The Committee is encouraged by the government’s responses to our 2023 White Paper recommendations. By supporting and implementing policies related to autonomous vehicles and the Internet of Vehicles, addressing concerns about electric vehicle (EV) battery recycling, streamlining Taiwan Power Co.’s (Taipower) charging facility application process, and enhancing warehouse fire safety measures, the government has demonstrated its commitment to addressing critical issues and fostering progress in various sectors.

The Committee’s call for more specific and proactive actions from the government to promote EVs aligns with the broader goal of achieving net-zero carbon emissions by 2050. By facilitating the equitable development of the EV industry and improving paperless customs clearance operations, the government can contribute to sustainable economic growth and environmental protection.

Additionally, adopting a forward-looking and unified approach to enhancing the regulatory framework for passenger transportation services and aligning airport transportation services with market needs will improve the overall passenger experience and contribute to the competitiveness of Taiwan’s transportation sector. Lastly, we stress the importance of providing sufficient preparation time for industry to adapt to new policies, ensuring a smooth transition and fostering innovation and growth in key sectors. With that in mind, we offer the following suggestions:

Suggestion 1: Enhance processes related to customs administration and trade facilitation.

We are pleased with the signing of the first agreement under the U.S.-Taiwan Initiative on 21st Century Trade. In particular, we welcome the provisions in Chapter 2, covering customs administration and trade facilitation. This chapter promises significant developments, such as raising the allowable customs value for simplified clearance to US$2,500. To further enhance these initiatives, the Committee makes the following recommendations:

1.1   Remove weight limitations for express clearance to support smoother customs operations. In alignment with the objectives of the 21st Century Trade Initiative, we urge the government to remove weight restrictions on express shipments to better support small- and medium-sized enterprises and enhance trade convenience.

1.2   Allow customs declarations post-export for non-tax and non-fee related shipments. This practice is common in several markets. At the time of export, it should suffice to provide the import security filing information, commonly known in the United States as the “10+2” data elements.

1.3   Accelerate the implementation of simplified tax rates for low-value express import shipments. Article 7, Section 8.2(a) of the trade facilitation chapter encourages reducing documentation requirements. We commend the Customs Administration for simplifying express import shipment processes, including the use of a simplified Harmonized System (HS) code and fixed import duty. To streamline processes, we suggest further reducing documentation requirements for express shipments into Taiwan, which are currently identical to those required for other general goods. For instance, eliminating the power of attorney requirement would be possible if electronic data, such as signatures on electronic bills of lading, could be authenticated in accordance with recent amendments to the Electronic Signatures Act. This would ensure alignment with international practices, including those of the United States.

1.4   Promote the use of electronic documentation. The implementation of the Electronic Documentation and Systems for Traders (Article 2.6) undoubtedly benefits all parties involved. We propose expanding its application to include paperless and electronic processes for customs inspection, duty/tax collection, post-entry document filing, and the signing of documents and forms. Adopting these measures will streamline procedures and increase efficiency across the board.

While initiatives like paperless customs clearance, inspection of express shipments, and tax forms have been partially implemented, we urge that they be put into practice more extensively. Businesses should have the capability to submit necessary documents electronically to a designated portal for pre-review by customs officials. Moreover, to further reduce administrative burden, longstanding practices that require copious paperwork for selected declarations should be shifted to an online format. This change would greatly decrease the volume of physical paperwork and streamline the entire customs process.

We urge the Customs Administration to update its online protocols in accordance with the recent amendments to the Electronic Signatures Act and directives from the Ministry of Digital Affairs, enabling business operators to sign import and export documents electronically. Adopting this change will enhance efficiency and align with modern digital standards.

1.5   Adhere to the 60-day notice and comment period rule. Stakeholders have frequently been frustrated by deviations from the 60-day notice and comment period requirement, leading to insufficient communication between the government and stakeholders. An example occurred on March 5, 2024, when the Customs Administration sent out a notice for public consultation on simplified tax rates for low-value express shipments, which introduced four levels and 25 categories for shipments but failed to detail the implementation strategies or specific tax rates. Businesses were given a narrow window of 11 days to respond to the changes, limiting meaningful dialogue among government, businesses, and the public. We urge the Customs Administration to provide substantial opportunities to the public and industry to offer feedback.

Suggestion 2: Safeguard free competition in the data-collection process for the EV charging market.

In September 2023, the Executive Yuan announced the “Regulations for the Establishment and Management of Dedicated Electric Vehicle (EV) Charging Parking Spaces and Charging Facilities” (currently only available in Chinese). According to Article 11 of these regulations, both privately- and government-owned parking lot operators are required to transmit operating information about charging facilities to Transport Data eXchange (TDX), a platform designated by the Ministry of Transportation and Communications (MOTC). Operators who fail to follow these provisions may face fines.

Providing easy access to basic information about EV charging points, such as their locations and operating hours, is essential for encouraging EV adoption and enhancing user convenience. However, certain operational data, such as real-time charger availability as displayed on a Charge Point Operator’s (CPO’s) mobile app, present significant competitive advantages. This dynamic information serves not only as a key medium for engaging customers but also represents a valuable business asset, enabling CPOs to maintain a competitive edge.

The requirement to make such information universally available on platforms like TDX at no cost contravenes the principle of free market competition, leading to unfair market conditions and substantial losses for initial investors. Over time, this mandate could also reduce the commercial benefits for operators, potentially slowing down their investment in and expansion of charging infrastructure, thus negatively affecting the widespread adoption of EV charging points.

