COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Taking the Customs Union to the Next Level: a Plan for Action
Date: 2020-09-28
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: action programme, customs cooperation, customs regulations, customs territory (EU), customs union, electronic commerce, risk management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.9.2020  COM(2020) 581 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Taking the Customs Union to the Next Level: a Plan for Action  
 
 
I. 

Introduction  

Within  the  EU  Customs  Union,  EU  Member  States’  customs  authorities  are  responsible  for 
performing  a  wide  range  of  controls  before  goods  enter  into  free  circulation  in  the  EU  customs 
territory,  that  are  aimed  at  protecting  both  EU  revenues  and  the  security  and  safety,  health  and 
prosperity of EU citizens and business.  

It has become apparent in recent years that Member States’ customs authorities are struggling with the 
challenges of performing their various roles. Despite a major modernisation of EU customs legislation 
in 2016, there is evidence of problems such as undervaluation of goods to avoid customs duties and 
VAT1 and of smuggling  of illicit or unsafe goods. There are also concerns about imbalances between 
Member States in  customs  controls  and of  goods being diverted towards the weakest  entry  and exit 
points to the EU customs territory to avoid detection. The fast changing world, with the acceleration 
of digital transformation and new business models such as e-commerce, has added to the challenges 
that customs face in implementing and enforcing EU legislation on imports and exports. At the same 
time,  customs  must  always  endeavour  to  ensure  that  legitimate  trade  can  benefit  from  facilitation 
because international trade is vital to the success of the EU. Furthermore, the intensive preparations 
needed  for  the  departure  of  the  United  Kingdom  from  the  EU  Customs  Union  at  the  end  of  the 
transition period have greatly increased the workload of EU customs authorities. In these conditions, 
there are great risks of losses of revenues for the EU budget,  of threats to the safety and security of 
EU  citizens,  and  of  excessive  burdens  on  legitimate  trade,  if  action  is  not  taken  to  reinforce  the 
activity of national customs authorities across the EU. 

Mindful  of  this,  the  President  of  the  European  Commission,  Ursula  von  der  Leyen,  stated  in  her 
political  guidelines  for  the  new  Commission’s  term  of  office  published  on  16  July  20192  that  “It  is 
time  to  take  the  Customs  Union  to  the  next  level,  equipping  it  with  a  stronger  framework  that  will 
allow us to better protect our citizens and our single market”. She said that the Commission would 
propose  “an  integrated  European  approach  to  reinforce  customs  risk  management  and  support 
effective controls by the Member States.”.  

The  present  Communication  lays  down  an  Action  Plan  to  turn  President  von  der  Leyen’s  Political 
Guidelines into tangible benefits for European citizens, businesses and society.  

The significant effect of the Covid-19 pandemic has made it more important than ever to ensure smart 
management  of  the  EU  Customs  Union.  The  Commission’s  customs  services  reacted  swiftly  to  the 
crisis, adopting legislation, issuing guidelines and actively supporting Member States and businesses 
in particular to ensure flexibilities in relation to customs debt obligations, facilitate the fast and swift 
clearance of medical/protective equipment and prevent counterfeit or unsafe equipment from entering 
the EU. This response should help customs operations if there is a generalised resurgence of COVID-

1 For example, the potential losses of customs duties and VAT due to undervaluation of imports of textiles and footwear 
from China to one Member State were calculated to be close to 5.2 billion euro for the period 2013-16. See the European 
Court  of  Auditors  report  no  19  of  2017:  “Import  procedures:  shortcomings  in  the  legal  framework  and  an  ineffective 
implementation impact the financial interests of the EU 

2 https://ec.europa.eu/commission/sites/beta-political/files/political-guidelines-next-commission_en.pdf 

1 

 
 
 
                                                           
19 cases. However, the crisis has made it clear that it is now vital to explore all ways to ensure that the 
Customs  Union  and  Member  States’  customs  authorities  operate  to  maximum  efficiency,  remain 
flexible and resilient in times of crisis and better anticipate problems. This implies, above all, a new 
emphasis  on  ensuring  greater availability and use of data and data  analysis for customs purposes as 
well as developing an appropriate set of foresight and common crisis management tools.  

Some  of  the  proposed  actions  will  require  Member  States  to  allocate  the  appropriate  resources  at 
national  level  and  to  support  EU  level  financing  for  the  already-proposed  new  EU  customs 
programme  and  new  financial  instrument  for  customs  equipment.  In  the  case  of  EU  financing,  the 
amounts  at  stake  are  modest3  while  the  potential  is  substantial,  as  customs  duties  alone  account  for 
14% of total EU budget revenues (without taking into account the knock-on effect on VAT revenues 
of Member States). About 85% of the funding proposed for the new EU customs programme will go 
into the operation, maintenance and development of the customs electronic systems that provide the 
seamless and coherent structure for the smooth functioning of the Customs Union and the protection 
of  the Single Market and EU citizens.  

II. 

Context 

The EU Customs Union means that EU Member States apply a common system of customs duties to 
imports of goods from outside the EU customs territory, there are no customs duties and no customs 
controls  at  the  borders  between  the  EU  Member  States.  The  EU  is  a  member  of  the  World  Trade 
Organisation, has a common commercial policy and acts as one trade bloc in drawing up international 
trade  deals.  Member  States’  customs  authorities  supervise  all  goods  entering  or  leaving  the  EU 
customs territory, regardless of their mode of entry or exit.   

A modernised legal framework of customs rules and procedures is in place since 2016 and work on 
upgrading  and  developing  electronic  systems  designed  to  make  the  Customs  Union  a  modern, 
interconnected and fully paperless environment should be completed across the EU before end 2025 at 
the latest.  

Customs authorities nowadays have an enormous range of supervisory and control responsibilities in 
relation  to  goods  imported  into  the  EU  customs  territory.  They  not  only  collect  customs  duties  and 
VAT  on  imported  goods,  and  excise  duties  where  applicable,  but  they  also  check  those  goods  for 
many non-financial purposes, such as to ensure that they meet EU product compliance4 requirements, 
food, health and environmental standards and rules, and much more.  

