Call for Evidence: Trade Council Agenda Item TR‑001

1. Purpose of this call

1.The Trade Council invites small-business owners to share evidence about the practical effects of trade rules, tariffs and related costs on small traders. The Council is beginning an inquiry, not announcing a conclusion. It wants to understand what happens when a small business buys, imports or moves goods across a border, what information or support it receives, and where a rule or service arrangement creates a recurring difficulty.

2.The inquiry is called TR-001. It is part of Reseated’s work to describe common business practices and assess whether a problem is sufficiently widespread and consistent to justify a proposed response. We are asking for first-hand accounts, documents where available, and careful descriptions of the circumstances. Reports can describe a difficulty, a workable practice, or a case in which a process was clear and proportionate.

3.The Council does not assume that every trade requirement is unfair, that every cost can be removed, or that one process will suit every country and product. Trade rules may serve public purposes and may differ by jurisdiction, product, route and transaction. The inquiry asks how those rules are experienced by small traders and whether practical improvements—such as clearer information, appropriate size thresholds, workable transition arrangements or more transparent cost estimates—could reduce avoidable burdens without weakening legitimate objectives.

4.This is a call for evidence, not legal advice, a complaint service, a customs determination or a promise that Reseated can change a law or commercial decision. Do not rely on this note to decide what duties, declarations, permits or other obligations apply to a particular shipment. For advice about a real transaction, consult

an appropriately qualified adviser or the relevant authority in the jurisdiction concerned.

2. Why the Council is examining this subject

5.Small firms often have fewer staff and less specialist capacity than larger traders to interpret changing requirements, obtain professional help, compare service offers or absorb an unexpected charge. The Council wants to test these practical observations against reports rather than treat them as established findings. It is especially interested in the difference between a rule that is understandable in principle and the steps, timing and information needed to comply with it in practice.

6.The wider importance of small and medium-sized enterprises is recognised internationally. The United Nations describes MSMEs as approximately 90 per cent of businesses, 60–70 per cent of employment and about 50 per cent of GDP worldwide.¹ The International Labour Organization estimates that MSMEs account for about 70 per cent of employment worldwide and that roughly 80 per cent operate in the informal economy.² These global estimates provide context; they do not establish how many small businesses trade internationally or how often any particular trade problem occurs.

7.Reseated is a global assembly of small-business owners, organised in seven councils. On 10 February 2026, the Assembly has 20 members in 18 countries and has received five reports from five countries: four concerning the Platform Council and one concerning Cashflow. The Trade Council has three members from three countries and has not yet received a Trade Council report. These are the figures available on the date of this note. A zero in the Trade Council column means that no report has been filed there; it does not show that a problem exists or does not exist.

8.The first task is therefore to learn from owners in different settings. A report from a small number of people can alert the Council to a question, but it cannot by itself establish prevalence. Conversely, the absence of reports at the start of an inquiry is not evidence that a difficulty is absent. The Council will seek a range of experiences,

including different countries, business sizes, products, routes, business models and outcomes.

3. Scope of the inquiry

9.For this call, a small trader is an owner or operator of a small business that buys, sells, imports, exports or arranges the movement of goods across a border, or that is materially affected by another party’s cross-border goods process. You do not need to use a particular legal definition of “small business” to take part. Please describe your business in broad terms and explain why you consider it small in the setting where you operate. Do not name your business.

10.Reports may concern the practical effects of tariffs or other trade-related charges; customs or product requirements; the clarity and timing of official or commercial information; administrative steps; changes to rules or rates; the ability to plan or budget; and the cost information supplied by a freight forwarder, broker or other intermediary. Reports may also address the information available before a transaction, the difference between an estimate and a final charge, or the handling of a change, delay or correction.

11.The Council is particularly interested in the relationship between the scale of a business or shipment and the process it must navigate. Tell us if a requirement appears to have a fixed cost, a minimum volume, a recurring administrative task, a short transition period or a specialist-information burden that affects a small trader differently from a larger one. The Council is not presuming that a size-based exemption is appropriate in any specific case. It is asking what the actual effect is, what alternatives have been tried and what safeguards or distinctions might matter.

12.A report may also describe a helpful arrangement: a plain-language guide, advance notice, a reliable landed-cost estimate, a clear explanation of what is included or excluded, a reasonable time to adapt, or a proportionate process. Evidence of what works can be as useful as evidence of what fails. Please identify the circumstances in which the practice worked and whether it was available consistently.

