REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT Progress Report on the implementation of the EU Strategy and Action Plan for customs risk management
Date: 2016-07-19
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU control, action programme, customs cooperation, customs regulations, customs territory (EU), customs union, exchange of information, import policy, institutional cooperation

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 19.7.2016  COM(2016) 476 final   REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT Progress Report on the implementation of the EU Strategy and Action Plan for customs risk management {SWD(2016) 242 final}  
 
 
TABLE OF CONTENTS 

1 

INTRODUCTION ....................................................................................................... 3 

2  OVERALL ASSESSMENT ........................................................................................ 3 

2.1  Purpose and methodology ................................................................................. 3 
2.2  Objective 1 — Improving data quality and filing arrangements ....................... 4 
2.3  Objective  2  —  Ensuring  availability  of  supply  chain  data,  sharing  of 

risk-relevant information and control results .................................................... 5 

2.4  Objective  3  —  Implementing  control  and  risk  mitigation  measures 

where required (‘assess in advance — control where required’) ...................... 5 

2.5  Objective 4 — Increasing capacity to ensure effective implementation 
of  the  Common  Risk  Management  Framework  and  to  increase 
responsiveness to newly identified risks ........................................................... 6 

2.6  Objective  5  —  Promoting  interagency  cooperation  and  information 
sharing  between  customs  and  other  authorities  at  Member  State  and 
EU level ............................................................................................................. 7 
2.7  Objective 6 — Improving cooperation with trade ............................................. 9 
2.8  Objective 7 — Tapping the potential offered by international customs 

cooperation ........................................................................................................ 9 

3. PRELIMINARY CONCLUSIONS ............................................................................... 10 

2 

 
 
 
 
1 

INTRODUCTION 

The  Council  conclusions  of  4  December  2014  endorsing  the  2014  EU  Strategy  and 
Action Plan for customs risk management1 (hereinafter referred to as ‘the Strategy’ and 
‘the Action Plan’) invite the Commission to report to the Council, within 18 months, on 
the implementation of the Strategy and the Action Plan and on the results achieved. 

This  Progress  Report  (hereinafter  referred  to  as  ‘the  Report’),  constitutes  the 
Commission’s response to that request. 

The  overall  aim  of  the  Strategy  is  to  achieve  a  high-quality,  multi-layered  approach  to 
risk  management  that  is  effective  and  efficient.  The  Strategy  identifies  seven  key 
objectives, namely: 

i. 
ii. 

iii. 
iv. 
v. 

vi. 
vii. 

improving data quality and filing arrangements; 
ensuring availability of supply chain data and sharing of risk-relevant 
information between customs authorities; 
implementing control and risk mitigation measures where required; 
strengthening capacity; 
promoting cross-sectoral cooperation and information sharing between 
customs and other authorities at Member State and EU level; 
improving cooperation with trade; and 
tapping the potential offered by international customs cooperation. 

The Action Plan sets out a series of actions (totalling 22 actions and 54 sub-actions) to be 
taken  for  each  objective.  A  roadmap  for  the  implementation  of  the  actions  has  been 
developed, identifying 64 deliverables. The majority of the actions are being carried out 
either by or under the responsibility of the Commission. 

The  Commission  is  assisted  in  implementing  the  Strategy  by  the  Risk  Management 
Strategy  Implementation  Coordination  Group,  which  is  composed  of  representatives 
from all Member States. This group has contributed to the preparation of this Report. 

2  OVERALL ASSESSMENT 

2.1  Purpose and methodology 

This  Report  gives  an  overall  qualitative  assessment  of  the  implementation  of  the 
Strategy.2  It  highlights  the  progress  made  under  each  of  the  seven  key  objectives  and 
draws some preliminary conclusions. In view of the short time elapsed since the launch 
of the actions, this Report does not seek to assess their impact.   

The information presented in this Report was obtained by means of a survey conducted 
within  the  Commission  and  in  Member  States.  It  covered  the  implementation  of  the 
individual actions (both those already started and those yet to be launched), and allowed 

1    COM(2014) 527 final. 
2    Quantitative result indicators were not available to measure the progress achieved in the implementation of the Strategy. 

3 

 
 
                                                 
the  Commission  to  identify  both  success  stories  and  challenges  encountered,  and  to 
gather comments and suggestions on the implementation process overall.3 

The  survey  shows  that,  at  the  time  of  preparing  this  Report,  i.e.  18  months  into  the 
implementation process, the great majority of the actions and sub-actions set out in the 
Action Plan have been launched and are under way.4 

The  Commission  Staff  Working  Document,  annexed  to  this  Report,  provides  further 
information on the progress made on the individual actions and sub-actions. 