They also check the conformity of imported goods with rules on the protection of Intellectual Property 
Rights,  they  control  the  imports  of  drug  precursors  to  prevent  their  illegal  diversion  into  the 
manufacturing of drugs, they control the trade of cultural goods, wildlife trade and waste shipments to 
prevent  illegal  exportation  and  importation,  and  they  enforce  rules  on  illicit  cash  flows  entering  or 
leaving  the  EU  as  part  of  the  EU's  anti-money  laundering  legislation.    They  cooperate  in  the  fight 
law  enforcement  authorities, 
against  fraud, 

terrorism  and  organised  crime 

together  with 

3 The amount proposed is under 1 billion euros spread over 7 years 
4 Product compliance covers not only compliance with product harmonisation legislation but also other requirements such 
as product safety and accessibility for persons with disabilities 

2 

 
 
                                                           
 
administrations  and  agencies  responsible  for  border  and  internal  security.  In  addition,  they  are 
responsible  for  managing  and  enforcing  an  increasing  number  of  preferential  trade  agreements 
between the EU and other countries.   

The  EU’s  Internal  Market,  which  established  an  area  without  internal  frontiers  to  the  movement  of 
goods,  has  made  it  more  important  than  ever  to  ensure  the  uniform  application  of  rules  at  external 
borders to goods that can move freely once inside the customs territory. Customs must balance these 
controls with the facilitation of international trade and global supply chains; exports to the rest of the 
world  have  in  recent  decades  become  an  increasingly  significant  source  of  business  for  European 
companies  and  of  jobs  for  Europeans5  while  80%  of  EU  imports  provide  raw  materials  for  EU 
production  activities.  New  legislation  on  EU-wide  action  in  non-customs  policy  areas  often  brings 
new  responsibilities  for  customs  and  this  is  likely  to  continue.  For  example,  customs  are  already 
facing requests to collect data and share it with  other authorities. Each time new responsibilities are 
imposed on customs, a new electronic system must be developed and managed, involving additional 
human resource and financial costs for the Commission and Member States’ customs authorities. 

Against  this  background,  the  Commission  launched  an  exercise  in  2018  aimed  at  helping  policy 
makers ensure that EU customs remains effective for the long-term. This innovative foresight project 
on “The Future of Customs in the EU 2040”6 worked to create a shared and strategic understanding 
among  key  stakeholders  of  ways  to  deal  with  current  and  future  challenges  for  customs  and  to 
generate a vision for how EU customs should look in 2040.  

The  outcome  of  this  foresight  exercise  painted  a  picture  of  an  EU  Customs  Union  of  the  future  in 
which customs authorities operate in a fully integrated way to: 

  Protect  society,  the  environment  and  the  EU  economy  through  effective  facilitation  of 

legitimate trade and intelligent, risk-based supervision of supply chains; 

  Be  proactive,  working  seamlessly  with  stakeholders,  be  committed  to  innovation  and 

sustainability and be the reference for customs worldwide; 

  Be seen to act as one.  

To achieve this vision, participants underlined steps such as more data mining and better use of data 
resources;  more  interoperability  between  customs  and  other  border  information  systems;  stronger 
governance  of  the  Customs  Union;  a  better  system  for  training  customs  officials;  and  improved 
cooperation between the EU and other countries at multilateral and bilateral level.  

III.  The way ahead 

In  line  with  the  Commission’s  Better  Regulation  efforts,  the  foresight  exercise  brought  value  to  the 
Commission both through the vision that it has generated of an EU customs for the future and through 
its reinforcement of the important links with the broad stakeholder community. The Commission now 
proposes a series of actions for the period of its mandate to take the Customs Union to the next level 
that  aim  to  have  regard  to  the  results  of  the  foresight  exercise  to  the  consultations  of  EU  Member 

5 Since 2000, extra-EU exports have on average grown by 6% per year in value and by 3% in tonnage; the number of items 
exported to non-EU countries has increased by 12% on a yearly basis since 2010. 
6 https://blogs.ec.europa.eu/eupolicylab/?s=future+of+customs 

3 

 
 
                                                           
States  and  stakeholders7,  and  to  the  need  to  draw  some  conclusions  for  customs  purposes  from  the 
recent  Covid-19  pandemic.  As  a  first  step  towards  achieving  the  vision  generated  in  the  foresight 
exercise,  the  actions  focus  in  particular  on  ensuring  greater  availability  and  use  of  data  and  data 
analysis  for  customs  purposes  and  intelligent,  risk-based  supervision  of  supply  chains.    The  actions 
are grouped under four headings as follows:  

a)  Risk  management  is  pivotal  to  customs  controls,  given  the  substantial  volumes  of  goods 
coming into and leaving the customs territory that customs authorities cannot always examine 
on  an  individual  basis  and  given  the  need  to  facilitate  legitimate  trade.  Customs  authorities 
already  perform  risk  management  on  the  basis  of  an  EU-wide  common  risk  management 
framework  comprising  common  risk  criteria8  and  standards,  measures  to  exchange  risk 
information and the performance of electronic risk analysis. The central principle is articulated 
around  two  lines  of  defence:  (i)  assessing  in  advance,  and  (ii)  controlling  when  and  where 
required, before or after the release of the goods into the EU customs territory. However, there 
are concerns that the risk management framework is not implemented in the same way in all 
Member  States.  Furthermore,  Member  States’  risk  assessment  systems  may  not  encompass 
important  information  either  because  the  information  is  not  collected  or  shared  between 
Member States or because Member States lack Union-wide comparative data that would allow 
them to interpret their own national data.  Data analysis at EU level is needed to drive a better 
and  more  extensive  use  of  data  from  all  sources,  including  through  international  customs 
cooperation, and  facilitate interlinkages in  risk management,  customs controls  and anti-fraud 
actions.  

b)  Managing  e-commerce.  E-commerce  is  to  be  welcomed  for  the  benefits  it  brings  for 
businesses,  in  particular  for  SMEs,  and  consumers,  and  facilitating  this  activity  is  a 
cornerstone of the Digital Single Market Strategy. However, tax and customs authorities have 
serious  difficulties  in  ensuring  the  tax  and  customs  compliance  of  goods  purchased  online. 
Customs  authorities  have  the  additional  obligation  of  checking  goods  for  the  wide  range  of 
non-financial  purposes  already  described,  including  EU  safety,  security,  intellectual  property 
rights and other standards. The VAT e-commerce package9 adopted on 5 December 2017 and 
to be implemented as from 1 July 2021 aims to combat VAT fraud and ensure a level playing 
field  for  EU  businesses  while  facilitating  cross-border  trade.  Customs  legislation  and  IT 
systems  are  being  adapted  to  cater  for  these  new  VAT  rules.  New  reporting  obligations  on 
postal  services  from  15  March 2021  will contribute to  ensuring the safety  and security  of e-
commerce 
international 
cooperation, to ensure that customs can control these imports effectively. 