We urge the government to exclude information on charging points installed in private parking lots, as well as other information that could potentially undermine a company’s competitive advantage, from the regulations compelling the transmission of operational data. Private commercial activity should not be subject to mandatory disclosure through government regulations.

The Committee recommends that the government consider incorporating information uploads as one of the qualifying conditions for charging point deployment subsidies, rather than imposing penalties. This approach would help accelerate the pace of charging point deployment while also assisting the government with its data collection objectives.

Suggestion 3: Implement a consistent legal framework for automotive transportation services that aligns with consumer behavior and technological advancements.

Under Article 34 of the Highway Act, the automobile transportation industry is segmented into the taxicab business and the car rental business. The primary distinction between these categories is the service model: taxicab businesses provide cars with drivers, while car rental businesses offer customers the choice to either drive themselves or hire a driver.

Further, in 2019, the MOTC introduced an amendment to Article 103-1 of the “Regulations for Automobile Transportation Operators.” This amendment aimed to differentiate these business types more clearly by prohibiting car rental businesses from offering driver services via internet applications (also known as e-hailing), thereby fostering the growth of diversified taxi businesses. However, as both models fundamentally provide similar services, a more forward-looking, inclusive, and consistent regulatory framework is necessary to better reflect the industry’s evolving dynamics.

According to a survey by the National Taxi Industry Development Association, e-hailing has become the preferred option for most passengers. This trend spans traditional taxis, diversified taxis, and car rental services with drivers. The current regulatory disparity between these services, however, may hinder digital transformation in the long term.

We strongly recommend a comprehensive review of the current regulations governing the automobile transportation industry to ensure that consumer experiences reflect digital norms. This review should encompass both legal frameworks and practical implementations to ensure that the regulations effectively address the evolving needs of the industry while maintaining compliance with legal standards. The Committee recommends the following specific measures:

1. Review the current regulatory framework and assess whether it reflects new circumstances and consumer behavior. Develop an action plan for the integration of a new, more streamlined system that addresses current challenges and future advancements in technology, such as autonomous driving and evolving vehicle models. Enhance the resilience of regulations to accommodate these advancements effectively.
2. Implement measures under the new framework to facilitate seamless operations of passenger transportation services across cities and counties. Replace restrictive area management with more efficient technological solutions to ensure seamless operations.
3. Revise the current fare system to introduce greater flexibility in pricing. Allow for the adoption of more dynamic pricing models to respond effectively to market demand. Fully open app pricing mechanisms to all hailing services under the new framework to accommodate consumer preferences for e-hailing services.

Suggestion 4: Review regulations for ground transportation services at international airports and provide more diverse and convenient options for travelers.

As international tourism rebounds and airlines expand their flight offerings, Taiwan Taoyuan International Airport is experiencing a resurgence in passenger volume, nearing pre-pandemic levels. Airport taxis play a crucial role by connecting passengers to and from the “gate of Taiwan,” serving as a vital link for direct access to the rest of the country.

However, the ongoing third terminal expansion and Taoyuan Aerotropolis projects have led to a significant reduction in long-term parking spaces around the airport, posing challenges for passengers who rely on private vehicles to travel to the airport.

While the government promotes the use of public transportation, the operating hours of the Taoyuan Airport MRT do not adequately accommodate passengers on red-eye flights and long-haul journeys to Europe and the United States. These flights often depart or arrive early in the morning or late at night, when the MRT is not running, creating inconvenience for travelers. Furthermore, existing regulations for airport ground transportation services lack foresight in enhancing the overall passenger experience and do not encourage the promotion of sustainability and social responsibility in the transportation industry.

The Committee believes that it is essential to update the regulations governing airport taxis to keep pace with advancements and trends in the automotive industry. Outdated practices, such as using engine displacement or size as a measure for airport taxis, fail to account for technological advancements that allow smaller engines to meet the needs of larger vehicle models.

Further, requiring airport taxis to transition to electric in line with the government’s 2050 net-zero emission policy would aid Taiwan’s green transition. Moreover, despite the growing popularity of e-hailing services, Taiwan’s international airports continue to rely predominantly on traditional airport taxi services, and the absence of designated pick-up and drop-off areas for e-hailing services further exacerbates the disconnect between airport ground transportation practices and passenger behavior. As a result, international passengers may experience frustration and inconvenience when navigating ground transportation options at Taiwan’s airports.

To enhance the passenger experience and improve the airport’s performance in international rankings, Taiwan’s airport operators and the MOTC should jointly reassess current airport ground transportation practices. This re-evaluation should prioritize flexibility, sustainability, and alignment with evolving passenger preferences and industry trends.

Recommendations:

• Revise standards for airport taxis. Remove engine displacement as a measure for airport taxis and replace it with more relevant criteria such as vehicle dimensions. This measure will ensure that airport taxis meet modern standards and can accommodate passengers comfortably.
• Promote electric vehicles. Mandate that a certain proportion of airport taxis and rental car services at international airports be electric vehicles. This initiative supports the government’s 2050 net-zero emissions target and promotes sustainability efforts within the transportation sector.
• Designate areas for e-hailing services. Introduce designated pick-up and drop-off areas for e-hailing services at international airports. Doing so will improve the accessibility and convenience of e-hailing options for passengers, aligning airport ground transportation practices with evolving passenger preferences.
• Conduct trial runs allowing diversified electric taxis to serve international airports. This initiative would enable the exploration of innovative transportation solutions and evaluate their feasibility in meeting the diverse needs of airport passengers while promoting sustainability.