13.This call is limited to the experience of small traders and the practical operation of trade-related rules and services. It is not a general inquiry into all international commerce, competition, labour conditions, environmental policy, taxation or consumer protection. Those matters may intersect with a report, but please explain the connection to the trader’s experience rather than assume that the Council will investigate every related issue.

14.The Council does not seek confidential commercial strategies, personal data about customers or employees, or information that you are not entitled to share. Do not submit another person’s private information or confidential material belonging to a third party unless you have permission and it is necessary for the report. You may summarise the relevant facts instead.

4. Legal comparison in the dossier

15.The legal comparison on record is deliberately narrow. The dossier identifies a European Union Carbon Border Adjustment Mechanism simplification: a 50-tonne annual mass threshold from 1 January 2026, described as removing approximately 90 per cent of importers, mostly SMEs, while retaining approximately 99 per cent of emissions within scope.³ The case shows one way a rule may distinguish by an annual quantity threshold. It is included as a reference point for discussion, not as a recommendation that the same threshold, design or result should apply to other rules, goods or jurisdictions.

16.The figures in the comparison are those stated in the cited European Parliament material. The Council is not independently assessing their methodology in this call. They do not establish that the same design would be suitable for tariffs, customs administration, freight services or other trade rules. Please do not treat the case as a statement about your own legal obligations.

17.No broader survey of national trade laws is presented here. The Council will not infer that two countries have equivalent rules merely because their processes use similar terms. If you describe a law or official requirement, identify the country or jurisdiction, the date or period when it applied, and the source you relied on, if known. A link or document reference is helpful but not required. If you are unsure whether something is law, guidance, a contract term or a service provider’s policy, say so.

5. Questions for business owners

18.You may answer only the questions relevant to your experience. A short, specific account is valuable. If a question does not apply, leave it blank. Please distinguish what you personally experienced from what you heard from another person, inferred from a document or believe may happen in the future.

1. What kind of goods or trade activity is involved? Describe the goods in general terms. Do not identify your business, customer, supplier or a shipment in a way that would expose a person or a confidential commercial relationship.

2. In which country or countries did the relevant step take place, and when did it happen? If the process crossed jurisdictions, identify the points at which the relevant information, charge or delay arose.

3. What rule, charge, form, deadline, threshold, information requirement or service process was involved? If you do not know its formal name, explain what you were told or what you encountered.

4. What did you need to do, and what information did you have at the time? Explain whether the requirement was clear before you committed to the transaction, and whether the information came from an authority, a professional adviser, a supplier or another service provider.

5. What was the practical effect on the business? For instance, did it change the expected cost, time, paperwork, staffing, cash requirement, price, route or decision to proceed? Give an approximate amount or interval only if you can do so safely and accurately.

6. Was the effect one-time or repeated? If it happened more than once, how many instances can you recall, over what period, and were the circumstances materially similar?

7. Did other traders in a comparable position appear to experience the same issue? Explain how you know. Do not present a general impression as a verified count.

8. Did the issue occur in other products, routes, locations or stages of the process? Identify the similarities and differences rather than assuming that a single case applies everywhere.

9. What documents or other evidence support your account? You may describe them without attaching them. If you attach material, remove unnecessary personal, account, address, tracking and commercial identifiers.

10. Was there an explanation, correction, appeal, alternative service or other remedy? What happened, and how much time or effort did it require?

11. Did you find a process that worked better? What made it clearer, more predictable or more proportionate, and under what conditions would it remain workable?

12. If you could change one practical feature while preserving the legitimate purpose of the rule or process, what would you change? What risks or unintended effects should the Council consider?

19.There is no expectation that owners provide a legal analysis or calculate a precise economic loss. Please label estimates as estimates and say how you arrived at them. If a figure is approximate, use a range or describe the order of magnitude. If you cannot safely share a number, explain the type of effect without it.

6. What counts as evidence

20.Evidence includes a first-hand account that gives enough detail for the Council to understand the event and assess its relevance. Supporting material can strengthen an account, but it is not required. Cases include a redacted notice, form, invoice, tariff or fee schedule, written estimate, change notification, public guidance, correspondence, or a record of time spent. Evidence may also include a contemporaneous note made by the owner. Submit only material you may lawfully and safely share.