imports.  However,  additional  actions  are  needed, 

including 

c) The promotion of compliance. Strengthening and facilitating compliance is vital in order to 
free up customs resources to focus on suspicious movements of goods. A scheme for providing 
benefits to trusted traders in return for their compliance with criteria laid down in EU customs 
legislation already exists and is widely used but it must be managed better to prevent abuse. At 
the same time, efforts  must  continue to  facilitate compliant low-risk traders, in  particular by 

7 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12305-Action-Plan-on-the-Customs-Union 
8 Accessible only to experts in risk management in Member States 
9 https://ec.europa.eu/taxation_customs/business/vat/modernising-vat-cross-border-ecommerce_en 

4 

 
 
                                                           
 
ensuring  that  the  simplifications  of  customs  procedures  provided  for  in  customs  legislation 
actually work in practice. Continuing to develop cooperation with key international partners, at 
bilateral  and  multilateral  level,  while  monitoring  the  implementation  of  the  EU’s  existing 
preferential  arrangements  with  third  countries  and  enforcing  their  rules,  is  another  important 
element of compliance.  

d) Customs authorities acting as one. While Member States already cooperate with each other 
in  many  areas,  there  must  be  broader  and  more  operational  cooperation  among  customs 
authorities on a thematic or geographical basis in order to ensure delivery of the core priorities 
of customs. Cooperation between customs authorities and other national authorities must also 
be  improved  and  the  EU  must  act  as  one  on  customs  matters  at  international  level.  It  is 
necessary to address imbalances between Member States in customs controls in particular by 
ensuring  that  all  Member  States  have  sufficient,  trained  human  resources  and  modern  and 
reliable  customs  control  equipment.  Equivalence  of  results  in  carrying  out  controls  at  the 
external  borders  must  also  be  ensured  by  measuring  accurately  the  performance  of  customs 
activities and tasks. Above all, it is necessary to address more fundamental questions such as 
how  to  handle  crises  like  the  recent  Covid-19  pandemic;  how  to  manage  the  costs  of  the 
customs  electronic  systems;  how  to  ensure  that  customs  tools,  training  and  methods  and 
organisational structures are adequate and appropriate; and how to ensure visibility for the role 
of customs in society and attract talented and motivated people to work for customs.  

Under these four main headings, the Commission announces several actions in the following chapter. 
Preliminary work on some actions has already commenced but the actions deserve a mention because 
of their importance for the plan for taking the Customs Union to the next level. The Commission will 
support the implementation  of these actions to  take the Customs  Union to the next  level  through its 
technical  support  programmes.  The  actions  announced  below  do  not  preclude  the  possibility  of 
customs  being  required  to  implement  additional  EU  policies  at  the  EU’s  borders,  subject  to 
availability  of  human  and  financial  resources,  to  an  assessment  of  the  policy  and  IT  impact  and  to 
appropriate planning.  

IV.  Actions 

a) More effective customs risk management to allow more effective controls 

1)  EU Joint Analytics Capabilities (JAC)   

It  has  become  evident  from  discussions  on  customs  controls  that  customs  authorities  would  benefit 
greatly, for a wide range of customs purposes, from more data and data analysis. Better data analysis 
would  help  with  risk  management,  customs  clearance  and  post-clearance,  and  anti-fraud  actions.  In 
the longer term, the monitoring of trends and patterns via data analysis could, for example, help the 
Commission and customs authorities to identify shortcomings and vulnerabilities and to make policy 
decisions in a more informed way.  

There is a wealth of data in a wide variety of EU and Member States’ databases and data platforms 
that  is  already  utilised  to  some  extent  for  risk  management  purposes,  and  more  data  are  becoming 
available  for  EU  level  work  as  new  Union  Customs  Code  (UCC)  electronic  systems  and  upgrades 
come  on  line.  However,  this  wealth  of  data  has  never  been  properly  interlinked  or  tapped  into  and 

5 

 
 
 
customs authorities and the Commission need better accessibility to this data, including for antifraud 
purposes.   

The Commission therefore proposes to launch an EU “Joint Analytics Capabilities” initiative within 
its own services to facilitate the collection of data and the better use of data from customs and non-
customs sources and to provide tools for better sharing and interlinkage of the data. The work will be 
carried out in close cooperation with Member States and the results of the work will be shared with 
them, complementing Member States’ own information and tools. The data analysis will also be made 
available for anti-fraud and enforcement actions, including for purposes related to preventing the loss 
of Traditional Own Resources (TOR).  

The starting point for the joint analytics initiative will be improving risk management and, in line with 
the  present  risk  management  strategy,  it  will  give  first  priority  to  ensuring  better  protection  of  the 
financial interests of the Union and greater security and safety of the EU and its citizens. The results 
will help  customs authorities to identify  risky trade flows, including in  crisis situations. As a result, 
they will be able to undertake more focused, efficient and cost-effective controls and optimise the use 
of  scarce  resources  that  should  be  reflected  in  better  results  under  the  Customs  Union  Performance 
indicators (see below).  

Within  this  framework,  the  work  will  focus  initially  on  exploiting  data  already  available  within  the 
EU  Customs  Surveillance  database  of  import  and  export  data  in  order  to  analyse  trade  flows.  The 
analysis of Surveillance data will also help to ensure the correct and uniform implementation of the 
Union tariff in the customs clearance systems of the Member States.  

The  new  Customs  Import  Control  electronic  system  (ICS2)  that  is  being  deployed  in  three  phases 
between  2021  and  2024  to  identify  safety  and  security  threats  before  they  arrive  into  the  EU  will 
provide  further  data  and  capabilities  for  data  analytics.  Pilot  work  to  explore  those  ICS2  shared 
analytics  capabilities  will  start  in  2020  and  the  Customs  Policy  Group  will  be  asked  to  endorse  the 
analytics tool for ICS2 in December 2020.  

Later  on,  and  depending  on  the  availability  of  resources,  the  Commission  services  will  expand  the 
scope of their data analytics work by considering whether and how data from additional sources could 
complement  the  JAC  analysis.  This  could  include  combining  data  from  the  Customs  Surveillance 
system with data concerning Intellectual Property (IPR) infringements included in the “COPIS” anti-
counterfeiting and piracy system), utilizing data in the Anti-Fraud Information System (“AFIS”) and 
capitalizing  on  new  data  sources  including  data  that  could  be  collected  under  several  of  the  actions 
described  further  on  in  this  Communication  (VAT  payment  data,  online  platforms,  Customs  Union 
Performance, Union Customs Code electronic systems and others). The JAC analysis could also, over 
time and if feasible, encompass artificial intelligence/machine learning. 