2.2  Objective 1 — Improving data quality and filing arrangements 

The Strategy and Action Plan call for a legal framework to be set up that will ensure that 
high-quality  data  on  advance  cargo  information  relating  to  supply  chain  movements  is 
available  and  is  correctly  used  by  customs  and  other  competent  authorities  for  the 
purpose  of  risk  management.  Central  to  ensuring  data  quality  is  the  introduction  of 
‘multiple  filing’  —  filing  of  information  related  to  the  same  specific  assignment  by 
different  operators  —  and  the  lifting  of  existing  exemptions  for  postal  and  low-value 
consignments.  The  legal  framework  consists  of  the  Union  Customs  Code5  and  the 
detailed rules contained in the delegated6 and implementing7 acts. This new legislation is 
applicable from 1 May 2016 and the development and upgrading of relevant IT systems 
necessary  for  its  implementation  will  take  place  in  accordance  with  the  timeline  laid 
down in the Work Programme for the Union Customs Code.8 

The objective of a complete legal framework providing requirements for multiple filling 
and  improving  data  quality  has  thus  been  accomplished  and  only  its  implementation 
remains to be achieved. 

3   The  survey  covered  all  Members  States  and  ten  departments  of  the  Commission  (DG  Taxation  and  Customs  Union,  DG 
Agriculture and Rural Development, DG Budget, DG Internal Market, Industry, Entrepreneurship and SMEs, DG Migration and 
Home Affairs, DG Justice and Consumers, DG Maritime Affairs and Fisheries, DG Mobility and Transport, DG Health and Food 
Safety, and the European Anti-Fraud Office). 

4   Of  the  54  sub-actions  identified  by  the  Strategy  and  Action  Plan,  41  have  been  completed  or  are  under  way  (i.e.  76 %).  In 
addition,  of  the  64  deliverables  identified  in  the  roadmap,  11  have  been  completed  (i.e.  17 %)  and  34  are  being  finalised  (i.e. 
53 %). 

5

   Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs 

Code (OJ L 269, 10.10.2013, p. 1). 

6   Commission  Delegated  Regulation  (EU)  2015/2446  of  28  July  2015  supplementing  Regulation  (EU)  No  952/2013  of  the 
European  Parliament  and  of  the  Council  as  regards  detailed  rules  concerning  certain  provisions  of  the  Union  Customs  Code 
(OJ L 343, 29.12.2015, p. 1); Commission Delegated Regulation (EU) 2016/341 of 17 December 2015 supplementing Regulation 
(EU) No 952/2013 of the European Parliament and of the Council as regards transitional rules for certain provisions of the Union 
Customs Code where the relevant electronic systems are not yet operational and amending Delegated Regulation (EU) 2015/2446 
(OJ L 69, 15.3.2016, p. 1). 

7   Commission  Implementing  Regulation  (EU)  2015/2447  of  24  November  2015  laying  down  detailed  rules  for  implementing 
certain  provisions  of  Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  laying  down  the  Union 
Customs Code (OJ L 343, 29.12.2015, p. 558). 

8   Commission  Implementing  Decision  (EU)  2016/578  of  11  April  2016  establishing  the  Work  Programme  relating  to  the 
development and deployment of the electronic systems provided for in the Union Customs Code (OJ L 99, 15.4.2016, p. 6). 

4 

 
                                                 
2.3  Objective  2  —  Ensuring  availability  of  supply  chain  data,  sharing  of  risk-

relevant information and control results 

Improving data quality and filing arrangements and ensuring the availability and sharing 
of supply chain data and risk-relevant information between customs authorities depends 
on  the  development  and  availability  of  the  necessary  IT  systems,  i.e.  most  notably  the 
new Import Control System. 

IT systems for other customs procedures are also to be developed or upgraded as part of 
the Union Customs Code.  