21.A useful report generally identifies the sequence: what the owner was doing, what requirement or service step arose, what information was available, what action followed, and what result occurred. Where the report concerns a repeated problem, explain how often it occurred and what makes the instances comparable. Where a document is supplied, explain which part matters. A file without context may be difficult to interpret.

22.Reports need not be dramatic or prove wrongdoing. A modest but repeated administrative burden may be relevant; so may a large single event that reveals an important process. Conversely, a large amount at stake does not by itself prove that a pattern exists. The Council will assess the quality, relevance and limits of each report rather than rank owners by the value of their losses.

23.Anonymous accounts and accounts based on hearsay may help the Council identify questions, but the Council will distinguish them from reports that can be checked or corroborated. If you are reporting something you did not experience directly, state that clearly, describe the basis of your knowledge and avoid identifying the person who told you unless they have agreed.

24.Do not alter a document in a way that changes its meaning. Redaction of identifying or confidential details is encouraged; if redactions remove context needed to understand the evidence, explain what was removed. The Secretariat may ask a follow-up question through the channel you used. You may decline to answer, and the report will be assessed on what is available.

7. How reports contribute to the five-part pattern test

25.The Council uses a five-part pattern test: Volume, Frequency, Consistency, Spread and Corroboration. The test is a disciplined way to ask whether reports point to a recurring practice or problem, rather than relying on a vivid isolated account or an unsupported generalisation. Passing or failing the test is not a judgment about the honesty, importance or worth of any individual owner’s experience.

1. Volume asks how many relevant reports describe the issue. Counts will be interpreted in context. The Council will consider how many businesses had an opportunity to report, how many countries and types of trade are represented, and whether a cluster of reports comes from one source or event. There is no fixed minimum in this notice.

2. Frequency asks how often the issue occurs for affected businesses and over what period. A report should distinguish a single occurrence from repeated events where possible. Frequency is not simply the number of submissions: several owners may describe one incident, while one owner may describe many separate instances.

3. Consistency asks whether the accounts describe materially similar features. Similar wording alone is not enough. The Council will compare the underlying steps, conditions and effects, and will note important differences. A consistent pattern may exist even when the consequences differ in size; the common feature must be stated precisely.

4. Spread asks whether the issue appears across more than one business, location, product, route or relevant setting. The scope of the claimed pattern will be kept no broader than the evidence supports. A problem confined to one setting may still merit consideration, but the Council will not describe it as global or sector-wide without evidence for that reach.

5. Corroboration asks whether independent accounts or other evidence support the description. This may include documents, separate first-hand reports, public information or a clear record of the process. Corroboration is assessed with care: the same copied material or a group of accounts derived from one source does not necessarily provide independent confirmation.

26.Each report will be recorded and assessed for relevance to TR-001. Counts are administrative measures, not a vote on whether an owner’s account is true. The Council will take reasonable care to identify duplicates, connected submissions and reports that concern different problems. A report may inform more than one part of the test. If information is incomplete, the report may still contribute, but the Council will not treat missing detail as proof of a particular conclusion.

27.The five parts are considered together, not as a mechanical score. A strong showing on one part cannot automatically substitute for all the others. The Council will record what the evidence supports, what remains uncertain and what further information could change the assessment. The outcome of the review may be that a pattern is supported, not supported, or not yet sufficiently clear. This call does not predetermine that outcome.

8. Privacy, anonymity and safe participation

28.Members are anonymous unless they choose a public seat. You may make a report without asking to be publicly identified. The Council asks owners not to name their own business in a narrative or attachment. In describing other parties, use neutral descriptions such as “a customs intermediary,” “a freight forwarder,” “a large marketplace” or “a national retailer.” Do not make public accusations against a named company or person in a report.

29.A report may contain information that could identify its author even when no name is included. Exact dates, unusual products, routes, transaction values or quoted correspondence may reveal identity. Consider whether a broader description would preserve the relevant evidence while reducing that risk. You may tell the Secretariat that a detail is sensitive and ask how it will be handled before sending it.

30.The Council will use submitted information for the inquiry, its pattern review and any later work on a draft proposal, consultation or Assembly decision. Reports may be summarised in aggregate or paraphrased to explain a pattern. The Council will avoid publishing identifying details and will not attribute a story to a named member without that person’s informed choice. Because this is an evidence-gathering process, absolute confidentiality should not be assumed: information may need to be reviewed internally, and the Secretariat may need to clarify how a submission can be handled.