Appropriate governance solutions will be developed for the results of the analysis and data protection 
and confidentiality issues will be taken into account. In the medium term, if necessary and subject to 
an impact assessment, an EU architecture for data storage and management could be developed within 
existing structures or in a new agency to be established (see also below).  

Action: 2020 - 2024: 
  From  2020  onwards:  Work  is  ongoing  on    developing  tools  within  the  EU  Surveillance 

6 

 
 
electronic system  to  utilise its comprehensive set of import and export data to  extract  trends 
affecting  the  financial  interests  of  the  Union.  For  ICS2,  Member  States  should  endorse  the 
proposed ICS2 analytics tool in December. 

  From end 2021, the Commission services will use Surveillance data analytics to support the 

correct and uniform implementation of the Union tariff.  

  By  end  2023,  following  the  planned  expansion  of  the  Surveillance  dataset  to  include 
additional data elements, and subject to availability of resources, the Commission services will 
expand  analytics  to  combine  data  from  that  system  with  data  in  other  systems  related  for 
example  to  seizures  of  counterfeit  goods    (COPIS),  anti-fraud  information  (AFIS),  VAT 
payments data, online platforms, Customs Union Performance and in the Union Customs Code 
electronic  systems.  In  addition,  following  the  development  of  the  ICS2  analytics  tool  and 
following  the  implementation  of  two  of  the  three  phases  of  ICS2,  the  Commission  and 
Member  States  will  commence  analytics  on  pre-loading  and  pre-arrival  advance  data  for 
postal, express and cargo air carriers. 

  By end 2024, following the implementation of the final phase of ICS2, the Commission and 
Member States will carry out analytics of pre-loading and pre-arrival advance data provided by 
all maritime, road and air carriers and logistic providers. 

2)  Revised risk management strategy  

 The Commission plans to reshape and strengthen the current Risk Management framework in order to 
achieve  an  even  more  responsive  and  structured  approach  to  risk  management.  Risk  management 
work  focuses  on  security,  safety  and  financial  risks.  The  Commission  wishes  to  strengthen  the 
framework  by  leveraging  on  the  proposed  new  joint  analytics  capabilities.  In  addition,  it  wishes  to 
develop  a  sound  and  efficient  governance  for  addressing  financial  risks  in  the  context  of  the 
implementation of the Commission’s decision of 2018 on Financial Risk Criteria10.  

The  Commission  will  also,  in  order  to  protect  the  EU  Internal  Market  and  its  citizens,  aim  to 
strengthen the current risk management process for the wide range of non-financial risks that customs 
are  responsible  for  controlling,  as  outlined  above,    In  this  respect,  the  new  tools  for  real-time 
cooperation  between  customs  and  for  identifying  risks  that  will  be  put  in  place  under  the  Customs 
Import  Control  electronic  system  (ICS2)  should  provide  great  assistance  to  customs  authorities  in 
managing pre-arrival security and safety risks, by enabling customs to work together in real time to 
target  risk consignments even before they are loaded in  third countries.  Improvements must also  be 
made to the processes for identifying and managing risks that may arise after the arrival of goods into 
the  EU  customs  territory.  Finally,  the  new  risk  management  framework  will  aim to  respond  to  new 
challenges  such  as  those  arising  from  the  increasing  amount  of  e-commerce  entering  the  customs 
territory. 

Action: 2021 

  New Risk Management Strategy in the form of a Commission Communication (to leverage on 
joint  analytics work, develop  governance for financial risks, strengthen risk management for 
non-financial risks and address  the rapid increase in e-commerce) to be adopted in Q2 2021 

10 C(2018) 3293 (access restricted to risk management experts of Member States) 

7 

 
 
 
                                                           
b) Managing e-Commerce 

3)  Using VAT data for customs purposes  

As announced in its Action Plan for fairer and simpler taxation supporting the recovery strategy11, the 
Commission  intends  to  explore  the  possibility  of  establishing  within  the  Eurofisc  tax  anti-fraud 
network12 an EU hub for tax information serving not only VAT administrations but also customs and 
anti-fraud  services,  and  of  providing  a  direct  connection  to  Eurofisc  for  customs.  Some  exchanges 
between these services already exist13 but they need to be streamlined and structured via the creation 
of a direct access to taxation information for customs authorities.  

In  addition,  the  Commission  aims  to  ensure  that  customs  will  be  able  to  leverage  the  new  payment 
data reporting obligations to be imposed as of 1 January 2024 on payment service providers for VAT 
purposes14. These payment data will identify recipients of those payments and provide information on 
amounts and dates of payments and the Member State of origin of the payment/payer. Access to these 
data  would  help  customs  to  trace  goods  back  to  their  source  and  thus  to  detect  undervaluation  of 
imported goods in particular. Such access should also ensure greater synergies between customs and 
tax authorities that would reinforce the efforts to fight against fraud.  

Actions: 2020 to 2024 

  Creation of direct customs access to the Eurofisc tax information hub15 by 2022 
  The Commission will assess as from Q3 2020 the possible arrangements to ensure access by 
customs to VAT payment data and, subject to that assessment, will propose a final solution by 
1/1/2024 

4)  Revisit role and obligations of e-commerce actors notably platforms 

The VAT e-commerce package adopted on 5 December 2017 and to be implemented as from 1 July  
2021  abolishes  the  current  €10/22  threshold  under  which  imported  goods  are  exempted  from  VAT. 
This  means  that, from the day  the package enters into force,  customs will  have to  levy  VAT on  all 
goods on their arrival into the EU unless the seller already collected the VAT at the time of purchase 
under  the  Import  One-Stop  Shop  (IOSS)  scheme.  From  the  same  date,  online  marketplaces 
(“platforms”) will also have the obligation to keep certain information for VAT purposes and provide 
it to the tax authority upon request.  