Import Control System 

One priority action identified by the Strategy is the development and implementation of 
appropriate  IT  solutions  for  improving  data  quality,  filing  arrangements  and  data 
availability for the detection  of security  and safety risks  at the point of entry  of goods. 
The  development  of  a  new  Import  Control  System  is  the  main  deliverable  under  this 
priority.  The  Commission,  with  the  support  of  Member  States,  has  prepared  a  business 
case and a vision document on the basis of external cost-benefit analysis and feasibility 
studies.9 

The new Import Control System will bring significant improvements to EU customs risk 
management. A common repository of advance cargo information is at the core of, and 
constitutes a fundamental prerequisite for, the required improvements in data quality and 
availability.  With  the  introduction  of  multiple  filing  and  the  expected  increase  in  the 
volume  of  advance  cargo  information  —  from  approximately  40  million  declarations 
annually in the current system to some 400 million under the new Import Control System 
–  a  decentralised  approach  would  be  very  burdensome  for  customs  and  trade.  A  cost-
benefit analysis carried out in 2013 and further analysis of possible options have already 
identified that only a centralised approach can cover the need for a high-level of system 
availability,  and  will  ensure  a  harmonised  approach  of  customs  risk  management  on 
advanced cargo information. The common repository will make it possible to store and 
process the increased  volume  of  advance  cargo  information  and  will allow  all  Member 
States  in  any  given  supply  chain  to  perform  effective  and  efficient  risk  assessment 
directly  and  simultaneously  using  the  information  in  the  repository.  It  will  also  allow 
risk-relevant information and control results to be shared between Member States. 

The  launch  of  the  formal  elaboration  phase  for  ICS  2.0  has  been  delayed,  but  work  is 
under  way  to  resolve  outstanding  questions  related  to  the  budget,  governance,  delivery 
strategy and planning, operational mode, a dedicated implementing act for the IT system 
and capacity of the project. A pragmatic step-by-step approach (using ‘building blocks’) 
for its further development and implementation is to be followed. 

2.4  Objective  3  —  Implementing  control  and  risk  mitigation  measures  where 

required (‘assess in advance — control where required’) 

The  progress  made  in  this  area  is  due,  in  large  part,  to  the  progress  made  on  activities 
already under way at the  time of the adoption of the Strategy, namely those relating to 
prohibitions and restrictions. A set of factsheets has been produced (in cooperation with 
Member States) for selected pieces of legislation that set prohibitions and restrictions on 

9   The business case and vision documents were presented to the Customs Policy Group on 3 December 2015. 

5 

 
                                                 
imports and exports of goods, to be controlled at the external EU border. The factsheets 
give a description of the legislative framework, the role of customs and the documentary 
and physical checks to be applied. They provide a basis on which to determine the timing 
of  customs  controls  and  whether  further  recommendations  for  customs  and  other 
authorities are needed. 

The  services  of  the  Commission  have  prepared  guidance  to  support  the  preparation  or 
review of EU legal acts on how customs involvement is to be envisaged including how 
customs risk management should be taken into account.  

2.5  Objective  4  —  Increasing  capacity  to  ensure  effective  implementation  of  the 
Common  Risk  Management  Framework  and  to  increase  responsiveness  to 
newly identified risks 

Progress  has  been  slow  despite  many  ongoing  actions  designed  to  increase  capacity  of 
Member States and EU to implement the current customs risk management framework. 
the 
While  Member  States  have  been  active 
implementation  of  the  Common  Risk  Management  Framework  at  national  level  and 
finding  ways  to  address  these  weaknesses,  there  are  issues  relating  to  Member  States’ 
capacity to implement solutions and the EU’s ability to provide appropriate risk analysis 
capacity  support  to  the  Member  States  through  the  initiative  of  a  new  Import  Control 
System. 

inconsistencies 

identifying 

in 

in 

In 2015, the Commission and Member State experts assessed and identified the need for 
an improved IT  system to  share risk information,  i.e.  a next  generation of the Customs 
Risk Management System. 

Common risk criteria were evaluated at both Member State and EU level. Pilot projects 
were  launched  by  Member  States  in  order  to  assess  and  test  the  implementation  of 
common  risk  criteria.  In  parallel,  data  mining  tools  and  designs  for  data  analysis  were 
tested  on  data  available  at  EU  level.  The  aim  of  these  tests  was  to  identify  possible 
in  particular  for 
further  risk  management  capabilities  and 
containerised transport. 

targeting, 

improve 

As part of the ongoing process of developing common criteria for the full range of risks, 
the  Commission  and  Member  States  began  working  on  definitions  for  the  various 
financial risks and revising the existing risk criteria for safety and security, in particular 
in respect of air cargo security. 

The  Commission  and  Member  States  have  also  taken  steps  to  ensure  the  harmonised 
implementation of risk criteria. 

In  monitoring  and  evaluating  the  implementation,  they  have  been  able  to  achieve 
synergies with the Customs Union Performance exercise. 

