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"Changing customs rules and procedures are the guerrilla tactics of undeclared trade wars," he said.
"Recently, and not for the first time, the United States has resorted to changing the rules of origin for textiles and clothing.
"It has done so despite international undertakings to the contrary and despite agreement within the World Trade Organisation and the World Customs Organisation to work towards standardisation internationally.
"On this, as on the previous occasion, the US administration is reacting to pressure from its 'infant' textiles and clothing industries for just a little bit more protection."
Mr Miller queried the need for rules of origin in a globalised economy and said: "Manufacturers are now virtually free to source materials wherever they are most readily available, to manufacture wherever makes most sense, often in more than one place, and to market internationally.
"Given this, how does one go about establishing where a product was 'made' and is it really worth the effort?" he asked.
Using the example of a recent EU directive on bananas, Mr Miller went on to highlight the dangers of too much rule making and standardisation.
"Setting standards can be a more effective way of blocking trade than tariffs and it has the added PR advantage that it sounds good. Standards are good for us. They are there to protect us against things which are harmful in some way, or shoddy, or whatever," he said.
"Where I part company with the standardisers and harmonisers is at the point at which they seek to deny the existence of comparative advantage, where wittingly or unwittingly they begin to use standardisation in ways which reduce the benefits of diversity.
"At one extreme this is represented by bureaucrats telling consumers that they can only eat bananas or Brussels sprouts if they comply with quite arbitrary specifications. At the other, it is represented by attempts to go beyond agreement on international codes to insist that governments seek to achieve such standards in a particular way."