Building on these tax reporting requirements, the Commission will explore the imposition of customs 
reporting obligations on platforms in order to address the challenges of e-commerce. While platforms 
are not typically involved in arranging the customs clearance of goods bought online, they have and 
could share data showing entire sales chains, from the original seller, via the transactional value, to the 

11 COM (2020) 312 of 15/7/2020 
12 Eurofisc is a network for the swift exchange between Member States, processing and analysis of targeted information on 
cross-border tax fraud and for the coordination of follow-up actions. 
13 These exchanges have taken place, for example, under the European Multidisciplinary Platform Against Criminal 
Threats (EMPACT). Under that scheme, there was practical, operational cooperation between EU tax administrations, via 
Eurofisc, customs administrations and both Europol and OLAF in the field of VAT fraud detection and prevention. 
14 Council Directive (EU) 2020/284 of 18 February 2020 (OJ L 62, 2.3.2020, p. 7) and Council Regulation (EU) 2020/283 
of 18 February 2020 (OJ L 62, 2.3.2020, p. 1) 
15 See action 9 of the Action Plan for fairer and simpler taxation supporting the recovery strategy (footnote 10 above) 

8 

 
 
                                                           
final-end buyer. This data would supplement information provided in customs declarations and could 
enhance customs and tax actions against fraudulent activities such as undervaluation, misdescription 
of  goods  and  false  declarations  of  origin,  VAT  and  customs  fraud,  and  against  the  range  of  non-
financial risks. The provision of data by platforms would also benefit trade in that it would allow the 
identification  and  speedier  release  of  low  risk  consignments  that  are  below  the  customs  duty 
exemption  threshold,  where  VAT  has  already  been  paid  under  the  IOSS  scheme.  The  Commission 
will also examine the effects of e-commerce on customs duty collection and on the level playing field 
for EU operators. This will include exploring arrangements for customs duty collection on the lines of 
the new VAT collection approach. 

Actions: 2021 to 2023 

  Following pilot testing, and subject to the results of an impact assessment, legal amendment to 

UCC package to impose customs reporting obligation on platforms: Q1 2023. 

  Analysis  of  the  impact  of  e-commerce  on  customs  duty  collection  and  on  the  level  playing 

field for EU operators: to be launched in 2021. 

c) Strengthening and facilitating compliance 

5)  Stepping up the AEO programme  

The EU Authorised Economic Operator (AEO) programme that is in place since 2008 aims to enhance 
the  security  of  international  supply  chains  while  facilitating  legitimate  trade.  It  allows  traders  to 
benefit  from  a  range  of  simplifications  of  customs  formalities  if  they  in  return  take  strengthened 
measures  to  ensure  compliance  and  cooperation  with  customs.  The  Commission  has  developed  a 
comprehensive  strategy  and  methodology  to  improve  the  robust  implementation  of  the  programme, 
including by strengthening links to customs risk management and increasing traders’ understanding of 
the programme. 

The  Commission  will,  subject  to  the  results  of  fact  finding  visits  to  Member  States,  consider 
introducing legislation that will impose more precise obligations on Member States to monitor AEOs 
to ensure their continued fulfilment of the AEO criteria. Separately, the Commission will update the 
AEO guidelines that are designed to provide assistance to Member States and economic operators in 
the application of the AEO programme.   

Actions: 2021  

  Legislative proposal to set out more precise monitoring obligations (if necessary): Q2/3 2021 
  Update to AEO guidelines: Q2/3 2021  

6)  Develop and deploy the EU Single Window environment for Customs 

The Commission is working on a proposal for an EU Single Window environment for Customs that 
would offer both stronger control possibilities and trade facilitation.  

Businesses would benefit by being able to complete all border formalities, for customs and for other 
purposes such as health, environment, product and food safety and security, in one electronic action 

9 

 
 
 
 
 
and  enjoy  a  speedier  border  clearance  of  goods  at  import  and  export.  For  government  agencies,  the 
measure  would  allow  collaborative  processing,  sharing  and  exchange  of  information  and  better  risk 
assessment. A pilot exercise along these lines between customs and partner authorities competent for 
the agri-food chain, import of timber and phyto-sanitary formalities is already operational and in use 
in nine Member States16.  

Actions: 2020 

  Legislative proposal for a Single Window environment for Customs by Q4 2020 

7)  Union Customs Code evaluation  

A modernised legal framework of customs rules and procedures is in place since 2016, in the form of 
the Union Customs Code (UCC). More than half of the UCC’s seventeen electronic systems designed 
to make the Customs Union a modern, fully paperless environment are already in operation and the 
remaining  systems  will  be  completed  before  end  2025  at  the  latest.  The  Commission  will,  by  end 
2021, complete an interim evaluation to establish whether the Union Customs Code and the electronic 
systems  completed by that  date are still fit  for purpose having regard to  the objective which was to 
ensure modernised, streamlined and simplified processes for the assistance of compliant traders and 
customs authorities. The evaluation will support decisions on whether the Code and its implementing 
and  delegated  acts  should  be  revised.  It  will  in  particular  consider  whether  the  Code  is  sufficiently 
flexible to deal with the management of customs formalities during crises such as Covid-19 and new 
business models such as e-commerce.  

Action: 2021 

 

Interim evaluation of the Union Customs Code – Q4 2021 

8)  Common system of customs sanctions 

Although customs legislation is harmonised, its enforcement varies as it is the task for Member States’ 
national  authorities.  The  absence  of  a  common  system  of  infringements  and  sanctions  creates  legal 
uncertainty  for  businesses  and  possible  competitive  distortions  in  the  Internal  Market.  It  means  in 
particular  vulnerabilities  in  revenue  collection  and  weaknesses  in  enforcing  policies.  Under  World 
Trade  Organisation  rules,  the  EU  is  obliged  to  ensure  a  uniform  application  of  customs  legislation, 
including in regard to sanctions for non-compliance. 

The  Commission  will,  therefore,  propose  another  approach  to  this  subject  following  the  lack  of 
agreement  on  the  Commission’s  2013  proposal  for  a  Union  legal  framework  for  customs 
infringements and sanctions17. 

The  Commission  proposes  with  the  support  of  Member  States  in  a  project  group  to  draw  up  an 
updated  comprehensive  report  on  the  individual  systems  of  penalties  in  each  Member  State  in 

16 Bulgaria, Cyprus, Czechia, Estonia, Ireland, Latvia, Poland, Portugal and Slovenia 

17 COM(2013) 884 final of 13.12.2013  

10 

 
 
 
                                                           
 
accordance with Article 42 of the Union Customs Code. On the basis of that report, the Commission 
will  establish  guidelines  for  the  application  of  the  criteria  set  out  in  Article  42  (1)  to  such  national 
systems, namely that the sanctions must be “effective, proportionate and dissuasive”.  This work may 
lead in due course to another legislative proposal in place of the 2013 proposal.    

Actions: 2020 to 2022 

  Guidelines on criteria for national sanctions regimes – Q4 2021 
  Based  on  experience  with  the  Guidelines,  the  Commission  will  consider  whether  it  is 

necessary to propose legislation  concerning sanctions for non-compliance - 2022 

9)  Legal framework to combat customs fraud  

At Union level, Regulation (EC) No 515/9718 is the main legal tool to combat customs fraud through 
cooperation and the exchange of information between Member States and with the Commission. The 
Commission is currently carrying out a thorough evaluation of this Regulation with the main purpose 
of assessing whether the Regulation is still suitable and relevant for tackling challenges brought about 
by new customs fraud patterns. On the basis of the outcome of this evaluation, the Commission will 
decide whether there is a need to revise the Regulation. 

