COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing the European Union Single Window Environment for Customs and amending Regulation (EU) No 952/2013
Date: 2020-10-28
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU customs procedure, administrative cooperation, customs cooperation, customs regulations, electronic government, exchange of information, information system

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.10.2020  SWD(2020) 238 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council  establishing the European Union Single Window Environment for Customs and amending Regulation (EU) No 952/2013 {COM(2020) 673 final} - {SEC(2020) 360 final} - {SWD(2020) 237 final} - {SWD(2020) 239 final}  
 
 
TABLE OF CONTENT 

1. 

2. 

INTRODUCTION: POLITICAL, LEGAL CONTEXT AND VISION STATEMENT ................................................. 3 

PROBLEM DEFINITION ............................................................................................................................ 5 

2.1 
 WHAT ARE THE PROBLEMS? ............................................................................................................................ 5 
2.2  WHAT CAUSES THE PROBLEM? ......................................................................................................................... 8 
2.2.1 
OVERALL CONTEXT .................................................................................................................................... 8 
PROBLEM DRIVERS .................................................................................................................................. 10 
2.2.2 
2.3  WHAT ARE THE CONSEQUENCES AND SIZE OF THE PROBLEM? ............................................................................... 11 
DELAYS AND INEFFICIENT USE OF FINANCIAL AND HUMAN RESOURCES ............................................................... 11 
2.3.1 
INEFFECTIVE APPLICATION OF RULES IN THE EU SINGLE MARKET AND BEYOND ..................................................... 13 
2.3.2 
2.4  AFFECTED STAKEHOLDERS ............................................................................................................................. 17 
2.5  HOW WILL THE PROBLEM EVOLVE? ................................................................................................................. 17 

3.  WHY SHOULD THE EU ACT? .................................................................................................................. 18 

3.1 
 LEGAL BASIS ............................................................................................................................................... 18 
3.2  SUBSIDIARITY: NECESSITY AND ADDED VALUE OF EU ACTION ................................................................................ 18 

4. 

OBJECTIVES: WHAT IS TO BE ACHIEVED? .............................................................................................. 20 

4.1 
 GENERAL OBJECTIVES .................................................................................................................................. 20 
4.2  SPECIFIC OBJECTIVES .................................................................................................................................... 20 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ...................................................................................... 21 

5.1 
 WHAT IS THE BASELINE FROM WHICH OPTIONS ARE ASSESSED? ............................................................................ 21 
5.2  ONGOING IMPACTS WITHOUT ANY FURTHER EU POLICY ACTION ........................................................................... 23 
5.3  DESCRIPTION OF THE POLICY OPTIONS.............................................................................................................. 25 
GROUP I: GOVERNMENT-TO-GOVERNMENT (G2G)....................................................................................... 26 
5.3.1 
GROUP II: BUSINESS TO GOVERNMENT (B2G) ............................................................................................. 29 
5.3.2 
5.3.3 
GROUP III: CROSS-CUTTING OPTIONS FOR REGISTRATION AND IDENTIFICATION OF ECONOMIC OPERATORS ............... 30 
5.4  OPTIONS DISCARDED AT AN EARLY STAGE ......................................................................................................... 31 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................................. 34 

6.1  APPROACH TO THE ANALYSIS OF THE OPTIONS ................................................................................................... 34 
6.2  ANALYSIS OF THE IMPACTS OF THE POLICY OPTIONS ............................................................................................ 38 

HOW DO THE OPTIONS COMPARE? ...................................................................................................... 59 

PREFERRED OPTION .............................................................................................................................. 68 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ........................................................ 69 

7. 

8. 

9. 

ANNEX 1: PROCEDURAL INFORMATION ......................................................................................................... 71 

ANNEX 2: STAKEHOLDER CONSULTATION ...................................................................................................... 79 

ANNEX 3: WHO IS AFFECTED AND HOW? ....................................................................................................... 90 

ANNEX 4: ANALYTICAL METHODS .................................................................................................................. 94 

ANNEX 5: ACRONYMS .................................................................................................................................... 95 

ANNEX 6: GLOSSARY ...................................................................................................................................... 98 

Page 1 / 237 

 
ANNEX 7: OVERALL VOLUMES OF EU SUPPORTING DOCUMENTS ................................................................ 102 

ANNEX 8: CATEGORISATION OF REGULATORY FORMALITIES ....................................................................... 104 

ANNEX 9: SINGLE WINDOW INITIATIVES AT NATIONAL LEVEL ..................................................................... 110 

ANNEX 10: SINGLE WINDOW INITIATIVES AT INTERNATIONAL LEVEL .......................................................... 118 

ANNEX 11: NUMBER OF DECLARATIONS COVERED BY OPTIONS 1, 2 AND 6 ................................................ 123 

ANNEX 12: ANALYSIS OF THE DISCARDED POLICY OPTIONS ......................................................................... 126 

ANNEX 13: COMPARISON OF ECONOMIC IMPACTS FOR ALL OPTION PACKAGES ......................................... 128 

ANNEX 14: EVALUATION OF THE EU CSW-CVED PILOT AND EU CSW-CERTEX PROJECT ................................ 131 

ANNEX 15: ASSESSMENT OF IMPACTS RELATED TO INFORMATION AND COMMUNICATION TECHNOLOGIES 
AND SYSTEMS .............................................................................................................................................. 152 

ANNEX 16: COUNTRY CASE STUDY REPORTS ................................................................................................ 153 

ANNEX 17: OVERVIEW OF POLICY OPTIONS ................................................................................................. 236 

Page 2 / 237 

 
 
 
 
1.  INTRODUCTION: POLITICAL, LEGAL CONTEXT AND VISION STATEMENT 

The EU Customs Union is a fundamental aspect of the European Union and the management 
of  external  borders  is  of  crucial  importance  in  ensuring  the  health  and  prosperity  of  EU 
citizens  and  businesses.  The  Covid-19  pandemic  has  made  it  more  important  than  ever  to 
establish a stronger framework for the Customs Union and to ensure more effective controls 
while  facilitating  trade  especially  in  times  of  emergency.  This  involves  not  only  customs 
formalities, but also multiple non-customs regulatory requirements that certain goods are also 
subject  to  at  the  border  in  policy  domains  such  as  health  and  safety,  the  environment, 
agriculture, etc. 

The  customs  administrations  and  competent  authorities  in  charge  of  enforcing  non-customs 
regulatory formalities (hereafter ‘partner competent authorities’) have worked mostly in silos. 
Most  e-government  initiatives  have  preserved  the  silos  inherited  from  manual  processes, 
leading  to  the  development  of  many  electronic  systems  of  varying  interoperability.  In  the 
customs domain, the Customs Union has undergone a number of modernisation steps since its 
creation. The design and deployment of the 17 Union Customs Code (UCC)1 systems aim to 
consolidate  the  digitalised  EU  Customs  Union,  enabling  the  electronic  processing  of  more 
than 99% of all customs declarations. President von der Leyen recently proposed2 equipping 
the  Customs  Union  with  a  stronger  framework  to  better  protect  EU  citizens  and  the  single 
market and using an integrated European approach to reinforce customs risk management and 
support effective controls by the Member States. In response, the EU Commission (hereafter 
‘the  Commission)  is  preparing  an  Action  Plan  that  includes  the  implementation  of  an  EU 
Single Window Environment for customs over the next decade. 

                        Figure 1: Path to the Customs Union digital modernisation 

This  digitalisation  process  is  ongoing  at  a  varying  pace  in  the  different  policy  areas 
interacting with customs at the border and requires breaking existing silos to facilitate trade 
and enhance controls. In recent years, single window initiatives have gained momentum as a 
way of doing this within and across EU. The vision of the EU Single Window environment 
for customs is designed to coordinate customs  and partner competent authorities at the 
border to eliminate these silos.  

1   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. 1–101 

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

Page 3 / 237 

 
 
 
 
                                                 
There  is  a  short  window  of  opportunity  to  advance  this  initiative  before  Member  States 
establish  distinctly  different  and  non-harmonised  single  windows,  increasing  the  risk  of  an 
uneven playing field for economic operators and citizens across the EU. The establishment of 
the  EU  Single  Window  environment  for  customs  is  envisaged  as  an  ‘evolution,  not  a 
revolution’  approach.  The  strategy  will  build  on  existing  solutions  to  develop  a  framework 
for  digital  cooperation  with  partner  competent  authorities  that  would  encompass  their 
regulatory  formalities  over  time  once  the  respective  sectorial  legislation  and  operational 
Information and Communication Technology (ICT) aspects are in place. The objective of this 
initiative is not to revise the sectorial legislation, which falls under different areas of Union 
competence.  Instead,  it  sets  the  appropriate  conditions  for  digital  collaboration  between 
customs and partner competent authorities.   

The  Commission  and  EU  Member  States  have  made  a  number  of  commitments  to  develop 
harmonised  single  window  services  at  EU  level.  The  2008  e-Customs  Decision3  on  a 
paperless environment for customs and trade called on the Member States and Commission to 
“endeavour  to  establish  and  make  operational  a  framework  of  single  window  services”. 
However,  the  evaluation  of  the  e-Customs  Decision  in  20144  found  these  provisions 
insufficiently  concrete  and  recommended  the  adoption  of  a  new  legal  instrument  for  the 
single  window.  The  2014  Venice  Declaration5  proposed  a  progressive  action  plan  to 
implement  an  EU  Single  Window  environment  for  customs  and  to  develop  its  legal 
framework.  In  addition,  in  2016  the  Communication  from  the  European  Commission  on 
“Developing  the  EU  Customs  Union  and  its  Governance”6  announced  the  Commission’s 
plans  to  explore  a  workable  solution  for  the  development  and  creation  of  an  EU  Single 
Window  environment  for  customs.  This  position  was  supported  by  the  ECOFIN  Council 
Conclusions of March 20177 which requires the signatory parties to “make their best efforts 
to establish single windows”. This is also in line with the 2017 Trade Facilitation Agreement 
of the World Trade Organization (WTO), which requires the signatory parties such as the EU 
to “make their best efforts to establish single windows”. Some of EU’s main trading partners 
have embarked on ambitious single window initiatives, while other countries are building the 
foundation for future implementation8.  

In line with these priorities, the Commission launched a pilot project (“EU Customs Single 
Window-Common  Veterinary  Entry  Document”  ‘EU  SW-CVED’)  in  2015  to  provide  an 
interface between national customs systems  and a certification system at  EU level9  through 
the central information technology (IT) solution of the Directorate-General for Taxation and 
Customs  Union  (DG  TAXUD).  This  project  enabled  the  automated  verification  of  three 
health  certificates  by  five  Member  States’  customs  administrations,  participating  on  a 
voluntary basis. The “EU Customs Single Window-Certificates Exchange project” (hereafter 
‘EU CSW-CERTEX’), launched in 2017, expanded the pilot and enhanced its functionality. 
By  the  end  of  2018,  new  certificates  were  introduced,  and  the  number  of  participating 
Member States increased from five to nine. EU SW-CVED and EU CSW-CERTEX can be 

3   Decision No70/2008/EC of the European Parliament and of the Council of 15 January 2008 on a paperless environment 

for customs and trade, OJ L 23, 26/01/2008, p. 21-26. 

