Joint Position Paper:
Joint Foreign Chambers of the Philippines

02 April 2025 — The Makati Business Club co-signed a position paper with the Joint Foreign Chambers (JFC) in expressing its position on Joint Administrative Order (JAO) 001-2025 issued by the Committee on Pre-border Technical Verification and Cross-border Electronic Invoicing (CPTVCEI*), led by the Department of Finance.

Issued on January 20, 2025, the JAO enforces Administrative Order No. 23/2024 from President Marcos last year. It requires the establishment of digital systems for Pre-Border Technical Verification (PTV) and Cross-Border Electronic Invoicing (CEI) for all imported goods.

The CEI system covers all exports to the Philippines, requiring exporters to register and issue e-invoices before shipment. These invoices must contain 20 mandatory fields, including a universal identifier, timestamp, invoice number, issuance date, and key contact details of stakeholders like exporters, importers, customs brokers, and manufacturers. Failure to comply with these requirements will result in financial penalties or revocation of accreditation of the importer.

That said, the JFC acknowledges the government’s intent to enhance national security, consumer rights, and environmental protection but raises concerns about potential unintended consequences on foreign investment, ease of doing business, and economic growth.

Key Concerns:

1. JAO 001-2025 imposes additional layers of compliance for importers and exporters under the Digital and Integrated System for Pre-Border Technical Verification (PTV) and Cross-Border Electronic Invoicing (CEI), which may deter foreign investments and slow down business operations.
2. The order imposes additional customs and logistics requirements, potentially causing delays in the movement of goods and affecting trade efficiency.
3. There is a need for broader engagement with industry players to ensure that the regulation is practical and aligned with business realities.
4. The order could make the Philippines less attractive to investors compared to regional peers by increasing operational costs and bureaucratic burdens.
5. Certain provisions lack clarity, potentially leading to inconsistent enforcement and uncertainty in compliance.

JFC Recommendations:

1. Conduct comprehensive consultations with business groups and stakeholders before implementation.
2. Simplify regulatory requirements to maintain ease of doing business and ensure competitiveness.
3. Clarify ambiguous provisions to provide legal certainty and prevent misinterpretations.
4. Ensure alignment with investment goals to avoid unintended disruptions in investment and trade.

The JFC and its signatories, including MBC, urges the government to reconsider and refine JAO 001-2025 to balance regulatory objectives with economic growth. A more consultative and business-friendly approach will strengthen the Philippines’ position as an attractive investment destination.

For a detailed breakdown of the concerns and recommendations, access the full position paper HERE.

* The Committee on Pre-border Technical Verification and Cross-border Electronic Invoicing (CPTVCEI) is composed of the following agencies:

• Department of Finance (DOF)
• Department of Agriculture (DA)
• Department of Trade and Industry (DTI)
• Department of Energy (DOE)
• Department of Health (DOH)
• Department of Environment and Natural Resources (DENR)
• Department of Information and Communications Technology (DICT)
• Bureau of Customs (BOC)
• Philippine Drug Enforcement Agency (PDEA)