6 

 
 
 
2.6  Objective  5  —  Promoting  interagency  cooperation  and  information  sharing 

between customs and other authorities at Member State and EU level 

Interagency cooperation has been improved overall, in particular in non-customs policy 
areas. 

For  example,  a  methodology  has  been  developed  for  the  exchange  of  risk  information 
between  customs  and  market  surveillance  authorities  in  the  area  of  product  safety.  An 
outline of this methodology was shared with Member States in December 2015.10 

Improvements  can  be  achieved  in  the  cooperation  between  customs  and  other  border 
authorities on the aspect of information sharing in relation to controls of goods carried by 
travellers or crew members. The issue was highlighted in the April 2016 communication 
Stronger and Smarter Information Systems for Borders and Security11. 

An  evaluation  of  the  cooperation  between  customs  and  border  guards,  including  the 
implementation  of  the  April  2013  guidelines12,  is  ongoing.  The  initial  results  show  a 
good level of cooperation overall and a set of good practices has been identified. 

A high level seminar on passenger controls was organised in Riga on 7-8 May 2015 to 
improve  integrated  border  management  between  customs  and  other  authorities.  The 
seminar  identified  an  agenda  for  further  work  and  cooperation  between  customs  and 
other border authorities, including making advance passenger data available for customs 
use.  To  improve  cooperation  with  Frontex13,  a  formal  dialogue  has  been  launched 
focusing  on  the  functions  falling  within  the  agency’s  framework  and  those  of  customs, 
including customs risk management. 

The  risk  management  section  of  the  Customs  Code  Committee  has  assessed  the 
implications, as relates to customs, of the sharing of information provided for under the 
Passenger Name  Record (PNR) and Advanced Passenger Information (API) Directives. 
Securing customs participation in the national Passenger Information Units (PIUs) and/or 
customs  access  to  this  data,  according  to  Directive  (EU)  2016/68114,  is  important  for 
effective  and  efficient  customs  supervision  of  goods  in  passenger  traffic.  The  data  is 
considered to be very valuable for the identification of risks related to passenger luggage 
(or cash carried by passengers) and allows customs to carry out targeted and risk-based 
controls  at  arrival,  thus  contributing  to  the  fight  against  serious  and  organised  crime, 
terrorism  and  the  financing  of  terrorism  whilst  respecting  data  protection  and  privacy 
safeguards. 

Ensuring  cooperation  with  other  law  enforcement  authorities  remains  a  challenge 
(including, in some cases, between the departments responsible for customs controls/risk 

10   Cooperation between Customs and Market Surveillance Authorities (MSA) on risk management in the area of product safety and 

compliance controls on imported goods. 

11   COM(2016)205, 6.4.2016. 

12   Guidelines for the cooperation between Border Guards — Customs administrations working at the external borders, April 2013. 
13   European Agency for the Management of Operational Cooperation at the External Borders of the Member States of the European 

Union. 

14   Directive (EU) 2016/681 of the European Parliament and of the Council of 27 April 2016 on the use of passenger name record 
(PNR)  data  for  the  prevention,  detection,  investigation  and  prosecution  of  terrorist  offences  and  serious  crime  (OJ  L  119, 
4.5.2016, p. 132). 

7 

 
                                                 
management  and  those  responsible  for  investigations  within  a  customs  administration). 
Over  the  reporting  period,  focus  has  been  put  on  better  communicating  and  explaining 
the role of risk management, and existing and possible future customs capacities. Mutual 
understanding  of  the  different  responsibilities  of  customs  and  other  law  enforcement 
authorities has improved as a result, but further efforts are needed. 

The scope of the exchange of information for the purpose of mutual assistance between 
Member State customs authorities and between those authorities and the Commission has 
been  extended  with  the  amendment  of  the  Regulation  on  mutual  assistance.15  The 
amended Regulation offers a wider legal basis for a number of actions aiming at better 
compliance  of  economic  operators  with  customs  and  agricultural  legislation.  Access  to 
the  data  collected  under  the  amended  Regulation  for  risk  management  would  improve 
customs risk management at Member States and EU level. 