4   Evaluation  of 

the  electronic  customs 

implementation 

in 

the  EU  Final 

report 

(21 

January  2015).  

https://ec.europa.eu/taxation_customs/sites/taxation/files/docs/body/ecust_evaluation_final_en.pdf  

5   http://data.consilium.europa.eu/doc/document/ST-16507-2014-INIT/en/pdf   

(The Venice Declaration is annexed to the December 2014 Council Conclusions). 

6   COM (2016) 813 final 
7   http://data.consilium.europa.eu/doc/document/ST-7585-2017-REV-1/en/pdf 
8   An overview of these initiatives is provided in Annex 10. 
9   TRAde Control and Expert System (TRACES) 

Page 4 / 237 

 
 
                                                 
considered as a blueprint for this initiative. An evaluation of EU SW-CVED and EU CSW-
CERTEX carried out by DG TAXUD (hereafter ‘the evaluation’)10 is included in Annex 14.  

The  scope  of  the  EU  Single  Window  environment  for  customs  extends  beyond  the  field  of 
customs. Its establishment builds upon the UCC’s digital transformation approach to take the 
Customs Union to the next level of modernisation by digitally connecting customs and non-
customs  domains.  The  ongoing  Covid-19  crisis  has  created  challenges  for  government 
authorities  and  trade  to  realise  full  digitalisation  of  the  entire  supply  chain.  Establishing  an 
EU Single Window environment for customs will provide a solution for digital collaboration 
between  customs  and  partner  competent  authorities  in  response  to  part  of  the  challenges 
raised  by  such  crises.  This  collaboration  will  enhance  trade  facilitation,  while  ensuring  the 
safety and security of European citizens in the single market. 

2.  PROBLEM DEFINITION 

2.1  What are the problems? 

In  2018,  the  EU  was  the  second  largest  exporter  and  importer  of  goods  in  the  world,  with 
extra-EU  trade  accounting  for  16%  of  export  and  15%  of  import  globally.  In  handling  the 
high volume of imported and exported goods, the role of customs serves two main purposes: 
it  implements  customs  and  trade-related  legislation  in  line  with  the  provisions  of  the  UCC, 
and it enforces many non-customs regulatory requirements for specific goods at the external 
borders. The laws governing non-customs regulatory requirements11 are the result of specific 
policies established in different domains of EU competence under the Treaties, such as health 
and  safety,  environment  protection,  fisheries,  agriculture,  market  surveillance,  etc.  They 
impose  different  obligations  for  the  import,  export  or  transit  of  specific  goods  and  create 
specific administrative procedures. These have been designed independently and are mostly 
run in a non-coordinated manner, overlapping to a certain extent. This generates complex and 
burdensome reporting obligations  for traders and poses a significant  barrier to  the effective 
enforcement of the regulatory formalities at stake. 

This impact assessment defines as the main problems (as established by the external study to 
support  the  impact  assessment)12:  (1)  fragmented  interoperability  between  customs  and 
partner  competent  authorities  responsible  for  regulatory  formalities  required  for  the 
international  trade  in  goods,  and  (2)  duplication  of  information  and  procedural 
redundancies in the fulfilment of these formalities.  
The fragmented interoperability13 between regulatory authorities involved in the clearance 
of  goods  is  a  major  obstacle  to  progress  on  the  digital  single  market  and  to  achieving  an 
integrated,  coordinated  border  management.  Interoperability  is  defined  by  the  European 
Interoperability  Framework14  as  “the  ability  of  organisations  to  interact  towards  mutually 
beneficial  and  agreed  common  goals,  involving  the  sharing  of  information  and  knowledge 
between  these  organisations,  through  the  business  processes  they  support,  by  means  of  the 

10   See Annex 14 for a summary of the evaluation.  
11   https://ec.europa.eu/taxation_customs/sites/taxation/files/prohibition_restriction_list_customs_en.pdf  
12   The  problems  were  examined  extensively  in  an  external  study  commissioned  by  DG  TAXUD  to  support  the  impact 
assessment. Among other things, the study assessed the current situation by evaluating existing action in the form of the 
EU SW-CVED pilot and EU CSW-CERTEX. DG TAXUD commissioned an external study to evaluate the EU CSW-
CVED  pilot  and  EU  CSW-CERTEX  and  to  support  the  impact  assessment.  The  external  study  report  was  written  by 
Oxford  Research,  Coffey,  Economisti  Associati  and  wedoIT.  The  final  report  and  the  executive  summary  have  been 
published in: https://tinyurl.com/yd56kk5r  

13   According  to  the  European  Interoperability  Framework,  an  interoperability  model  includes  four  layers:  legal 

interoperability, organisational interoperability, semantic interoperability and technical interoperability.   

14   https://ec.europa.eu/isa2/sites/isa/files/isa_annex_ii_eif_en.pdf 

Page 5 / 237 

 
 
                                                 
exchange of data between their ICT systems.” The use of IT systems is a prerequisite for such 
interoperability.  The  increased  digitisation  of  customs15  and  partner  competent  authorities16 
creates opportunities to promote the digital exchange of data between each other for a fully 
coordinated  and  efficient  goods  clearance  process.  However,  there  is  no  domain-specific 
interoperability  framework  to  support  interaction  between  customs  and  partner  competent 
authority  systems.  This  means  that,  while  electronic  systems  are  in  place  for  some  policy 
areas,  customs  authorities  still  rely  on  manual  documentary  controls  to  verify  certain  non-
customs  formalities17.  These  manual  checks  take  time  and  resources  and,  compared  to 
automated checks, are more prone to error and fraud (see section 2.3.1). In addition, the lack 
of interoperability prevents the possibility of streamlining and integrating customs and non-
customs procedures. To give an indication of the scale of the problem, non-customs reporting 
formalities associated with the import and export of various goods apply to a sizeable portion 
of  imports  and  exports  at  EU  level:  this  applies  to  up  to  39.7  million  customs  declarations 
annually18.  
In part for this reason, 93% of economic operators19 participating in the public consultation 
carried out for this impact assessment considered that the “promotion of electronic means to 
exchange information” should be one of the most important priorities for potential EU action. 
This  shows the significance of this problem  for  economic operators dealing with  the cross-
border movement of goods. Fragmented interoperability also poses a significant barrier to the 
enforcement of certain regulatory formalities. In particular, this is because partner competent 
authorities lack systematic and automated feedback on the use of the supporting documents 
they issue.  

Box 1: Evidence of fragmented interoperability  

Fragmented interoperability (CVED-A, CVED-P and CED certificates) 

For those Member States that have put in place a solution for the automated verification of 
Common Veterinary Entry Documents for Animals (CVED-A), for products of animal Origin 
(CVED-P),  and  of  Common  Entry  Documents  for  Feed  and  Food  of  non-Animal  Origin 
(CED),  the  existing  arrangements20  have  improved  clearance  procedures.  However, 
interoperability between customs and non-customs authority systems is limited. This hinders 
the effective monitoring  on the use of these certificates and increases the risk of fraud (see 
section 2.3).  

Lack of interoperability (export and import of hazardous chemicals) 

15   The application of the Union Customs Code (UCC) governing customs operations in the EU as of 1 May 2016 represents 
a large scale streamlining that has facilitated the uniform application of customs law in the EU and the transition to an 
interoperable  electronic  customs  environment  (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. 1–101). 

16   In other policy areas  affecting international trade, there is a clear trend towards digitalisation of regulatory  formalities 

(see section 2.2.2). 

17   This depends largely on the extent of digitalisation at national level and progress with national single window initiatives. 
For example, Common Veterinary Entry Documents in most Member States require paper certificates, while Italy  uses 
only digital certificates as part of its national single window.  

18   2016 declarations data from DG TAXUD and feedback from Member State administrations. 
19   252 respondents to the public consultation rated this as very important and 71 as somewhat important. This percentage is 

based on the 349 total number of trade respondents. 

20   EU  CSW-CERTEX  and  some  national  single  window  solutions  enable  the  electronic  exchange  of  these  documents 

between customs and partner competent authorities’ systems. 

Page 6 / 237 

 
 
                                                 
Customs is  responsible for enforcing the obligations specified in  Regulation 649/201221 for 
the  export  of  hazardous  chemicals.  Some  of  these  chemicals  are  subject  to  an  export 
notification  and  Prior  Informed  Consent  (PIC)  from  the  importing  country  outside  the  EU. 
These procedures are managed by the European Chemicals Agency (ECHA) through the PIC 
IT  system  (ePIC).  Customs  must  check  the  inclusion  and  validity  of  the  Reference 
Identification Number (RIN) of the export notification, referenced as a supporting document 
to  the  customs  declaration.  Although  this  is  available  electronically,  ePIC  and  customs 
systems  are  not  interoperable,  meaning  that  customs  authorities  need  to  check  the  ePIC 
system manually. A recent study22 on the enforcement of Regulation 649/2012 revealed that 
this had not been done in 44% of the cases. Automatic checks would ensure that necessary 
checks are carried out in addition to increasing efficiency. 

Duplication  of  information  and  procedural  redundancies  is  another  dimension  of  the 
problem.  The  different  regulatory  frameworks  introduce  data  requirements  and  business 
processes, which are not harmonised with the customs ones. Differences in data sets inhibit 
exchange  across  competent  authorities  and  at  EU  /  Member  State  level,  making  operators 
submit  the  same  information  several  times.  On  the  other  hand,  lacking  data  harmonisation 
serves  as  a  barrier  to  the  re-use  of  data.  This  is  a  significant  drag  on  the  supply  chain, 
diverting resources that could have been deployed elsewhere. Indeed,  81% of the economic 
operators responding to the public consultation cited “submission of the same information to 
more authorities” as negatively impacting the movement of goods.  

Box 2: Duplication of information and procedural redundancies  

One  representative  from  a  trade  association  participating  in  the  EU  Customs  Single 
Window project group stated that “duplication and inefficiencies caused by the absence of 
harmonised procedures and systems amongst Member States are an economic drag on the 
whole supply chain”. 

A customs policy adviser working for a Dutch company interviewed for the external study 
provided  the  example  of  aluminium.  When  importing  aluminium  from  certain  third 
countries,  economic  operators  must  apply  for  a  paper  document  to  facilitate  the 
Commission’s  monitoring  of  this  type  of  product23.  Nearly  all  of  the  information  is  also 
provided  in  the  customs  declaration.  The  Spanish  customs  authority  confirmed  that  the 
overlap of information is 92%.  