Action 2020-2021 

  Report on evaluation of Regulation (EC) No 515/97 by Q4 2020 
  Assess  the  need  to  update  Regulation  (EC)  No  515/97  to  address  modern  customs  fraud 

challenges – Q1 2021 

10) Involvement of customs in protecting the single market against the import of non-compliant 

and unsafe products  

A new regulation19 on market surveillance and compliance of products that will enter into application 
in 2021 will allow more effective controls on products entering the EU. The COVID crisis has again 
highlighted the threat posed by illegal products,  with multiple cases of dangerous, non-compliant or 
counterfeit  protective  equipment  shipped  from  third  countries  that  reached  the  Member  States.  The 
Commission  will  adopt  implementing  legislation  aimed  at  rendering  customs  intervention  and 
cooperation more  effective, including through  a  strengthened  risk management framework, and  will 
develop  a  new  interface  between  customs  and  market  surveillance  systems  at  EU  level  in  order  to 
support sharing of information. 

Actions: 2021 - 2025  

  The Commission will adopt implementing acts for the market surveillance regulation, aimed at 

addressing customs-related aspects, from 2021 onwards.  

  The Commission will, by 2025, develop a new interface at EU level between the Information 

18 Council Regulation (EC) No 515/97 of 13 March 1997 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 agricultural matters. OJ L 082 22.3.1997, p. 1, as amended. 
19 Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market surveillance and 
compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 765/2008 and (EU) No 305/2011. 
OJ L 169, 25.6.2019, p. 1–44 

11 

 
 
                                                           
and  Communication  System  for  pan-European  Market  Surveillance  (ICSMS)  and  the  EU 
Single Window environment for customs. 

11) Monitor the functioning of preferential trade arrangements  

The  EU’s  preferential  trade  arrangements  with  other  countries  are  essential  to  support  access  to 
external  markets  for  EU  producers  and  exporters  but  they  can  give  rise  to  trade  circumvention, 
through non-compliance with rules on preferential origin. The Commission will continue to monitor 
the  implementation  of  preferential  origin  rules  and  procedures  and  will  extend  the  scope  of  its 
monitoring activities to Free Trade Agreements to cover imports from main partner countries and EU 
export interests. This monitoring will be used to identify areas where the rules could be improved and 
updated.  In  addition,  the  Commission  will  enhance  the  tools  at  its  disposal  to  improve  cooperation 
with  all  actors  in  particular  beneficiary  countries’  authorities  and  exporters,  while  considering  how 
best  to  enforce  commitments  in  this  regard.  The  tools  will  include  enhanced  access  to  information, 
detailed guidance, technical assistance and training.  

The  ultimate  objective  is  to  safeguard  the  EU’s  own  resources  by  ensuring  that  preferences  are 
granted only to products genuinely entitled to them while guaranteeing the preferential access of EU 
products to partner countries’ markets. 

Action: 2021 onwards 

  The  Commission  services  will  from  2021  extend  their  monitoring  of  the  application  of 
preferential origin rules and procedures to Free Trade Agreements and will aim to resolve with 
the  countries  involved  issues  arising  related  to  weaknesses  and  shortcomings  in  the 
implementation of these rules and procedures.  
In case of a clear violation of the rules of origin in force and procedures, the Commission will 
launch  discussions  with  the  country  involved  and  use  the  mechanisms  provided  for  in  the 
context  of  the  preferential  arrangement  at  stake  to  restore  compliance  and  protect  the  EU’s 
financial interests. 

 

12) Analyse and, where appropriate, enhance the Union’s international systems of cooperation 

in customs matters with important trade partners, in particular China  

The Commission  will analyse and,  where appropriate, enhance the Union’s international  systems  of 
cooperation and mutual administrative assistance in customs matters with important trade partners and 
in multilateral fora. Improving cooperation and mutual administrative assistance with China is the first 
priority given the size of our bilateral trade and, in particular, the exponential growth of e-commerce 
shipments.  

As a second priority, the Commission will consider developing or enhancing cooperation with other 
trading partners taking into account criteria such as EU accession perspective, geographical proximity 
and  neighbourhood,  transit  lanes  and  EU  trading  interests.  This  cooperation  will  include,  where 
appropriate,  the  development  of  initiatives  such  as  facilitating   the  electronic  exchange  of  customs 
documents,  implementing  the  action  plan  on  product  safety  in  online  sales,  the  support  of  risk 
management  and  supply  chain  security  (such  as  customs-to-customs  information  exchanges,  mutual 

12 

 
 
 
 
recognition of Authorised Economic Operators and customs controls). The work may include a review 
of existing bilateral agreements with a view to strengthening elements concerning enforcement. 

Finally,  reinforced  customs  cooperation  may  also  benefit  partner  countries  by  facilitating  better 
domestic resource mobilisation in these countries.  

Action: 2020 - 2021 

  China: The EU is due to agree on a new Strategic Framework for Customs Cooperation 2021–
2024 with China before the end of 2020. In parallel, the Commission is evaluating the present 
customs  cooperation  and  mutual  administrative  assistance  agreement  with  China  in  order  to 
determine whether to seek negotiating directives to review the agreement. 

  The  Commission  will  at  the  end  of  2020  launch  a  comprehensive  analysis  of  the  Union’s 
system of international cooperation and mutual administrative cooperation in customs matters, 
with a view to proposing possible enhancements of a general or specific nature/scope in 2021. 

d) Customs working as one 

13) Enhance  cooperation  between  customs  and  security  and  border  management    authorities 

and synergies between their information systems  

It is imperative to close the gaps between customs information systems and other information systems 
designed  to  protect  the  EU’s  external  borders  and  enhance  internal  security.  The  aim  will  be  to 
counter  security  and  other  risks  at  borders,  for  the  benefit  of  all  citizens,  by  supporting  new 
cooperation  methods  and  cross-referencing  of  data  aimed  at  ensuring  coherent,  future-proof  actions 
across various competent authorities and avoid duplications of reporting arrangements.  

