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. In the first week of the definitive phase, more than 10,000 customs declarations containing CBAM goods were recorded, with iron and steel accounting for the majority. This means that CBAM is no longer theoretical. It is operational and already affecting trade flows. In mid-December, the European Commission published a large package of implementing rules to make the system operational. These rules cover verification, the CBAM Registry, authorised declarant status, default values and the calculation of embedded emissions. This provides more clarity, but it also adds significant technical detail for companies to consider. A key requirement is about Authorised CBAM Declarant status. From March 2026 onwards, importers above the applicable threshold must hold this status in order to import CBAM goods into the EU. Obtaining the authorisation is not simply a formality. It requires companies to demonstrate compliance capacity and financial guarantees in certain cases. For businesses that rely on indirect customs representatives, liability allocation and contractual arrangements may require careful review. The calculation of embedded emissions is essential for the mechanism. Companies can use actual emissions data from producers or rely on default values given by the Commission. However, default values are set up to become increasingly strict over time. In 2026, default values will already include a mark-up, and this will increase in the following years. As a result, relying on default values can significantly raise carbon costs compared to using verified actual data. At the same time, the use of actual emissions requires verification by a verifier accredited by the EU. This may cause practical problems, especially in the first year of implementation. The full list of accredited verifiers is expected later in 2026, which raises questions about verification capacity and the timing. Companies will need to carefully assess the readiness of their data and verification planning in order to avoid last minute issues. CBAM certificates work as digital tools that represent one tonne of embedded CO2. Their price will reflect the average EU ETS price. In 2026, pricing will be based on quarterly averages, while from 2027 onwards the prices will be published every week. The first annual CBAM declaration and receiving the certificates will be due by 30 September 2027. From 2027, authorised declarants will also be required to hold a minimum number of certificates during the year. This introduces additional cash flow considerations. The Commission is already considering whether CBAM should be extended to additional downstream products. If that happens, more types of goods could fall under the system in the coming years. At the same time, further clarification is still expected on how carbon prices that have already been paid in the country of production will be taken into account when calculating CBAM costs. For companies involved in international trade, CBAM is therefore not just another environmental rule. It changes how imports are handled in practice. It has an impact on purchasing decisions, supplier relationships, data collection and financial planning. Having reliable emissions data, clear insight into supply chains and early coordination with producers outside the EU will be increasingly important. Businesses should evaluate whether their current systems allow them to accurately track embedded emissions, whether agreements with suppliers clearly define responsibilities for data and verification, and how possible carbon costs can affect pricing and competitiveness. In sectors such as iron and steel in particular, the impact could be significant. CBAM aims to link climate policy more closely with trade. The system will continue to develop, and further changes can be expected. ICC will continue to follow these developments closely, engage with members and contribute to discussions on practical implementation. It remains important that the mechanism is workable, predictable and proportionate for internationally active businesses. What Remains Uncertain Several elements are still evolving: Final rules on carbon price paid outside the EU. Potential extension to downstream products. Practical experience with verifier capacity. Development of parallel CBAM regimes in other jurisdictions. For internationally active firms, multiple border carbon systems could emerge rather than convergence toward a single framework. That possibility should be considered in medium-term compliance planning. Practical Priorities for 2026 Confirm authorised declarant status and review contractual allocation of liability. Quantify financial exposure under both default and verified emissions scenarios. Strengthen supply chain data protocols , particularly for precursor products. Integrate CBAM into financial planning , rather than treating it as a reporting obligation. Early alignment reduces the risk of customs disruption and unexpected certificate costs.