The  Spanish  customs  authority  further  confirmed  that  about  30%  of  the  customs 
declarations  affected  by  non-customs  regulatory  formalities  require  more  than  one 
supporting  document  from  partner  competent  authorities,  creating  high  potential  for 
duplication of information across these different requirements. For example, the import and 
export of  shark fins  could be subject  to  four different  certificates to  comply with  the EU 
tariff and trade legislation measures24 for this commodity. 

In  addition  to  the  identified  problems,  the  problem  tree  in  the  figure  below  depicts  an 
overview  of  the  underlying  drivers  (i.e.  root  causes)  and  consequences  for  stakeholders,  as 

21   Regulation (EU) No 649/2012 of the European Parliament and of the Council of 4 July 2012 concerning the export and 

import of hazardous chemicals, OJ L 201, 27.7.2012, p. 60–106. 

22   https://echa.europa.eu/documents/10162/0/forum_project_on_control_of_pic_en.pdf/ 
23   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R0640  
24   The  integrated  Tariff  of  the  EU  (TARIC)  is  a  multilingual  database  integrating  all  measures  relating  to  EU  customs 
tariff,  commercial  and  agricultural  legislation.  The  integration  and  coding  of  these  measures  facilitates  their  uniform 
application by all Member States and gives economic operators a clear view of requirements needed for the import or 
export of goods into and from the EU.  

Page 7 / 237 

 
 
                                                 
well as key contextual factors. Each of these other aspects is described in detail over the next 
pages.  

Figure 2: Problem tree 
Source: DG TAXUD 

2.2 What causes the problem? 

2.2.1  Overall context 

This  initiative  focuses  on  the  customs  clearance  process  of  goods  subject  to  non-customs 
regulatory formalities. The key underlying drivers  linked to the identified problems are:  (1) 
complex and fragmented goods clearance, and (2) insufficient cooperation and coordination 
between  the  regulatory  authorities  involved  in  goods  clearance.  To  better  understand  these 
drivers,  it  is  important  to  consider  the  fundamental  contextual  factors  surrounding  the 
clearance of these specific goods, including the existing  complexity of the regulatory and 
political  frameworks  along  with  the  uneven  state  of  digitalisation  of  the  different 
regulatory authorities. The interaction between these factors provides the overall context for 
identifying the problem drivers.   

Page 8 / 237 

 
 
  
  
The regulatory complexity stems from a large number of regulatory formalities required 
for  international  trade25.  National  customs  authorities  and  partner  competent  authorities 
enforce over 60 EU acts at the EU’s external borders26. In addition, Member States introduce 
national requirements in accordance with Article 36 of the Treaty on the Functioning of the 
European  Union  (TFEU)27.  To  meet  these  regulatory  formalities,  economic  operators  must 
often  provide  supporting  documents  to  the  customs  declaration  as  evidence  of  compliance. 
These supporting documents can be grouped into several categories (see Annex 8), depending 
on whether they relate to EU or national legislation, and whether the documents or the data 
are available at the national or EU level.  

EU  regulatory  requirements  and  associated  mandatory  supporting  documents  vary 
significantly by Member State, in  line with  their different  trading profiles, both  in  terms  of 
type  and  volumes  of  goods  traded.  Based  on  estimates  by  partner  Directorates-General 
(DGs), the overall volumes of data available for supporting documents in the past few years 
indicate that these are required in large numbers, particularly in some countries (see Annex 
7).  

The  political  complexity  results  from  the  diverse  implementation  schemes  within  the 
regulatory framework governing goods clearance. Most notably, this is linked to the internal 
organisation  of  the  Member  States,  meaning  that  the  division  of  competences  between  the 
multiple partner competent authorities involved in the management of non-customs regulatory 
formalities  varies  significantly  across  Member  States  according  to  national  specificities. 
Adding  to  this  complexity  are  the  differing  priorities  and  resources  for  customs  and 
partner  competent  authorities.  Customs  authorities  are  unique  for  their  comprehensive 
insight  on  regulatory  requirements  for  international  trade  and  the  concerns  economic 
operators face.  In contrast, partner competent authorities lack a clear picture on the broader 
set of administrative burdens related to  goods clearance due to the specialist nature of their 
policies.  In  addition,  the  different  comparative  advantages  and  trading  profiles  among 
Member  States  lead  to  differing  objectives  in  terms  of  balancing  trade  facilitation  with 
customs controls28. 

The uneven state of digitalisation of partner competent authorities involved in the clearance 
of  goods  adds  to  the  regulatory  and  political  complexity  surrounding  goods  clearance  and 
would  need  to  be  considered  as  part  of  any  future  attempt  to  improve  digital  collaboration 
between  customs  and  partner  competent  authorities.  This  will  be  pursued  by  building  on 
existing  systems  and  providing  a  framework  that  would  progressively  encompass  sectorial 
regulatory requirements as they become digitalised.  

25   Given  that  traded  goods  are  highly  diverse,  the  analysis  is  conducted  per  non-customs  regulatory  formality  and  the 
identified problems are addressed based on categories of these formalities. See Annex 8 for a comprehensive list of these 
categories of non-customs regulatory formalities in the scope of this initiative.   

26   This number reflects the official list of prohibitions and restrictions. In reality, the number of rules to be enforced at the 
EU’s external borders is even higher. For instance, the requirements for market surveillance and product compliance laid 
down in Regulation (EC) N°765/2008 (to be replaced in 2021 by Regulation (EU) 2019/1020) are one of the 60 elements 
of prohibitions and restrictions but they relate to the enforcement of more than 100 pieces of EU legislation regulating 
products.   

27    Treaty on European Union and the Treaty on the Functioning of the European Union, Official Journal C 326, 26/10/2012 

P. 0001 – 0390. 

28   For example, the Netherlands is a transport hub that handles the EU’s highest volume of maritime freight, most of which 
is destined for other Member States. In contrast, goods arriving in Italy are typically for domestic consumption, while it 
produces  large  volumes  of  agricultural  and  manufacturing  products.  This  naturally  leads  to  differences  in  national 
priorities at the border, with the Netherlands placing a higher weight on its competitive advantage in logistics while Italy 
prioritises the avoidance of unfair competition from illegitimate traders. 

Page 9 / 237 

 
 
                                                 
2.2.2  Problem drivers 

Problem driver 1: Complex and fragmented goods clearance 

The  fact  that  customs  and  sectorial  legislation  have  developed  independently  has  led  to 
isolated administrative procedures which are run sequentially and overlap to a certain extent. 
This fragmented model of regulatory compliance creates a complex and challenging path for 
economic  operators  to  import  or  export  certain  goods.  They  must  communicate  separately 
with both customs and non-customs authorities to place the goods under a specific customs 
procedure and wait for validated supporting documents29 from the relevant partner competent 
authority before starting the customs declaration process where they have to submit those at 
the  request  of  the  customs  authority.  This  is  a  major  obstacle  to  streamline  the  import  or 
export  of  affected  goods  (see  box  5).  The  progressive  digitalisation  of  the  authorities 
concerned and the possibility of electronic information sharing between them has opened up 
new opportunities to improve this situation as depicted in the figure below.  

Figure 3: Complex and fragmented goods clearance 
Source: DG TAXUD  

Problem  driver  2:  Insufficient  cooperation  and  coordination  between  regulatory 
authorities involved 

Another  underlying  driver  is  the  insufficient  cooperation  and  coordination  between  the 
different  authorities  responsible  for  goods  clearance  that  typically  operate  in  institutional 
silos.  Interviews  in  eight  Member  States  with  relevant  authorities  suggested  that  close 
cooperation  was  not  the  norm  and  required  commitment  and  resources  from  both  sides  to 
develop integration.  

Where  formal  cooperation  has  been  developed,  it  is  typically  limited  to  certain  competent 
authorities.  For  instance,  agreements  are  in  place  in  Romania  between  customs  and  the 
Ministry of Health to allow for a coordinated control for goods requiring CVEDs. Likewise, 
Irish Customs is collaborating with the Department for Agriculture, Fisheries and the Marine 
for  coordination  of  goods  requiring  CVEDs.  Member  States  implementing  national  single 
window initiatives (France, Spain, and Italy) have managed to put in place more agreements 
for digital cooperation, but these are exceptions.  

Feedback from stakeholders suggests that, in general this problem driver is very difficult to 
overcome.  When  asked  about  factors  which  act  as  barriers  to  developing  a  single  window 
environment,  nearly  half of responding customs authorities cited  the  reluctance among 

29   Certificates, attestations, licences and permits issued by partner competent authorities to certify the fulfilment of Union 

non-customs formalities. 

Page 10 / 237 

 
 
 
                                                 
competent  authorities  to  give  up  traditional  areas  of  responsibility  or  coordinate  with 
other  authorities.  Likewise,  a  respondent  to  the  public  consultation30  specified  that 
improving coordination between authorities should be the priority, considering that customs 
authorities, as the "final" authority for the release of goods, should play a leading role in the 
organisational structure.  

2.3  What are the consequences and size of the problem? 

Two types of consequences have been identified: (1) delays and inefficient use of financial 
and human resources, and (2) an ineffective application of rules in the EU single market 
and beyond, leading to negative impacts on the safety and security of EU citizens.  

2.3.1  Delays and inefficient use of financial and human resources 

Fragmented  interoperability  and  duplication  of  information  contributes  to  an  inefficient  use 
of financial and human resources. This implies that processes at the border are unnecessarily 
long, while compliance costs are higher, leading to negative impacts on the competitiveness 
of EU businesses involved in the international trade of affected goods (see box below).  

Box 3: Delays in the export of dual use goods and their impact on competitiveness 

The final report on data and information collection for EU dual-use export control policy 
review31 indicates that in the space industry six companies out of nine experienced delays 
at  customs  when  seeking  to  export  dual-use  items.  This  was  also  true  of  the  machinery 
sector,  where  companies  reported  export  delays  even  after  licences  were  issued.  In  the 
chemical  sector,  dual-use  controls  were  seen  to  delay  export  procedures  because  of 
misaligned export requirements and customs requirements for the same goods.  

The report found that export controls are a key element for international competitiveness. 
Several  associations  representing  the  space  industry  indicated  that  the  current  dual-use 
export controls affect competition, giving rise to significant distortions between companies 
located  in  different  EU  Member  States  and  between  EU  companies  and  third  country 
competitors, such as the USA and India. 

Delays: Longer clearance times 

Main affected stakeholders: economic operators 

At  import,  the  general  ratio  of  customs  declarations  subject  to  clearance  documentary 
controls is around 5% and for physical controls around 3.2% (2.1% and 1.2%, respectively, at 
export)32.  Compared  to  that,  the  ratios  of  documentary  or  physical  customs  controls  for 
specific goods subject to non-customs regulatory formalities are very high, reaching in some 
cases 100%. This is due to the sensitivity of the goods and the enforcement role assigned to 
the customs authorities in the respective regulatory frameworks.  