One  contribution  made  by  customs  to  the  implementation  of  the  European  Agenda  on 
Security16 is  the  development of specific  risk rules (common risk criteria) for  air cargo 
security. A preliminary set of common risk criteria has been agreed. As the criteria in the 
air  cargo  domain  concern  not  only  customs  but  also  other  authorities,  relevant 
Commission  services,  EU  Intelligence  Analysis  Centre,  and  national  customs,  civil 
aviation  and  counter-terrorism  experts  have 
their 
development.  The  common  risk  criteria  for  air  cargo  are  therefore  based  upon  multi-
disciplinary, cross-sectorial input from all relevant parties and will complement existing 
civil aviation security measures for cargo and post as an additional layer of security. As 
the new risk rules will only be applied on the basis of the new Import Control System, 
they will not be implemented before the end of 2020. 

therefore  been 

involved 

in 

The Strategy also supports the implementation of the EU Maritime Security Strategy and 
its  action  plan,  adopted  by  the  Council  on  16  December  2014.  In  particular  the 
implementation of the Common Information Sharing Environment (CISE) that has been 
developed as a meta-project for enhanced cooperation and information exchange between 
civil  and  military  authorities  with  a  view  to  further  enhance  a  common  maritime 
situational awareness picture and data exchange. With the aim of improving supply chain 
security  and  supporting  the  risk-based  surveillance  of  the  movement  of  goods  in  the 
maritime  domain  CISE  promotes  the  exchange  of  information  between  the  different 
authorities involved in the fight against terrorist and organised crime (e.g. smuggling of 
goods,  trafficking  of  arms  and  narcotics  and  cross-border  movements  of  the  cash 
proceeds  of  illegal  trade).  Relevant  EU  agencies17  are  invited  to  reinforce  inter-agency 
cooperation.  The  Pre-Operational  Validation  project  'EUCISE2020'  is  to  test  CISE  at 
large scale by 2017-18, followed by a step-by-step implementation until 2020.  

Any of the above mentioned information sharing will respect the fundamental rights, and 
in particular the rights to privacy and protection of personal data.  

15   Regulation  (EC)  No  2015/1525  of  the  European  Parliament  and  of  the  Council  of  9  September  2015  amending  Council 
Regulation (EC) No 515/97 on  mutual assistance between the administrative  authorities of the Member States and cooperation 
between the latter and the Commission to ensure the correct application of the law on customs and agriculture matters (OJ L 243, 
18.9.2015, p. 1) will enter into force on the 1 September 2016 as well as the  Commission implementing acts: Regulation (EU) 
2016/345 (OJ L 65, 11.3.2016, p. 38) and 2016/346 (OJ L 65, 11.3.2016, p. 40). 

16   COM(2015) 185 final. 

17   EMSA, EFCA, FRONTEX, EDA , EUROPOL and ESA. 

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2.7  Objective 6 — Improving cooperation with trade 

Cooperation  between  customs  and  trade  has  already  been  improved  through  the 
strengthening of the Authorised Economic Operator (AEO) concept. Changes to the AEO 
concept were introduced by the Union Customs Code and its delegated and implementing 
acts and these changes necessitated an update to the AEO guidelines18. 

The  AEO  Network  Group,  created  in  2007  to  monitor  the  implementation  of  the  AEO 
concept, launched its second monitoring initiative in 2013, designed to ensure correct and 
uniform  application  of  AEO  rules.  The  monitoring  exercise  confirmed  that  the  AEO 
concept  is  strong  and  reliable.  Member  States  have  developed  robust  procedures 
guaranteeing high-quality, efficient and consistent management of the concept. 

In 2015, two specific target groups were created within the Customs Risk Management 
System for the exchange of risk information relating to AEO processes and procedures: 
one  group  for  the  exchange  of  sensitive  information  in  the  AEO  process  and  another 
group for the exchange of information on irregularities involving a partner country AEO. 

Progress  has  been  slower  in  other  areas  such  as  improving  the  knowledge  of  supply 
chains. 

The creation of a legal framework to ensure the availability of high-quality data for risk 
management purposes has led to the question being raised as to whether and how the data 
submitted by traders and included in the customs declarations for postal parcels (i.e. the 
CN23 declaration) could be made available and re-used for submitting an entry summary 
declaration  for  safety  and  security  and  the  customs  declaration.  This  discussion  is  also 
pertinent given the ever-increasing volume of small consignments being sent as a result 
of  e-commerce.  Member  State  customs  authorities,  postal  operators,  trade  associations 
and international partners (the US, Canada and China) have been involved in analysing 
the  options  available  within  the  global  postal  model  of  the  Universal  Postal  Union. 
Whichever  option  is  chosen,  it  is  important  for  it  to  be  able  to  operate  with  the  new 
Import Control System. 

2.8  Objective  7  —  Tapping  the  potential  offered  by  international  customs 

cooperation 

A  number  of  activities  have  been  launched  and  are  ongoing  with  the  objective  of 
improving  the  risk  management  of  the  supply  chain  by  means  of  international 
cooperation. 