Updated Global Framework for Responsible Environmental Marketing Communications 7 Nov 2025 ICC has published 2025 ICC Framework for Responsible Environmental Marketing Communications a global reference designed to ensure environmental claims are truthful, clear and properly substantiated. Now in its fifth revision since its introduction in 2009, the framework aims to help brands communicate sustainability with integrity at a time when environmental messaging has become central to marketing strategies. Alongside the Framework, the Checklist is a practical tool for users in applying the principles. The updated framework aligns with the revised 2024 ICC Advertising and Marketing Communication Code and includes expanded guidance on emerging claim areas such as climate-related assertions (including “net zero” and “carbon neutral”), circularity, “free-of” claims, recyclability, degradability, compostability, reuse, recycled content, ESG and extended producer responsibility. While avoiding the creation of new definitions for environmental terminology, the ICC emphasises that marketers must follow local regulations and support all claims with reliable scientific evidence. The framework cautions against vague or exaggerated statements that could mislead consumers, undermine trust or invite regulatory scrutiny. Applicable across the entire marketing ecosystem, from global brands and agencies to small businesses and influencers, the framework is media-neutral and relevant to traditional, digital and emerging formats. It includes practical tools such as a glossary of key terms, an environmental claims checklist, and a comparative chart linking ICC Code principles to environmental guidance. The release comes amid heightened concern over mis- and disinformation and increased regulatory attention to greenwashing, reinforcing the ICC’s role in setting internationally recognised standards for responsible environmental communication. 2025_ICC-Environmental-Framework .pdf Download PDF • 2.44MB

ICC Report: Unlocking Private Sector Investment for Climate Adaptation 28 Aug 2025 ICC Report: Unlocking Private Sector Investment for Climate Adaptation Climate change is no longer a distant risk — it is already reshaping economies and societies worldwide. Extreme weather events caused over US$2 trillion in economic losses between 2014 and 2023 , directly affecting 1.6 billion people. Damages are escalating rapidly, with US$451 billion in losses recorded in just 2022–2023 . Despite this urgent need, adaptation finance lags far behind mitigation . In 2022, global mitigation finance reached US$1.3 trillion, while adaptation attracted only US$76 billion — and just 8% came from the private sector . Developing countries are particularly vulnerable: small island and least developed states paid over twice as much in debt service (US$59bn) as they received in climate finance (US$28bn). To address this gap, the International Chamber of Commerce (ICC) commissioned Oxera to analyse how the private sector’s role in climate adaptation can be scaled up. The report highlights that public finance alone cannot meet the scale of the challenge . Unlocking private capital is essential to drive the innovation and investment needed to build resilience at speed and scale. Key recommendations The report sets out three strategic priorities for governments, regulators and financial institutions: Strengthen climate risk information and transparency Improve access to high-quality, open climate risk data. Mandate proportionate disclosure of physical climate risks across operations and supply chains. Standardise adaptation metrics and taxonomies to make resilience measurable and investable. Establish enabling institutions and regulatory incentives Embed business participation in National Adaptation Plans. Create sandboxes and procurement frameworks that reward climate resilience. Adjust capital requirements to reflect the benefits of resilient investments. Scale adaptation finance with innovative instruments Expand blended finance, resilience bonds and insurance-linked products. Develop adaptation bonds tied to avoided losses or service delivery outcomes. Leverage insurers’ data and expertise to guide investment and maintain coverage in high-risk areas. ICC at COP30 As the official voice of business in the UN climate negotiations (UNFCCC) , ICC will use this report to advocate for a stronger role of the private sector in climate adaptation at COP30 in Belém, Brazil . With adaptation expected to be a central theme of the talks, ICC’s recommendations aim to shape an actionable policy agenda that enables businesses to be true partners in building global climate resilience. Read the full report 2025-ICC-Oxera-The-role-of-the-private-sector-in-climate-adaptation-Full-report .pdf Download PDF • 3.33MB Read the summary 2025-ICC-Oxera-The-role-of-the-private-sector-in-climate-adaptation-Report-summary .pdf Download PDF • 163KB