In the absence of electronic information exchanges between authorities, documentary checks 
must be carried out manually. This requires the assignment of customs officials to gather and 
review  the  supporting  documents  issued  by  the  partner  competent  authorities  from  the 
economic operator and to verify their content with the customs declaration data. The release 
of  the  goods  subject  to  manual  checks  can  take  days,  for  example,  where  a  declaration  is 
lodged outside of working hours. However, manual intervention by customs authorities have 

30   See Annex 2. 
31   http://trade.ec.europa.eu/doclib/docs/2016/september/tradoc_154962.PDF  
32   Data from the Annual Report 2017 on the Customs Union Performance.  

Page 11 / 237 

 
 
                                                 
significantly  decreased  in  those  Members  States  that  have  electronically  interconnected  the 
customs  systems  with  those  of  partner  competent  authorities,  enabling  the  automated 
verification  of  supporting  documents.  Indeed,  more  than  80%  of  respondents  to  the  public 
consultation indicated that the length of clearance time was the most prominent problem for 
respondents. 

Box 4: Time and human resource savings through automated exchange 

In  Spain  and  France,  the  introduction  of  a  single  window  environment  has  resulted  in 
automated data crosschecks with significant time and human resource savings. In Spain, the 
system analyses data from the different competent authorities' systems and provides results 
within one minute compared to the manual process that can take up to two days. A similar 
situation  was  found  in  France  where  the  single  window  environment  has  led  to  fewer 
interventions  on  the  part  of  customs  officers,  freeing  up  their  time  for  other  activities. 
Specifically,  prior  to  the  automated  exchange  of  supporting  documents,  85%  of  these 
documents  required  manual  checks,  whereas  now  this  has  been  reduced  to  15%  for 
supporting documents included in the single window environment. This means intervention 
is much less likely and resources can be deployed elsewhere.  

Inefficient use of financial and human resources: Direct costs (particularly for compliance) 
and enforcement costs 

Main affected stakeholders: customs authorities, economic operators and citizens 

These  costs  relate  to  the  financial  and  human  resources  needed  to  deal  with  customs  and 
other  regulatory  requirements,  which  could  otherwise  be  deployed  elsewhere.  The  need  for 
these  resources  is  linked  to  the  complexity  of  goods  clearance  processes:  as  regulatory 
requirements  increase, the clearance time increases, and so do the resources needed to  deal 
with  them.  The  stakeholders  affected  by  this  problem  are  primarily  customs  officers  who 
must  spend  resources  processing  declarations,  and  economic  operators  who  must  navigate 
complex  systems  and  liaise  with  different  authorities.  Partner  competent  authorities  are 
impacted  but  to  a  lesser  extent,  since  they  are  typically  involved  earlier33.  Citizens  are 
impacted to a certain extent, as costs are pushed onto them in the form of higher prices.  

Evidence  from  several  sources  shows  that  related  costs  are  too  high  for  the  main 
stakeholders. For example, in Ireland, customs officials estimated that the enforcement costs 
for  dealing  with  non-customs  formalities  accounted  for  two  thirds  of  their  work.  Some 
customs officials were dedicated to dealing specifically with implementing or verifying non-
customs  formalities  (in  this  case  often  the  license  for  import  of  agricultural  goods).  This 
represents  a  diversion  of  resources  from  other  tasks,  which  could  potentially  have  higher 
added  value  as  well  as  better  enforcing  compliance.  For  economic  operators,  compliance 
costs  are  also  considered  a  significant  problem,  especially  for  smaller  organisations  with 
fewer resources. Evidently the costs are higher in sectors where border formalities are more 
complex  (e.g.  for  food,  animals  and  animal  products),  and  for  those  economic  operators 
trading in countries with outdated or lacking electronic systems. 

Box 5: Inefficient use of resources – disproportionate compliance costs 

A trade association representative explained that, when dealing with different authorities at 
the  border,  in  many  cases  the  economic  operator  needs  to  act  as  a  “postman”,  carrying 

33   Competent authorities deal with economic operators’ application to deliver the supporting documents. 

Page 12 / 237 

 
 
 
                                                 
around files and sharing them with different authorities. 

In addition, economic operators in Member States with national initiatives already in place 
reported  very  favourable  experiences.  These  initiatives  have  allowed  them  to  simplify  the 
processes  of  submitting  and  dealing  with  the  supporting  documents  related  to  relevant 
regulatory requirements. For example, in Italy economic operators reported that by making 
certain  documents  fully  digital  (with  partner  government  authorities  sharing  them 
electronically with  customs), they were  able to  avoid  costs for transporting the documents 
between authorities themselves, thereby benefiting from faster clearance and fewer delays. 
Economic operators in other Member States shared similar anecdotes about reductions in the 
waiting times and administrative errors that used to delay clearance processes. 

The  extent  of  human  resources  needed  to  deal  with  regulatory  formalities  is  shown  by  the 
responses to the public consultation: most economic operators, and in particular micro, small 
and medium-sized enterprises (MSMEs), reported that they devote between one and four full 
time  equivalents  (FTEs)  to  formalities  related  to  movement  of  goods  across  borders34. 
Unsurprisingly, large businesses tend to have more staff dedicated to customs operations and 
related  regulatory  requirements.  Consultation  with  representatives  of  trade  association 
members confirmed the significance of costs associated with hiring customs experts to deal 
with the specificities of the different national systems, and again highlighted that the burden 
falls harder on MSMEs.  

2.3.2  Ineffective application of rules in the EU single market and beyond 

The  main  consequences  are  heightened  risk  of  fraud,  distorted  competition  in  the  single 
market  and unintentional non-compliance. The problems of fragmented interoperability and 
the complex clearance process also create knock-on effects for the achievement of EU public 
policy objectives, such as security and safety of citizens, animals and the environment, as it 
makes it more difficult to ensure the effective application of rules in the EU single market. In 
addition,  some  of  the  non-customs  formalities  at  stake  stem  from  international  agreements 
(e.g.  Convention  on  International  Trade  in  Endangered  Species  of  Wild  Fauna  and  Flora 
licences  (CITES),  Waste  Shipment  Regulation,  Prior  Informed  Consent  Regulation  on 
international  trade  in  hazardous  chemicals,  etc.)  or  aim  to  protect  third  countries  cultural 
heritage  (e.g.  import  of  cultural  goods  licences).  Any  loophole  in  the  enforcement  of  these 
policies affects the proper fulfilment of international commitments and the level of protection 
of EU partners in these agreements and third countries in general.  

Risk of fraud  

Main affected stakeholders: partner competent authorities, EU citizens  

The risk of fraud and corruption relates to deliberate deception to secure unfair or unlawful 
gain.  This  risk  is  higher  when  the  systems  for  enforcement  of  regulatory  requirements 
between  and  within  Member  States  cannot  talk  to  each  other.  The  most  tangibly  affected 
stakeholders in this case are partner competent authorities who are unable to effectively apply 
rules and regulations in their remit, as well as EU citizens who may suffer the consequences. 

Fraudulent reuse of supporting documents and abuse of quotas  

Some  supporting  documents  can  be  used  to  import  or  export  defined  quantities  of  goods 
which  can  be  split  across  different  consignments  (meaning  there  is  not  a  one-to-one 

34   The 2016 World Trade Report reinforces this idea, particularly as it relates to the vulnerability of SMEs and MSMEs in 

the context of international trade: https://www.wto.org/english/res_e/booksp_e/world_trade_report16_e.pdf 

Page 13 / 237 

 
 
 
                                                 
relationship  between  supporting  documents  and  customs  declarations).  Typically,  such 
documents are valid EU-wide and relevant consignments may be cleared in different Member 
States. To verify the validity of such documents, authorities need to know that the remaining 
quantity  has  not  already  been  used  in  the  clearance  of  other  consignments.  Automated 
quantity  management  requires  data  to  be  shared  in  real  time.  Similar  principles  apply  to 
goods  subject  to  quotas,  meaning  further  imports  or  exports  are  prohibited  after  a  certain 
threshold is reached. 

The current processes involving manual checks are not only time-consuming but also subject 
to  error  and  fraud,  making  it  difficult  to  prevent  the  fraudulent  use  and  re-use  of  quotas 
(especially  when  supporting  documents  are  supplied  in  paper  form).  However,  EU-level 
quantity  management  is  currently  not  possible  in  real  time  and  extremely  challenging  to 
conduct retrospectively given patchy and inconsistent monitoring and reporting requirements. 
Evidence  from  several  sources  shows  there  is  an  unaddressed  demand  for  the  capability  to 
undertake EU-level quantity management in order to apply EU rules in the single market. For 
example,  the  desire  to  have  quantity  management  capabilities  is  high  on  Member  States’ 
agendas, as shown in several case study reports35 and the feedback received in relation to the 
EU  CSW-CVED  and  EU  CSW-CERTEX  (see  Annex  14).  Interviews  with  Commission 
officials  also  highlighted  the  prominence  of  this  need  for  EU-level  quantity  management. 
This  issue was said to  contribute to  the inconsistent  enforcement of EU legislation in  some 
domains,  such  as  those  relating  to  environmental  protection  (see  further  information  in  the 
boxes below). 

Box  6: Possible  fraudulent reuse of supporting documents: An example of why EU level 
quantity management is needed  

Controls  for  the  import  and  export  of  Ozone  Depleting  Substances  licences  (ODS)  are 
managed  centrally  by  the  Directorate-General  for  Climate  Action  (DG  CLIMA)  but 
implemented  at  the  border.  While  DG  CLIMA  oversees  issuing  quotas,  licences  and 
authorisation  for  economic  operators  importing  goods,  customs  offices  must  conduct  the 
actual  controls.  This  includes  verifying  quantities  and  checking  the  validity  of  licences. 
However, only about 15% of customs offices (i.e. about 400 out of 2 600 customs offices 
in the EU), are registered in to verify the authenticity and validity of the documents. In the 
case of ODS licenses, only 70% of the licenses are currently verified; the remaining 30% 
are not checked. 

Box 7: Abuse of quotas: Illegal trade of hydrofluorocarbons (HFCs)  

Quotas related to the phasing down of HFCs in line with the 2016 Kigali Amendment to the 
Montreal  Protocol  have  increased  significantly  prices  of  HFCs.  While  encouraging 
innovation, this price increase has also raised the risk of illegal trade, which could potentially 
undermine environmental benefits and lead to unfair competition.  