The Commission services are already working on the development of an interoperability framework 
for information systems for security, border and migration management. A group of security, border 
management and customs experts from Member States, convened by the Commission, has completed 
a preliminary assessment of the interoperability of those systems with customs systems in the field of 
security  and  security  risk  assessment.  This  assessment  recommends  in  particular  a  link-up  of  the 
Schengen Information System (SIS) and Europol data with the customs Import Control System (ICS2) 
that  will  be  deployed  in  three  phases  between  2021  and  2024.  According  to  the  experts, 
interoperability between these systems could enhance the management of security risks. Following the 
recommendation  of  the  experts,  the  Commission  will  contract  out  a  feasibility  study  to  assess  the 
opportunities  involved  in  interoperability  between  these  three  systems  and  the  related  financial, 
operational,  technical  and  legal  challenges,  including  data  protection  and  confidentiality  issues.  
Synergies between customs electronic systems other than ICS2 and systems operated by security and 
border management authorities should also be explored.  

Action: 2021- 2024 

  Completion  of  study  on  feasibility  of  developing  interoperability  between  the  Schengen 
Information System and Europol data with the customs Import Control System (ICS2) by end 
2021 with a view to completing any link ups by the time of final deployment of ICS2 (2024) 

13 

 
 
14) Customs Union Performance  

The Commission is working to formalise its tool for collecting annual and quarterly information from 
Member  States  on  data  of  customs-related  processes,  while  avoiding  duplication  with  reporting 
obligations in other policy areas relevant for customs. The voluntary basis for the current operation of 
the collection of “Customs Union Performance” data causes certain  deficiencies for the process  and 
also raises questions about data quality. More comprehensive reporting would improve benchmarking 
and  eventually  approximation  of  practices  between  different  jurisdictions;  it  would  also  provide 
important aggregated information contributing to analytical capabilities for risk assessments.  A legal 
framework  could  help  to  homogenise  practices  in  data  collection  at  national  level,  consequently 
enhancing  the  use  of  key  performance  indicators  and  helping  in  assessing  the  impacts  of  customs 
policy decisions. However, the need for a legal framework and possible alternative options must first 
be carefully considered. 

Action: 202l 

  Evaluation of whether the Customs Union has been hampered by the lack of a specific legal 
basis for periodic reporting on the Customs Union Performance to be addressed as part of the 
interim evaluation of the implementation of the Union Customs Code by end 2021  

15) Better equip Member States with modern and reliable customs control equipment  

The  Commission  has  proposed  a  financial  instrument20  to  allow  the  purchase,  maintenance  and 
upgrade of relevant, state-of-the-art and reliable customs control equipment (such as x-rays, scanners, 
handheld  devices  and  automated  recognition  of  number  plates  and  laboratory  equipment)  under  the 
next Multiannual Financial Framework (MFF) that should be adopted by end 2020.  

The availability of modern and reliable customs control equipment would help to address weak points 
of  entry/exit  of  goods  into  the  customs  territory  that  are  detrimental  to  the  protection  of  the  EU’s 
financial  interests,  safety  and  security  and  to  ensure  equivalent  levels  of  customs  controls  in  the 
future.  The  proposed  instrument  is  a  response  to  the  frequent  calls  from  many  Member  States  for 
financial  support  for  the  purchase  of  such  equipment.  It  is  therefore  essential  that  the  European 
Parliament  and  the  Council  agree  as  soon  as  possible  to  the  Commission  proposal  to  create  an 
instrument  for  funding  customs  controls  equipment  so  as  to  ensure  equivalent  results  of  customs 
controls among Member States. 

Action: 2021 

 

If  the  financial  instrument  is  adopted,  the  Commission  and  Member  States  will,  from  2021, 
use the programme to contribute to ensuring equivalent results of customs controls. 

20  COM(2018) 474 final of 12.6.2018 

14 

 
 
 
                                                           
16) Deploy  and  deepen  cooperation  mechanisms  under  the  Customs  programme  (MFF  2021-

2027)  

Under the next Multiannual Financial Framework (MFF) which should be adopted at the latest by end 
of 2020, the objective21 of the Customs programme is to support the functioning and modernisation of 
the Customs Union, also in order to strengthen the internal market. It aims at facilitating cooperation 
between  participating  countries,  their  customs  authorities  and  their  officials.  It  is  vital  that  this 
cooperation be improved and increased. 

In recent years, Member States have shown an increasing interest in enhanced operational cooperation 
between customs authorities on a geographical or thematic basis in the form of expert teams, one of 
the  tools  of  the  programme.  There  seems  to  be  a  true  appetite  and  need  for  an  extension  of  such 
operational cooperation to more areas such as e-commerce and to more participating countries.   

There  is  also  a  need  to  strengthen  the  profile  of  the  customs  profession  in  order  to  attract  the  best 
people  to  work  for  customs  and  for  common  approaches  to  training  including  for  the  purpose  of 
reducing costs. Ideas to be considered in this respect could include a “mobility” programme enabling 
customs  officers  to  work  anywhere  in  the  EU  with  mutual  recognition  of  qualifications  and  the 
development  of  EU-wide  common  training  and  human  capacity  building  for  customs  officials,  in 
cooperation where warranted with other agencies such as CEPOL22.  

Actions under the Customs programme may be complemented by technical support to Member States’ 
customs administrations under the Technical Support Instrument 2021-2027. 

Action: 2021 onwards 
  The  Commission  will  from  2021  (up  to  2028)  encourage  Member  States  to  make  increased 
use of the operational  cooperation and human capacity building  facilities under the Customs 
programme tools in as many areas as possible.  

17) Smarter management of the customs union  

In the past few months, in response to the Covid-19 pandemic, the Commission has adopted several 
legislative  actions  and  issued  guidelines  interpreting  legislation  to  assist  customs  authorities  and 
traders during the crisis.  In addition, the upcoming evaluation of the Union Customs Code will aim to 
establish whether the Code is sufficiently flexible to deal with the management of customs formalities 
during times of crisis. However, there have been suggestions that there is a need for solutions that go 
beyond the Code. There is also an appetite for a continuation of discussions, following the foresight 
exercise, on the related subject of ensuring that the Customs Union is better prepared for the future.  

In  the  light  of  these  developments,  the  Commission  proposes  to  establish  a  reflection  group  of 
Member States and stakeholders under the customs programme to consider how to make the Customs 
Union  smarter,  more  agile,  more  technologically  advanced  and  more  crisis-proof.  Ideas  to  be 
considered could include ways to better forecast and anticipate problems, rapid reaction mechanisms, 
lessons to be learnt from the Covid-19 crisis and exploring how best to ensure that the Customs Union 

21  COM(2018) 442 final of 8.6.2018 
22 The European Agency for Law Enforcement Training 

15 

 
 
                                                           
fulfils its objectives. 