The world order is changing from a ‘rules-based’ to a more ‘power-based’ setup 1 Mar 2025 The previous two issues of our newsletter have looked closer at the current geopolitical situation: the challenges and solutions thereof. These have covered the subject from the perspective of the trans-Atlantic thinktank German Marshall Fund (Dr. Alexandra de Hoop Scheffer) and ICC Global (Deputy Secretary General for Policy Andrew Wilson). Now it’s time to hear from one of the largest business associations in the Netherlands – evofenedex – which represents its 10,000+ members active in supply chain logistics and/or international trade. Evofenedex Managing Director Bart Jan Koopman answers some of our most pressing questions covering risks, opportunities and how to build resilience. What is your take on the increasing international trade tensions that we have seen in the media so much over the previous couple of months? For a long time, international trade has been managed and regulated by international institutions implementing a variety of rules and agreements. However, a large number of countries and groups of countries are stepping out of this way of working. So instead of the world becoming more globalised, we are seeing more and more fragmentation. However, this goes back longer than the recent developments we are seeing in the media at the moment; this has been happening for a number of years. As for the timing of the coverage, it’s important to note that this is not a story that is driven by Trump. For example, the WTO started becoming a lame duck organisation in the Obama years. However, the situation has been worsened by Trump. To understand the underlying mechanisms as to why this is happening, we need to look at the fact that the world order is changing from a ‘rules-based’ to a more ‘power-based’ setup. And how does this affect international businesses? This has a significant impact on the business community with substantial economic and trade consequences. It is very challenging for companies to make decisions in this fragmented world with different rules and standards. Experience has taught us that protectionism comes with more rules and regulations and makes it harder to be compliant. And at the same time another reality is true. If things were complex with regulations, then without them, it is even more complex. You also now have to take all these geopolitical developments into account! Let’s talk about risks and opportunities. How should companies tackle the seemingly constant stream of risks? If you are in business, there have always been risks and there will always be risks: the Suez Canal blockage, the Middle East situation, and the coronavirus pandemic are all relevant examples. When looking at how to deal with such uncertainty – this unpredictability – if you only look at situations from a risk perspective, then you often don’t get a chance to see the opportunities. So rather than only looking at – and reacting to – the risks, companies need to act more strategically. This is the challenge of moving from a risk-based to a more resilient way of working. How can companies build resilience? Reconfiguration of supply chains is a good example. A large company working in the semiconductor sector, for instance, knows that the USA will have big problems with companies delivering certain chips to China but also chips made in China and shipped to the US will be a problem. In this case, reconfiguring the supply chain to relocate this part production outside China – to Malaysia or Vietnam – could be a solution. Another option rethinks the ‘just in time’ supply chain method. Companies can build resilience by increasing the number of their suppliers; having three or four instead of one or two. This would involve different supply chains operating in parallel, possibly at different production sites. Of course, this is more expensive, but it is more resilient. Other examples could be to set up production in the USA, or to focus more on internal European markets. Reconfiguration of supply chains can offer new possibilities for every company in every sector. Last but not least, cooperation in the value chain and supply chain helps to build resilience as well. What is the role of organisations like ICC and evofenedex? Companies need to concentrate on their business rather than sitting around analysing trends. On the other hand, they need to stay up-to-date with both the short and long-term trends so that they don’t make decisions that they could regret later. This is where organisations like ICC and evofenedex can help companies find their way through the complexity. At evofenedex, the trio of actions that we like to offer our members is ‘interpret, learn and influence’. This is not only useful for small and medium-sized companies, but large ones too. Look at the complexity that everyone is operating in: regulations are only increasing, but at the same time we are living in a world where regulations are getting less and less important. This is a challenge but also an opportunity. And how does this translate to practical help to members? Externally, we work with organisations such as the ICC on the ‘big picture’ issues; promoting the push towards increased digitalisation of trade procedures, and during the Week of Integrity, for instance. And then internally, we look at long-term trends and themes affecting our members, and try to give advice and increase members’ knowledge level on those subjects. Significant trends at the moment include compliance, working with trade restrictions, and sustainability. Rather than one-on-one transactions, we bring our members together in what we call communities to share experiences and knowledge with each other. Despite all of this do not forget international business is still very much alive and needed and I am convinced that together we can do business also in these turbulent times!