35   See Annex 16 on Country Case Study Reports that forms part of the study to support the impact assessment. This annex 
contains individual case studies  carried out in eight EU Member States (Czechia, France,  Germany, Ireland, Italy, the 
Netherlands,  Romania  and  Spain).  Quantity  management  was  viewed  as  a  highly  desired  feature,  particularly  by  the 
Member States participating in the pilot project. The analysis indicates that for France and Czechia, poor exploitation of 
electronic  information  results  in difficulties  for  enforcement  of  quotas  and information  gaps  within, but  also  between, 
EU Member States. This makes it difficult to ensure that licenses are not copied and reused. The lack of harmonisation in 
EU systems and/or the lack of EU legalisation to underpin the development of such systems, means there is a barrier to 
EU-wide enforcement and gaps in information on the nature and scale of enforcement problems in the first place. Most 
importantly  for  France,  while  quantity  management  is  possible  nationally,  this  really  needs  to  occur  at  (EU  level)  the 
level of the single market for it to be meaningful.  

Page 14 / 237 

 
 
                                                 
In  2018,  the  Commission  received  allegations  of  widespread  illegal  trade  in  HFCs,  from 
industry  sources  and  a  report  published  by  the  Environment  Investigation  Agency  (EIA)36. 
The  report  noted  in  particular  that  the  current  HFC  reporting  system  does  not  allow 
customs  authorities  to  fully  verify  compliance  with  quotas  for  HFC  shipments.  The  fact 
that  these  shipments  may  be  imported  without  quota  emerges  as  an  “open  smuggling” 
phenomenon  that  could  undermine  the  enforcement  of  the  F-GAS  Regulation.  A  study 
performed in 2019 by the Commission to assess the magnitude of illegal trade partly refuted 
the conclusions of the EIA as regards “open smuggling”, but acknowledged the presence  of 
illegal activities and the need to improve the enforcement of the quota system37.  

Quantity management at EU level of any restricted goods would require a centralised system 
to consistently monitor imported and exported quantities in one or more Member States and 
to  determine  remaining  unused  quantity(s)  for  a  supporting  document  (or  quota).  This  can 
only  function  correctly  and  be  effective  if  all  Member  States  participate  within  a  single  IT 
platform and use it in a consistent way, or if all Member States have IT systems which are 
interoperable in real time. 

Forgery of supporting documents 

Evidence  from  several  sources  shows  that  there  is  currently  an  unacceptable  risk  of 
documentary forgery, although it is not possible to fully estimate its scale.   

Box 8: Risk of forged supporting documents (Firearm exports and Certificate of Inspection 
(COI)) 

According to Regulation 258/2012 on firearms exports, each Member State is free to decide 
on the electronic system  for the application and  licensing process  of  export licenses in line 
with national practices. The channels used for the fulfilment of regulatory requirements thus 
vary  significantly,  while,  the  absence  of  electronic  systems  to  manage  the  authorisation 
process systematically creates high risks of fraud38. 

The  rapidly  increasing  demand  for  organic  products  has  led  to  multiple  types  of  fraud, 
including  documentary  forgery,  driven  by  large  price  differences  between  organic  and 
conventionally produced goods39. The Commission has already put measures in place to face 
this problem, for instance by developing the electronic Certificate of Inspection (COI), which 
had  substantially  improved  the  traceability  of  the  organic  products  imported  from  non-EU 
countries.  However,  even  if  the  regulatory  authorisation  systems  become  fully  digital,  an 
electronic connection with customs systems is necessary to tackle the existing heightened risk 
of fraud in full and to guarantee the complete traceability of organic products.  

While these issues are widespread, evidence suggests that national single window initiatives 
have  to  some  extent  contributed  to  reducing  the  risk  of  fraud  and  corruption  through  more 
joined-up  information  sharing.  For  instance,  when  an  electronic  solution  was  introduced  at 
national  level  in  France  it  showed  that  5%  of  CVEDs  were  illegally  reused40.  Although  no 
hard data on the impact of these was available, the authorities believe this to have reduced the 
risk of fraud. In other Member States, the reduction of fraud was expected to occur through 

36   https://reports.eia-international.org/doorswideopen  
37   https://ec.europa.eu/clima/sites/clima/files/f-gas/legislation/docs/report_illegal_trade_hcf_en.pdf 
38   Firearms  acquisition  by  terrorists  in  Europe  Research  findings  and  policy  recommendations  of  Project  SAFTE:  “In 
addition,  cases  of  embezzlement  have  also  been  observed  that  involved  the  use  of  forged  import  licences  enabling  a 
number of criminals to acquire hundreds of firearms directly from a legal gun manufacturer, or involved authorised arms 
dealers who staged false legal exports or domestic sales that allowed them to sell the weapons illicitly to criminals.” 

39   Opson VIII Operation: https://tinyurl.com/y9jtbwsw 
40   See Business Case - EU Customs Single Window: Certificates exchange. 

Page 15 / 237 

 
 
                                                 
 
the introduction of electronic solutions, particularly where these were developed at EU level 
or  made  interoperable  between  Member  States41.  The  European  Parliament  report  on  the 
shadow  economy42  and  the  EIA  report  on  illegal  HFC  trade  refer  to  the  importance  of 
electronic systems and information sharing as a means to combat fraud.  

Distortion of competition 

Main affected stakeholders: Economic operators 

The  ineffective  application  of  rules  in  the  EU  single  market  creates  a  distortion  of 
competition, contributing to an uneven playing field for economic operators.  
A  special  report  published  by  the  European  Court  of  Auditors  in  201743  on  EU  customs 
controls reiterated serious weaknesses and concluded the illicit traders exploited differences 
and  weaker  links.  The  report  found  evidence  of  uneven  application  of  customs  controls.  It 
also  found  different  approaches  to  imposing  customs  penalties.  The  report  highlights  that 
burdensome customs controls can have an impact on the traders’ choice of customs office of 
importation  and  that  (air)ports  with  fewer  customs  controls  may  attract  more  traffic.  These 
shortcomings clearly have important  implications, creating perverse incentives and customs 
duty evasion, as well as disadvantaging legitimate traders. While it has not been possible to 
provide concrete estimates, the evidence was cited as cause for significant concern.  A 2018 
report from the European Parliament took this further to indicate that the current imbalance in 
the  performance  of  customs  control  by  Member  States  creates  a  “diversion  of  the  flows  of 
goods  towards  the  weakest  points”  –  “port-shopping”  by  custom  fraudsters44.  This  was 
mentioned during the interviews with members of trade associations, who highlighted a risk 
of incoherence for the EU if there are persistent differences in the application of community 
law  by  different  Member  States.  Linked  to  this  is  the  potential  for  some  Member  States  or 
economic operators to exploit such differences for commercial gain.  

Unintentional non-compliance related to lack of regulatory knowledge or comprehension 

Main affected stakeholder: Economic operators (particularly small businesses)  

Evidence from field visits and consultations within the Commission suggested that, in some 
cases, the complexity of border management processes led to poor awareness of requirements 
and unintentional non-compliance by economic operators45. This was suggested in interviews 
with  authorities  dealing  with  the  export  of  waste,  and  the  import  of  ozone  depleting 
substances,  among  others.  A  total  of  84%  of  economic  operators  responding  to  the  public 
consultation  cited  “insufficient  support  from  authorities”  as  negatively  impacting  the 
movement  of  goods.  This  suggests  difficulties  navigating  the  complex  legal  and  technical 
requirements for movement of goods which may in turn hamper compliance. For example, a 
customs specialist working for a fruit importer in Ireland explained that the position had been 
created because the organisation was previously making too many errors and this was simply 

41   See Annex 14 (Evaluation of the EU CSW-CERTEX) for details on the national experiences of participating Member 

States in the implementation of electronic solutions.  

42   “From Shadow to Formal Economy: Levelling the Playing Field in the Single Market,” European Parliament Study 2013. 
43   Special Report No 19/2017: “Import procedures: shortcomings in the legal framework and an ineffective implementation 

impact the financial interests of the EU” is available on the ECA website. 

44   Committee on the Internal Market and Consumer Protection,  Report on the proposal for a regulation of the European 
Parliament  and  of  the  Council  establishing,  as  part  of  the  Integrated  Border  Management  Fund,  the  instrument  for 
financial support for customs control equipment (COM(2018)0474 – C8-0273/2018 – 2018/0258(COD)), 12 December 
2018  https://tinyurl.com/y7j68kx4 

45   Poor  understanding  of  regulations  is  also  known  as  an  important  cause  of  non-compliance  more  generally.  Among 
others,  this  has  been  explained  in  a  recent  report  by  the  OECD,  “Study  on  reducing  the  risk  of  policy  failure  and 
challenges for regulatory compliance”, http://www.oecd.org/regreform/regulatory-policy/1910833.pdf  

Page 16 / 237 

 
 
                                                 
due  to  difficultly  dealing  with  the  complex  requirements,  liaising  with  different  authorities 
and so on. 

2.4  Affected stakeholders 

There are four key groups likely to be affected by the problem: national customs authorities, 
other national authorities, economic operators, and citizens. 

Table 1: Affected stakeholders 

Directly affected stakeholders 

Economic operators  

National 
customs 
authorities 

Partner competent 
authorities 

-  Economic 

operators 

involved 

in 

-  Customs 

international trade: 
o  Manufacturers, 

o 

retailers 

and 
wholesalers  active  in  the  business  of 
purchasing and/or selling goods46; 
Shipping  and  transport  companies 
dealing  with  the  physical  movement 
of 
commercial 
or 
transportation (freight forwarders and 
logistics companies); 

goods 

authorities  of 
the 
27 
Member 
States 

-  Commission DGs 
-  National/local 
and 
ministries 
relying  on 
agencies 
customs to control and 
their 
implement 
policies 
the 
border47.  

at 

Indirectly affected 
stakeholders 

Citizens 

-  Citizens 

general 
in 
affected by the security of 
the market. 

-  Third 

countries, 

in 
particular 
partner 
countries  bound  by  EU 
international 
commitments. 

o  Other  transport  intermediaries  such 
as  port  and  airport  authorities, 
terminal  handlers,  stevedores  and 
warehouse operators, involved in the 
physical movement of goods; 

o  Other 

involved 

intermediaries 

in 
fulfilment  of  procedures,  including 
customs  brokers  and  businesses 
providing a service to one or several 
parties  in  the  supply  chain  (in  form 
of  data  processing  and  information 
exchange. 