In addition, it may be time to consider a more operational framework for customs activities. Taking 
into account the limits imposed by the Treaty on conferring certain powers to an agency, an agency 
structure  could  be  explored.  To  that  end,  the  Commission  will  in  due  course  launch  an  impact 
assessment  to  determine  whether  an  EU  customs  agency  (either  a  new  one  or  part  of  an  existing 
agency)  with  appropriate  powers  could  allow  a  better  and  more  coordinated  operational  customs 
response to crises and allow monitoring of trends and patterns and identification of vulnerabilities.  

In  addition,  the  impact  assessment  will  endeavour  to  establish  whether  an  agency  could  allow  the 
management, storage, greater development and effective sharing of data analytics for the assistance of 
all Member States in their risk management and anti-fraud activities and could also help to ensure the 
application  of  an  effective  and  uniform  approach  to  risk-management  through  the  EU  customs 
territory.  The  assessment  would  also  determine  whether  the  management,  development  and 
maintenance of customs electronic systems would be improved if they were handled by an EU agency, 
reducing the costs that Member States face if they fund those systems individually. The Commission 
would  also  assess  whether  an  agency  could  provide  a  formal  structure  for  cooperation  between 
Member States in customs controls and for rapid reaction cross-national expert teams when the need 
arises,  help  to  promote  the  customs  profession  and  reduce  training  costs  for  Member  States,  via 
mobility  programmes  and  common  training.  In  deciding  whether  an  agency  is  the  way  forward, 
careful consideration would need to be given to the synergies and potential for overlap with existing 
law enforcement agencies. 

Action: 2021 - 2023 

  Reflection group of Member States and stakeholders on foresight/crisis management – launch 

 

in early 2021 
In 2022, the Commission will launch an impact assessment, with an outcome by 2023, on the 
pros and cons of an agency approach covering a number of customs cooperation domains, so 
as  to  decide  whether  to  propose  such  an  agency  under  the  next  Multiannual  Financial 
Framework  

V. 

Conclusion  

This  Action  Plan  has  set  out  an  ambitious  series  of  actions  aimed  at  ensuring  a  more  coherent  and 
stronger  Customs  Union  responding  to  four  areas  of  intervention:  risk  management,  e-commerce, 
compliance, and the Customs Union acting as one. The Commission has drawn up this plan for work 
for the period up to 2025 having regard to the views of Member States and stakeholders in the various 
consultation formats described throughout the Communication. It is in line with the long-term vision 
of  the  Customs  Union  established  in  the  foresight  exercise  and  it  acknowledges  the  impact  that  the 
Covid-19 crisis has had on customs authorities and economic operators.  

A  central  focus  of  the  activity  will  be  the  addition  of  an  EU  layer  of  data  analytics  capabilities  to 
support  all  Member  States  in  risk  analysis  and  by  extension  in  control  effectiveness.  The  aim  is  to 
support  and  strengthen  different  risk  and  control  aspects  in  order  to  reinforce  the  whole  structure, 
reduce costs for Member States and further facilitate legitimate trade.  

16 

 
 
 
It  is  essential  to  underline  that  the  sizing  and  feasibility  of  some,  although  not  all,  of  the  proposed 
actions will be determined by the final outcome of the negotiations for the next Multiannual Financial 
Framework, from both the administrative and operational budget angle. It is also essential to note that 
Member  States  will  have  a  significant  role  to  play  and  will  need  to  make  available  the  necessary 
resources at national level. Should these conditions not be met, it will not be possible to develop all of 
these actions. 

The Commission wishes to continue discussing with Member States ways to make the Customs Union 
smarter, more agile and more crisis-proof. In the medium term, the Commission wishes to explore the 
idea  of  establishing  a  customs  agency  to  make  the  management  of  the  Customs  Union  more  cost-
effective  and  efficient,  eliminate  duplications  of  costs  between  the  Member  States  and  ensure  more 
effective and rapid reactions to crises.  

The Commission invites the European Parliament and the Council to support this Action Plan. 

17 

 
 
 
 
APPENDIX: list of actions and timelines  

2020 
1.  Joint analytics capabilities: data analysis to extract trends, using EU Surveillance: ongoing  
2.  Single Window environment for Customs - Legislative proposal: Q4 2020 
3.  Review of Regulation 515/97 on customs fraud: Q4 2020 
4.  China: International cooperation: New strategic framework with China: end 2020 
5.  Launch analysis of Union’s system of international cooperation in customs matters: end 2020 

2021 

1.  Joint analytics capabilities: use of Surveillance data to support correct implementation of the 

Union tariff  

2.  Revised risk management strategy: Q2 2021 
3.  Assess need to update Regulation 515/97 to address customs fraud challenges: Q1 2021 
4.  AEO programme:  possible legislative proposal  for more precise monitoring obligations Q2/3 

2021 

5.  AEO programme: Updated guidelines: Q2/3 2021 
6.  Interim evaluation of the Union Customs Code: Q4 2021 
7.  Market surveillance regulation – implementing acts for customs aspects: from 2021 
8.  Preferential trade arrangements – step up monitoring : from 2021 onwards 
9.  Possible  enhancements  to  international  cooperation  and  mutual  administrative  assistance  in 

customs matters, based on the results of the analysis : to start in 2021  

10. Customs Union Performance – evaluation of problems of no legal base:  end 2021  
11. Common system of sanctions – guidelines: Q4 2021 
12. Customs control equipment: work on financing equipment to start from 2021 
13. New customs programme: enhanced cooperation to start from 2021  
14. Launch analysis of impact of e-commerce on customs duty collection/level playing field 
15. Study on interoperability between customs and border systems: end 2021 
16. Reflection group on foresight/crisis management – launch in early 2021 

1.  Customs access to Eurofisc tax data hub 
2.  Common system of sanctions – reflection on legislation 

2022 

2023 

1.  Joint analytics capabilities: start combining data from Surveillance with data from other new 
and existing electronic systems; ICS2 analytics on pre-loading and pre arrival data for postal, 
express and cargo air carriers. 

2.  Customs obligations for e-commerce platforms – proposal for reporting: Q1 2023  
3.  Customs agency - completion of impact assessment 

1.  Joint  analytics  capabilities:  ICS2  analytics  of  pre-loading  and  pre-arrival  data  for  maritime, 

road and air carriers & logistic providers  

2.  Cooperation & interoperability with security and border management authorities –timeline for 

2024 

link ups (in line with final deployment of ICS2) 

3.  Customs access to VAT payment data 

2025 

1.  New interface between  the Market Surveillance system (ICSMS) and the EU Single Window 

environment for customs. 

18