The successes include the revision of the World Customs Organisation’s (WCO) SAFE 
Framework  of  Standards19,  the  development  of  international  standards,  e.g.  on  pre-
loading  air  cargo  information20,  and  the  development  of  mutual  recognition  of 

18   http://ec.europa.eu/taxation_customs/resources/documents/customs/policy_issues/customs_security/aeo_guidelines_en.pdf. 

19   The WCO SAFE Framework review cycle, endorsed by the WCO Council in June 2015, has introduced amendments to the WCO 

SAFE Framework, including on pre-loading air cargo information. 

20   i.e.  within  the  joint  working  group  of  the  International  Civil  Aviation  Organisation  (ICAO)  and  the  WCO  on  air  cargo 

information. 

9 

 
                                                 
Authorised Economic Operator (AEO) concepts  21. A number of projects are under way 
relating to the exchange of information with non-EU countries (e.g. in the context of the 
Smart and Secure Trade Lanes pilot project with China22). These projects will, however, 
require reliable IT systems to be created if they are to succeed. 

3. PRELIMINARY CONCLUSIONS 

The  reform  of  customs  risk  management  is  a  resource-intensive  exercise.  Achieving 
results takes time. Although a large number of actions have been launched, progress has 
been uneven. 

Progress is most noticeable on actions which fall within the remit of customs, while it has 
been slower for those actions requiring increased cooperation between customs and other 
authorities, in particular cooperation with law enforcement and security authorities. 

At  this  stage  of  the  implementation  process,  the  main  challenge  is  IT  related.  While 
feasible  solutions  have  been  found,  e.g.  for  ensuring  data  availability,  exchanging 
information and automating risk analysis, successful implementation depends on both the 
upgrading of existing IT systems and the development and deployment of new systems 
(either  by  the  Member  States  with  or  without  Commission  support,  or  by  the 
Commission). 

Insufficient  financing  to  develop  the  required  IT  systems  is  a  major  issue  hampering 
progress,  most  notably  in  relation  to  the  new  Import  Control  System.  Whilst  being 
recognised  as  an  European  Information  System  in  the  Customs  2020  Regulation,  the 
Customs 2020 programme budget is insufficient to cover the costs of IT implementation. 

Similar resource constraints exist at Member State level. In some Member States, it may 
be difficult to justify the extra resources needed for developing the necessary IT systems 
given the number of declarations to be processed. 

In  the  absence  of  additional  resources,  a  number  of  actions  will  not  be  able  to  be 
implemented by the end of 2020, as envisaged in the Strategy and Action Plan. A delay 
would also affect the implementation of commitments to customs related aspects in the 
context of the European Agenda on Security. 

Further  analysis  also  needs  to  be  carried  out  into  the  impact  of  the  new  EU  data 
protection legislation, in particular with respect to law enforcement authorities. 

At  this  stage  of  the  implementation  process,  the  Commission  does  not  suggest  making 
any changes to the Strategy and Action Plan.  

21   Agreements on AEO mutual recognition are in place with Norway, Switzerland, Andorra, the US, Japan and China; negotiations 
are ongoing with Canada. A system of automated data exchange for the purpose of mutual recognition has been put in place with 
China, Japan, Switzerland and the US. 

22   The  Smart  and  Secure  Trade  Lanes  (SSTL)  pilot  project,  launched  in  2006,  aims  to  test  specific  safety  and  security  related 
recommendations  issued  under  the  WCO  SAFE  Framework  in  EU-China  trade.  In  2014,  the  SSTL  IT  expert  group  began  
developing a new IT tool for data exchange which will allow larger, and consequently more meaningful, volumes  of data to be 
exchanged. 

10 

 
 
                                                 
External events and developments23 not included in the roadmap for implementation of 
the Strategy and Action Plan may, however, have an impact on the implementation and 
may require changes to specific actions and the prioritisation of certain sub-actions. The 
roadmap therefore needs updating.  

Recommendations  by  the  Council  and  the  European  Parliament,  and  the  impact  on  the 
fundamental rights will be considered. 

The availability of resources to fully implement the needs for customs risk management 
identified  in  the  Strategy  and  Action  Plan,  including  in  support  of  transnational  risk 
analysis in all customs procedures, will require having an in-depth consideration. 

23   e.g. the 2015 Paris and 2016 Brussels terrorist attacks, the European Court of Auditors Special Report 24/2015  Tackling intra-

Community VAT fraud: More action needed. 

11