-  EU  businesses  compliant  with  EU 
regulatory requirements that are affected 
by  distortion  of  competition  due  to  the 
uneven  enforcement  of 
these  EU 
requirements. 
Source: DG TAXUD 

2.5  How will the problem evolve? 

In the absence of new action, there is no evidence to suggest that the identified problems and 
their  consequences  would  substantially  improve.  As  such,  the  baseline  scenario  would  not 
introduce any drastic changes or improvements in the following areas:  

  Clearance  times  and  efficient  use  of  human  and financial  resources  needed  to  meet  the 
requirements  for  border formalities:  the customs clearance of  goods affected by certain 
non-customs  formalities  would  be  simplified  and  lead  to  time  and  resource  savings  in 
those Member States involved in single window initiatives for those particular formalities 
under their scope. However, no drastic changes in clearance times would be possible in 
most Member States. Likewise, this means the human and financial resources needed to 

46   Small and medium-sized enterprises may also need to employ specialist brokers to fulfil international trade requirements. 
47   These include competent authorities such as veterinary, sanitary, phytosanitary, agricultural and fisheries, environmental, 
pharmaceutical and  market surveillance authorities, and authorities that use the information for different purposes, i.e. 
statistical, police and tax/revenue authorities. 

Page 17 / 237 

 
 
 
                                                 
meet the requirements for border formalities, would continue to be used at the expense of 
more  efficient  technical  solutions.  Without  concerted  action  at  EU  level,  this  would 
deepen  the  differences  between  trade  facilitation  measures  available  to  the  economic 
operators  in  the  Member  States,  affecting  especially  small  businesses  with  fewer 
resources to move their import or export (international trade) operations to other Member 
States.  

  Better application of rules in the EU single market, including:  

o  Risk of fraud resulting from lack of real time EU-level quantity management. The risk 
of fraud derived from the fraudulent reuse of supporting documents and abuse of 
quotas  will  not  improve  unless  the  27  Member  States  customs  systems  are 
regulatory 
interoperable 
requirements  and  the  necessary  exchanges  of  information  between  customs  and 
partner  competent  authorities  that  would  enable  EU-wide  quantity  management  are 
uniformly defined.  

the  electronic  systems  managing  non-customs 

to 

o  Distortion of competition, as economic operators or Member States would continue to 
exploit differences in the application of legislation for commercial gain.  Differences 
in  the  enforcement  of  non-customs  legislation,  which  may  cause  diversion  of  the 
flows of goods towards the weakest points and raise disadvantages for EU businesses 
compliant with internal market rules will not be reduced. Rather, these would increase 
if the digital  cooperation between customs and partner competent authorities and its 
positive contribution in terms of automated controls and improved risk management 
were  only  applicable  in  some  Member  States  (those  involved  in  single  window 
initiatives). 

o  Non-compliance  due  to  lack  of  regulatory  knowledge  or  comprehension  would  also 
continue  to  be  a  risk,  particularly  when  combined  with  multiple  and  non-aligned 
national  single  window  solutions.  This  would  be  problematic  if  individual  Member 
States  develop  divergent  solutions  to  simplify  reporting  formalities  for  economic 
operators (B2G solutions).  

3.  WHY SHOULD THE EU ACT? 

3.1  Legal basis 

The  legal  basis  for  the  EU  to  act  is  provided  by  Articles  33,  114  and  207  of  the  TFEU. 
Articles 33 and 114 give the European Parliament and the Council the right to take measures 
to  strengthen  customs  cooperation  between  Member  States  and  between  the  latter  and  the 
Commission to ensure the proper functioning of the internal market. In addition, the choice of 
Article  207  as  a  legal  basis  relies  on  the  premise  that  the  scope  of  the  initiative  extends 
beyond cooperation between customs authorities to include trade facilitation as an important 
aspect of trade policy.  

3.2  Subsidiarity: Necessity and added value of EU action 

The identified problems are inherently transnational, involving the movement of goods across 
borders and EU-wide effects of any error and fraud taking place in individual Member States. 
The EU, given its responsibility for the Customs Union and for the non-customs regulatory 
requirements  in  question,  is  well  placed  to  address  the  problems  by  coordinating  action, 
tackling fragmentation and generating economies of scale. Moreover, existing and expected 
action at different levels has been shown to be inadequate on its own. The following points 
explain this for each of the three types  of existing and expected action, namely the  gradual 
digitalisation  and  modernisation  of  processes  related  to  the  clearance  of  certain  goods;  the 

Page 18 / 237 

 
 
development of customs single windows at national level; and continued operation of the EU 
CSW-CERTEX  project.  Gradual  digitalisation  and  modernisation  of  the  processes  for 
certain  goods:  over  time,  as  relevant  EU  non-customs  legislation  is  reviewed  and 
modernised, paper documents are likely to be replaced by electronic versions. This is likely to 
generate  some  positive  effects,  both  in  terms  of  efficiency  and  correct  application  of  EU 
rules. However, due to fragmented interoperability and diverse business processes, this would 
not  make  it  easier  for  economic  operators,  partner  competent  authorities  and  customs 
authorities to share information. The problem could even get worse, or force actors to resort 
to the exchange of paper documents, if the systems and processes are changed in divergent 
ways,  since  customs  authorities  could  not  be  expected  to  develop  links  with  all  of  them. 
Without  a  coordinated  approach,  it  is  also  likely  that  developments  would  proceed  at  an 
uneven  pace,  with  the  current  paper-based  processes  remaining  in  use  for  some  regulatory 
requirements. Finally, any such issues would be exacerbated for the substantial proportion of 
goods  movements  involving  more  than  one  Member  State  (e.g.  goods  requiring  supporting 
documents  issued  in  one  Member  State,  but  cleared  in  another),  since  customs  authorities 
could  not  be  expected  to  make  the  investments  needed  to  align  with  the  different  partner 
competent authorities in other countries.  

Development of national customs single windows: several Member States, such as France, 
Italy  and  Spain,  have  made  significant  progress  in  implementing  national  customs  single 
windows. However, these initiatives face several challenges, which suggest that the benefits 
would  be  limited.  First,  according  to  feedback  from  project  group  members,  the  necessary 
resources are unavailable in most Member States. Second, a major shortcoming of the current 
patchwork  arrangements  is  the  lack  of  EU-wide  quantity  management.  This  would  be 
unachievable under national customs single windows, even if they became widespread. Third, 
the  scope  of  national  customs  single  windows  varies  and  usually  only  includes  a  few  non-
customs regulatory requirements, leaving the majority of problems unaddressed. Fourth, the 
development  of  national  customs  single  windows  would  bind  individual  Member  States  to 
their chosen solutions, making any later decision to improve coordination and interoperability 
more difficult to realise. Evidently, the absence of harmonised measures to develop national 
single-entry  points  would  lead  to  a  complex  situation  for  economic  operators  due  to 
significant variations in regulatory reporting arrangements in different Member States. 

Continued operation of the EU CSW-CERTEX project: in the absence of a new initiative, 
some  Member  States  would  continue  to  participate  in  EU  CSW-CERTEX  on  a  voluntary 
basis.  For  the  countries  concerned,  this  would  allow  some  of  the  identified  problems  to  be 
addressed to a certain extent, especially as procedural redundancies (e.g. the continued need 
for paper documents to accompany electronic versions) are reduced. However, the project’s 
desired benefits in terms of efficiency gains, enforcement and reduction of fraud and errors 
cannot  be  realised  without  EU-wide  quantity  management,  which  is  only  possible  if  all 
Member  States  participate.  The  current  levels  of  participation  have  been  achieved  in 
anticipation  of  the  imminent  introduction  of  an  obligatory  version.  Without  this  prospect, 
participation  would  stagnate  or  decline.  This  would  also  make  it  difficult  to  justify  the 
investment  needed  at  EU  level  to  further  expand  the  scope  of  the  initiative  to  cover  more 
regulatory requirements.  

Given  its  role  in  modernising  the  Customs  Union  and  better  enforcing  customs  and  non-
customs regulatory requirements at the border, the EU has a unique advantage to reassess the 
fundamental  practices  and  procedures  of  the  current  fragmented  model  of  regulatory 
compliance. EU action in this area will improve compliance of regulatory requirements with 
EU legislation and further facilitate the cross-border movement of goods. This, in turn, would 
bring  a  clear  added-value  to  the  interaction  between  customs  and  partner  competent 

Page 19 / 237 

 
 
authorities and the day-to-day activities of economic operators. Ultimately, EU intervention 
will generate significant social and environmental impacts and substantial economic benefits 
for society as a whole.  
In accordance with Article 5(4) of the Treaty on the European Union48, the content and form 
of Union action must not go beyond what is necessary to meet the objectives of the Treaties. 
Respect  for  the  principle  of  proportionality  will  be  provided  by  ensuring  that  the  policy 
approach  and  its  outreach  match  the  identified  problem/objective.  For  this  purpose 
proportionality is a key criterion considered in the comparison of the policy options.   

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objectives 

The  general  objective  of  this  initiative  is  twofold:  (1)  to  improve  the  enforcement  of  non-
customs  regulatory  requirements  that  must  be  applied  to  goods  at  EU  borders,  thereby 
enhancing the protection of the Union; and (2) to facilitate international trade.  

4.2  Specific objectives 

The initiative will contribute to the general objective by pursuing the following three specific 
objectives in line with the identified problems: 

1.  Define a governance framework for the EU Single Window environment for customs to 
enhance  cooperation  and  ensure  interoperability  of  national  and  EU  Single  Window 
solutions  where  beneficial  and  appropriate.  This  objective  addresses  the  problem  of 
fragmented interoperability in the management of goods clearance processes. 

2.  Improve working practices between customs and partner competent  authorities involved 
in international trade to automate to the extent possible customs controls of non-customs 
regulatory  formalities,  and  to  promote  electronic  feedback  of  the  customs  clearance  as 
well  as  a  better  integration  of  the  applicable  procedures.  This  objective  addresses  the 
problems of fragmented interoperability in the management of goods clearance processes 
and duplication of information and procedural redundancies.  

3.  Determine a framework for data harmonisation and enable the re-use of data provided by 
economic operators when fulfilling the different formalities required by customs and non-
customs authorities for international trade. This objective addresses the problem of 
duplication of information and procedural redundancies.  

Taken together, the general and specific objectives would achieve the overall objective of a 
streamlined  EU  regulatory  environment  for  international  trade  that  delivers  long-term 
benefits  to  the  Union  and  its  citizens  across  policy  domains.  Importantly,  any  technical 
solutions  capable of addressing the objectives would  take considerable time to  develop  and 
be  deployed  progressively,  with  various  elements  becoming  operational  at  different  times. 
For  this  reason,  it  is  envisaged  that  the  objectives  would  be  achieved  gradually  over  the 
course of the next decade.  

48 Consolidated version of the Treaty on European Union, OJ C 326, 26.10.2012, p. 13–390. 

Page 20 / 237 

 
 
 
 
 
 
                                                 
Figure 4: Policy objectives 

Source: DG TAXUD 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1  What is the baseline from which options are assessed? 