31.Do not send passwords, payment credentials, identity documents, private customer data, employee records or full account numbers. Before attaching a document, remove information not needed to understand the issue. Keep an original copy for your own records. If a document contains information you cannot redact safely, describe the relevant part instead of attaching it.

32.Taking part is voluntary. You may submit a report without giving your name, decline a follow-up, or ask that a detail not be used in a public summary. Such a request will be considered, but the Council may be unable to assess a report if essential information cannot be recorded or checked. You may also describe an issue without supplying attachments. The Council will not penalise a person for choosing not to participate.

9. How to take part from any country and language

33.Owners from any country may contribute. You do not need to be a Reseated member, use a particular trade route, or operate in a country represented on the Council. You may report a local experience, a cross-border transaction or a process that affects you indirectly as a small supplier or buyer. If a local term has no clear English equivalent, include the term and explain what it means in your setting.

34.Evidence may be submitted in the language in which it is easiest for you to explain the experience. If you can, include a brief English summary, but it is not a condition of participation. The Council will seek to understand reports across languages and may use translation or ask for clarification where needed. Translation can introduce uncertainty; important legal or technical terms should

therefore be identified as precisely as you can, and an original document should be retained by you.

35.Organise your account in the order that makes sense to you. If useful, include the country, approximate date, kind of goods, step in the process, effect, recurrence and available evidence. You may answer the questions in section 5 rather than write a narrative. Please avoid sending large collections of unrelated documents. A focused account with an explanation of its evidence is more useful than volume without context.

36.If you submit with assistance from a colleague, adviser, association or translator, make clear which parts are your first-hand account and which parts were added or translated by another person. Do not send a report on behalf of another owner without their permission. A person who prefers not to submit directly may ask someone they trust to help, while ensuring the account accurately reflects the owner’s experience and protecting their identity.

10. Review stages and indicative timeline

37.This call opens on 10 February 2026. The Council will receive and organise evidence before deciding whether the reported experiences establish a pattern that warrants a draft fix. No closing date for submissions or date for a decision is fixed in this note. The Council will communicate later milestones through Reseated’s usual channels. Owners should not delay seeking professional or official guidance while waiting for this inquiry.

1. Reports. Owners submit accounts and, where safe and useful, supporting evidence. The Council records the issue, relevant setting and any limitations in the material.

2. Pattern review. The Council applies the five-part test—Volume, Frequency, Consistency, Spread and Corroboration—and identifies gaps or questions. This stage determines whether the evidence supports further work; it does not itself create a rule or obligation.

3. Draft fix. If the evidence supports a sufficiently clear and actionable pattern, the Council may prepare a draft proposal. A proposal might explore clearer guidance, thresholds, transition periods, cost information or another response, but no particular remedy is adopted by this call.

4. Public consultation. A draft, if produced, would be shared for comment. Owners and other interested participants could identify errors, unintended consequences, implementation concerns or better alternatives. The final text would not be assumed to match the first draft.

5. Assembly ballot. A proposal that proceeds would be put to the Founders Assembly for a decision under the applicable process. Evidence gathering and consultation do not guarantee adoption.

6. Letters and tracking. If the Assembly adopts a proposal, Reseated may send letters to relevant decision-makers or company leaders able to consider it. Any resulting seat or response would be tracked accurately. This notice records no such letters, replies or commitments.

38.The stages are sequential in purpose, but the work may require clarification, additional evidence or revision before moving forward. The Council will distinguish an evidence report from a draft recommendation, a recommendation from an adopted position, and an adopted position from an external party’s decision to act. No owner should infer that participation means a particular decision-maker has been contacted or has agreed to anything.

11. Closing invitation

39.The Trade Council asks owners to describe the process as they encountered it: what they were trying to do, what they were told or required to do, what happened next, and what effect it had. Specificity helps the Council separate a rule from a service practice, a one-off event from a repeated pattern, and a proposed remedy from the problem it is meant to address.

40.Reports from different countries and business circumstances will help the Council avoid mistaking one local experience for a universal condition. Equally, the Council will not dismiss a well-documented account because it comes from a

small business or a single location. The question is what the evidence supports, how far that evidence reaches and what practical change—if any—would be justified.

Notes and sources

Sources

1. United Nations — Micro-, Small and Medium-sized Enterprises Day
2. International Labour Organization — Micro, small and medium-sized enterprises
3. European Parliament — CBAM: Parliament adopts simplifications to the EU carbon leakage instrument