The  baseline  scenario  serves  as  the  benchmark  against  which  the  different  options  are 
assessed.  Its  analysis  requires  an  examination  of  EU  CSW-CERTEX  and  the  existing 
national  single  window  solutions.  To  facilitate  this  analysis,  two  different  variables  are 
taken into account to present the scope of single window initiatives to date at EU and national 
levels:  

Categories of single window services provided: these services are divided in a government-
to-government (G2G) and a business-to-government (B2G) dimension; 

Type  and  volume  of  non-customs  regulatory  requirements  covered:  regulatory 
requirements  1)  imposed  and  regulated  at  EU  level,  2)  introduced  nationally  in  accordance 
with Article 36 of the TFEU, or 3) certified by third countries in the context of international 
agreements or EU legislation.  

The  increased  digitalisation  of  customs  and  regulatory  procedures  has  opened  up  new 
opportunities  to  improve  the  interoperability  and  cooperation  between  customs  and  partner 
competent  authorities.  Both  the  Commission  and  some  Member  States  have  started  to 
develop  and  put  in  place  G2G  single  window  services  to  interconnect  national  customs 
systems  with  those  of  partner  competent  authorities  where  the  supporting  documents 
data  is  stored.  In  principle,  G2G  single  window  services  may  be  described  as  digital 
exchanges of information between customs and partner competent authorities’ systems that: 

  Allow  customs  authorities  to  automatically  receive  and  verify  the  relevant  electronic 

supporting documents issued by partner competent authorities; and  

  Enable  partner  competent  authorities  to  monitor  and  manage  the  authorised  quantity  of 

goods based on the release of goods by customs (quantity management).   

The  presence  of  G2G  single  window  renders  the  customs  clearance  process  more  efficient, 
thanks to  the automation of documentary controls and enables customs authorities to  better 
enforce  the  regulatory  policies  of  partner  competent  authorities,  thanks  to  the  ability  to 
automatically  monitor  the  consumption  or  use  of  supporting  documents.  However,  these 
services  do  not  resolve  the  issue  of  economic  operators  having  to  communicate  separately 

Page 21 / 237 

 
 
 
with both customs and the relevant partner competent authorities to place the goods under a 
specific customs procedure.  

B2G single window services aim at streamlining reporting formalities imposed on trade for 
the import, export and transit of specific goods subject to non-customs regulatory formalities. 
They  avoid  reporting  and  procedural  redundancies  and  enable  the  realisation  of  the 
internationally  recognised  single  window  concept  by  providing  economic  operators  with  a 
single-entry  point  to  fulfil  all 
import,  export  and  transit-related  regulatory 
requirements49.  B2G  single  window  services  aim  to  significantly  improve  the  customs 
clearance process, by allowing economic operators to lodge all the necessary data required by 
customs  and  non-customs  legislation  at  a  single-entry  point  and  receive  any  related 
information from concerned authorities directly from this point50. 

The relevant non-customs regulatory formalities can be categorised in four groups as shown 
in  the  table  below  (a  detailed  list  of  the  regulatory  requirements  under  each  category  is 
provided in Annex 8).  

Table 2: Categories of non-customs regulatory requirements 

Category 1 

Category 2 

EU regulatory 
requirements with data 
available for all Member 
States at EU level51. 

EU regulatory 
requirements with data 
available in a national or 
EU voluntary system52. 

Category 3 
National regulatory formalities 
introduced by national 
legislation in accordance with 
Article 36 of the TFEU53. 

Category 4 

EU regulatory formalities 
certified by a third-country 
authority and submitted to 
EU customs authorities.  

Source: DG TAXUD 

In light of the above variables, the relevant existing  EU and national initiatives consist of 
the G2G solution provided by EU CSW-CERTEX and the national single window initiatives 
being developed in several Member States. 

EU  CSW-CERTEX  is  focused  on  establishing  a  connection  between  the  national  customs 
systems of the participating Member States and a number of EU databases covering certain 
non-customs regulatory requirements. In practical terms, supporting document data is passed 
through  to  the  customs  systems  of  the  participating  Member  States  in  a  way  that  it  can  be 
automatically  verified  against  the  customs  declaration  data.  This  platform  also  provides  a 
quantity  management  functionality  for  reserving  the  declared  quantities  of  authorised 
goods in the source database. EU CSW CERTEX covers only a subset of Category 1, namely 
Union regulatory formalities54, whose information  is  available for  all Member States at  EU 
level55.  

49   The Single Window (SW) concept is defined by the United Nations Economic Commission for Europe (UNECE) as “a 
facility  that  allows  parties  involved  in  trade  and  transport  to  lodge  standardised  information  and  documents  with  a 
single-entry point to fulfil all import, export, and transit-related regulatory requirements.” 
50   Single point of communication to economic operators for the import, export and transit of goods. 
51   Approximately 4.1 million of customs declarations are affected by these formalities annually. 
52   Approximately 2.7 million of customs declarations per year are affected by these formalities. 
53   Approximately  3  million  declarations  at  import  and  2  million  declarations  at  export  are  affected  by  these  formalities 

annually. 

54   CHED-A (Common Health Entry Document for Animals) formerly CVED-A  

CHED-P (Common Health Entry Document for Animal Products) formerly CVED-P   
CHED-D (Common Health Entry Document for Feed and Food of Non-Animal Origin) formerly CED  
CHED-PP (Common Health Entry Document for Plants and Plant Products   
COI (Certificate of Inspection) for imports of organic products  
FLEGT (Forest Law Enforcement, Government and Trade) for imports of timber  
Currently, these certificates are available in TRACES NT (owned by DG SANTE). Further expansion will include ODS 
and F-GAS licences managed by the ODS2 licensing system (developed by DG CLIMA).  
55   A detailed evaluation of the EU CSW-CERTEX project and its scope is provided in Annex 14. 

Page 22 / 237 

 
 
                                                 
 
 
 
 
 
In addition to the voluntary participation of several Member States in EU CSW-CERTEX, a 
number  of  single  window  national  initiatives  are  ongoing  in  countries  such  as  Austria, 
Czechia, France, Italy, Latvia, Lithuania, Portugal, Spain and the Netherlands56. The majority 
of these are focused on G2G services while some Member States, such as Spain,  Italy, and 
the Netherlands have started taking steps to develop B2G services. Some Member States are 
also  using  their  national  initiatives  to  integrate  processes  across  various  authorities  for  the 
coordination  of  respective  controls  providing  a  one-stop  shop  solution57.  The  regulatory 
formalities within the scope of each national initiative can be summarised as follows:  

  Czechia,  Latvia  and  Portugal,  participating  in  the  EU  CSW-CERTEX  have  developed 
interconnections  with  some  national  systems  hosting  EU  regulatory  requirements  (e.g. 
AGRIM/AGREX for Czechia, Latvia and Portugal and CITES licences for Czechia). This 
allows  the  automated  verification  of  85-90%  of  the  volume  of  these  supporting 
documents, as long as they are issued within the same Member State. In 10-15% of the 
cases, the supporting document presented to customs for import or export has been issued 
in  another  Member  State  and  therefore  cannot  be  automatically  validated  through  the 
established  national  connections.  In  these  cases,  a  paper  version  of  the  supporting 
document has to be verified manually.  

  Austria,  Spain,  France,  Italy,  Lithuania  and  Sweden  have  connected  their  customs 
systems to national systems hosting either EU regulatory requirements, such as AGRIM, 
AGREX,  CITES,  dual  use  goods 
licences,  surveillance  documents  and  export 
authorisation  of  firearms,  or  national  ones.  Similarly  to  the  above,  this  enables  the 
automated verification of the respective supporting documents  in  around 85-90% of the 
cases and manual verification for the other 10-15%.  

  Spain and Italy have also developed a connection to automatically verify EU regulatory 
requirements available in EU systems (e.g. CHED-A, CHED-P, CHED-D) outside the EU 
CSW-CERTEX solution. 

Authorities  in  the  EU  also  deal  with  supporting  documents  issued  by  third  countries. 
Connections between customs and third countries licensing or certification systems have not 
been established at either EU or national level. This means that any EU regulatory formalities 
certified by a third-country authority and presented to EU customs as a supporting document 
to  the customs  declaration has to be verified manually  as is  currently  the case  for the VI-1 
document  for  wine  imports,  the  Kimberley  Process  Certification  Scheme  (KPCS)  for 
diamond imports, or Certificates of Origin58. 

5.2 Ongoing impacts without any further EU policy action 

The  evolution  of  the  current  situation  without  additional  EU  intervention  would  affect  in 
several ways the actors involved in the international trade. The scope of EU CSW-CERTEX 
project  would  remain  limited  to  G2G  services  focused  on  the  verification  of  regulatory 
requirements for a relatively small number of non-customs formalities. Member States would 

56   Information based on the Customs 2020 Project Group and the field visits (survey conducted during the initial phase of 
the  PG  on  the  state  of  play  of  national  customs  single  window  initiatives  and  presentations  provided  by  15  of  the  19 
Member States on the national situation and prospects in this area. See Annex 9. 

57   Article 47 of the Union Customs Code.  
58   An exception is made for some goods requiring proof of origin where alternative certification schemes apply. The REX 
system addresses this based on the principle of self-certification. It is developed by the EU Commission and regulated by 
Commission Implementing Regulation (EU) No 2015/2447 (UCC IA) to  progressively replace the former certification 
system requiring authorised certification issued by government authorities. For the moment, the REX system is used by 
EU  exporters  in  the  context  of  some  foreign  trade  agreements  (FTAs),  the  Generalised  System  of  Preference  and  the 
Overseas Association Decision.   

Page 23 / 237 

 
 
                                                 
continue to participate in this project on a voluntary basis59. While both the Commission and 
Member States would incur considerable costs to maintain the system and connections to it, 
the  limited  participation  would  make  it  impossible  to  implement  crucial  features  such  as 
reliable EU-wide quantity management60. The Member States that are not participating in this 
project  would  continue  to  follow  national  practices  leading  to  difficulties  in  verifying 
volumes  consumed  in  these  Member  States  for  EU  CSW-CERTEX  members.  As  reported 
universally by Member States, this would discourage additional Member States from joining 
the project. With fewer Member States likely to participate and an uncertain future, it would 
be difficult to justify the investment necessary to integrate further regulatory requirements. It 
can thus be assumed that coverage would remain limited to those where agreements between 
DG TAXUD and other DGs have already been made61.  

Based on the experiences to date and information regarding expected developments, national 
Single Window initiatives in a growing but limited number of Member States would be likely 
to  continue  in  parallel  with  EU  CSW-CERTEX.  They  would  evolve  in  different  directions 
and modalities based on the varying levels of digitalisation of government services, political 
priorities,  existing  IT  architecture  and  cost  structures.  These  initiatives  would  also  entail 
significant  costs,  partly  due  to  the  need  for  each  Member  State  pursuing  a  national  Single 
Window  to  develop  separate  IT  solutions.  In  some  cases,  national  customs  and  partner 
competent authorities would even need to replicate EU-level databases such as TRACES in 
order to cover certain regulatory requirements. 

EU  CSW-CERTEX  and  advanced  national  single  window  initiatives  pursued  by  a  few 
Member States will continue to provide certain benefits in the participating Member States.  
These  mainly  include  time  savings  through  reductions  in  the  time  and  effort  needed  for 
various  stakeholders  to  deal  with  the  goods  clearance  processes62,  improved  cooperation 
between  customs  and  non-customs  authorities63  and  better  enforcement  of  non-customs 
formalities64.  These  limited  benefits  would  only  partially  achieve  the  objectives  of  this 
proposal. In the absence of new EU action the following impacts could be expected:  

  Customs  authorities  in  non-participating  countries  without  national  single  window 
initiatives  would  continue  to  rely  heavily  on  manual  checks  for  the  verification  of 
non-customs  regulatory  formalities.  Reliance  on  manual  procedures  implies  more 
complex and uncoordinated goods clearance processes for both regulatory authorities 

59   More details on the expected gradual expansion in terms of participating countries are provided in Annex 16. 
60   A reliable quantity management functionality would require all Member States customs systems to be connected to the 
EU CSW-CERTEX to provide information on the quantities of authorised goods declared to and cleared by customs, in 
order to calculate how much of such quantities have been consumed to avoid fraudulent overuse.  

61   These include the CHED family of certificates (which will replace CVED in December 2019), COI, FLEGT, ODS and 

FGAS. 

62   The  EU  CSW-CVED  pilot  and  EU  CSW-CERTEX  project  have  delivered  on  their  objective  to  allow  for  automated 
checks of a limited number of supporting documents by customs authorities (see Annex 14 on the evaluation of these 
projects). For example, the introduction of a single window environment in Spain and France has resulted in automated 
data crosschecks with significant time and human resource savings and efficiency gains in the customs clearance process 
(see Box 4).   

63   The case study on Ireland indicates that the EU SW-CVED pilot led to more targeted manifest checks limited to risk-
based searches for unusual consignments rather than systematic checks for “normal” consignments given the improved 
ability to identify unusual consignments. These benefits as well as a continued enhanced cooperation between customs 
and  partner  competent  authorities  (i.e.  better  understanding  of  each  other’s  controls  creating  a  platform  for  future 
increased  integration  of  customs  and  partner  controls)  would  be  likely  to  continue  under  the  baseline  scenario.  (see 
Annex 16). 

64   The  case  study  on  France  indicates  that  digitalisation has  already  brought  benefits,  for  instance  in  terms  of  making  it 
possible  to  trace  goods  since  the  authority  delivering  the  document  knows  when  it  is  being  used,  as  do  economic 
operators and customs authorities. This leads to better monitoring of the use of the supporting documents, and of their 
chronology (see Annex 16). 

Page 24 / 237 

 
 
                                                 
and  economic  operators  at  EU  and  national  level65.  Moreover,  their  continued  use 
would cause delays in the clearance process and may generate administrative errors. 

  The lack of EU-wide automated quantity management would lead to persistent risks 
of  fraud  and  gaps  in  the  enforcement  of  concerned  regulatory  requirements  by 
customs,  even  in  Member  States  participating  in  the  pilot  or  with  single  window 
initiatives at national level. The potential for the fraudulent reuse of documents is high 
due to the absence of a strict one-to-one relationship between a supporting document 
and  a  customs  declaration.  For  example,  EU  level  quantity  management  is  also 
necessary for the effective enforcement of quotas (see box 7 in section 2.3.2.), but this 
functionality  is  not  possible  unless  all  Member  States  are  involved,  and  the 
technology supports real-time information sharing. 

  Finally,  the  current  situation  in  the  EU  related  to  regulatory  formalities  required  for 
the  international  trade  in  goods  is  still  far  from  meeting  the  needs  of  traders  for 
efficient  goods  clearance.  Differences  in  data  sets  and  processes  across  regulatory 
formalities  inhibit  harmonised  exchange  between  customs  and  partner  competent 
authorities, resulting in the submission of the same information multiple times. In the 
absence  of  EU  action,  only  non-harmonised  B2G  single  window  services  would  be 
available in the (few) Member States that decide to develop them nationally, leading 
to an uneven playing field in terms of trade facilitation. 

5.3 Description of the policy options 

Eight  policy options66 have been identified  to  address  the problems discussed above  and to 
achieve the set objectives. They are based on the evaluation of EU SW-CVED carried out by 
DG TAXUD and the experience derived from its evolution into EU CSW-CERTEX as well 
as discussions and deliverables of the project group. They were further analysed and assessed 
by 
trade 
the  senior  management  of  Member  States  customs  administrations  and 
representatives at the High-Level Seminar67 that took place in Bucharest on 15-16 May 2019. 
The options cover a range of potential actions to develop an EU Single Window environment 
for customs and can be structured in three different groups depending on the type of services 
offered:  

  Group  I  (options  1-4):  options  for  government-to-government  (G2G)  back-end 
cooperation  that  would  focus  primarily  on  facilitating  information  sharing  between 
customs and partner competent authorities.  

  Group  II  (options  5-7):  options  for  business-to-government  (B2G),  front-end 
cooperation  aimed  at  improving  economic  operators’  interactions  with  customs  and 
partner competent authorities.  

  Group  III  (option  8):  cross-cutting  option  aimed  at  streamlining  the  way  customs 
and  partner  competent  authorities  identify  and  store  information  on  economic 
operators.  

65   The case study on Czechia shows that continued voluntary participation in the pilot project means the continuation of 
non-harmonised procedures with some EU Member States dealing with certain regulatory requirements in paper-format, 
and  others  electronically,  which  especially  is  a  burden  for  traders  and  economic  operators.  In  addition,  the  baseline 
scenario would not support Czech customs in having more partner competent joining the single window initiative (see 
Annex 16).   

66   An overview of the policy options is provided in Annex 17. 
67   See Annex 2 (High Level Seminar on the EU SW environment for customs initiative) for further details on the assessment 

of the options.  

Page 25 / 237 

 
 
                                                 
5.3.1  Group I: Government-to-government (G2G)  

Options  1-4  address  how  customs  and  partner  competent  authorities  can  automatically  and 
effectively  exchange,  cross-reference  and  verify  information  for  the  customs  clearance 
process when an economic operator submits a customs declaration requiring the compliance 
of  non-customs  regulatory  formalities.  Each  option  covers  a  different  category  of  non-
customs  regulatory  requirements  (see  Annex  8).  Since  different  categories  of  regulatory 
requirements have different systems  and arrangements for receiving, processing and storing 
information, the solutions needed to include any of them in a future policy choice would also 
differ. Even within options, multiple implementation choices could be envisaged.  

Options  1-4  are  not  mutually  exclusive,  but  rather  are  cumulative,  meaning  that  a 
combination of them could form part of a future policy choice. Given that option 1 builds on 
the  existing  EU  CSW-CERTEX  project  by  expanding  it  to  all  Member  States  and  covers 
regulatory  formalities  that  (due  to  their  management  using  existing  EU  electronic  systems) 
are easier to interconnect, it would not make any logical sense to put in place options 2, 3 or 4 
(which  cover  different  categories  of  formalities)  without  firstly  implementing  option 1.  For 
this  reason,  option 1  is  viewed  as  a  prerequisite  to  any  future  policy  choice  apart  from 
continuing with the baseline scenario. 

Option  1  –  Interconnecting  national  customs  systems  to  EU  non-customs  regulatory 
formalities digitally available at EU level 

This  option  would  cover  EU  regulatory  requirements  managed  through  EU  electronic 
systems  or  through  a  combination  of  EU  and  national  systems,  but  where  the  relevant 
information  required  by  customs  for  clearance,  for  all  Member  States,  is  available  at 
central level68 (e.g. CHED-A, CHED-P, CHED-D, CHED-PP, COI, FLEGT, ODS, FGAS). 

Figure 5: Option 1 – EU regulatory requirements managed through EU systems 

Source: DG TAXUD 

It would put in place a legal framework for uniform and obligatory use of the existing EU 
CSW-CERTEX system to exchange information between the national customs systems and 
the  existing  and  future  EU  electronic  systems  managing  EU  regulatory  requirements. 
This means that the scope of the option has a dynamic feature and additional EU regulatory 

68   For example,  while  formalities related to the Waste Shipment Regulation are primarily  managed  at national level, the 
Commission  has  mandated  a  harmonised  and  interoperable  Electronic  Data  Exchange  system  that  will  make  for  all 
Member States the customs-relevant information centrally available.  

Page 26 / 237 

 
 
 
                                                 
formalities will be added as they become available at EU central level. Where applicable, this 
option would allow quantity management by customs of supporting documents at EU level69.  

Option  2  –  Interconnecting  national  customs  systems  to  EU  non-customs  regulatory 
formalities digitally available at Member State level  

Option  2  would  cover  EU  regulatory  requirements  managed  through  national  electronic 
systems,  or  a  combination  of  national  and  voluntary  EU  systems70,  which  make  only  the 
customs-relevant  information  from  participating  Member  States  centrally  available  (e.g. 
agricultural  import  and  export  licenses71  and  dual  use  goods  licences).  The  scope  of  this 
option  has  a  dynamic  element  intrinsically  linked  to  the  scope  of  option  1.  Formalities 
currently  under  the  scope  of  option  2  will  be  integrated  into  option  1  progressively  as  EU 
regulatory  formalities  become  digitally  available  for  all  Member  States  at  EU  level.  The 
possibility  to  centralise  national  non-customs  systems  must  be  assessed  on  a  case  by  case 
basis against each regulatory formality under the scope of option 2. This assessment should 
be based on the specific framework of each sectorial legislation72 and conducted through the 
engagement  of  all  relevant  stakeholders.  This  explains  why  the  centralisation  of  existing 
national  non-customs  systems  falls  outside  the  scope  of  this  impact  assessment  and  it  is 
subject to further analysis in the respective areas of competence73.  

For the purpose of this initiative, this option would put in place a legal framework for making 
existing  national  systems  and  future  voluntary  EU  electronic  systems  interoperable  through 
EU  CSW-CERTEX.  This  would  grant  national  customs  systems  access  to  relevant 
information  stored  both  in  their  own  and  other  Member  States’  certification  or  licensing 
systems. Customs authorities of a given Member State would be able to automatically verify 
supporting  documents  issued  in  another  Member  State  and  provide  feedback  of  goods 
clearance for quantity management purposes.  Technical  solutions  for connecting EU CSW-
CERTEX to national certification or licencing systems could either be direct – option 2 (i), 
or indirect – option 2 (ii). 

Option 2 (i) – Direct connection 

Figure  6:  Option  2(i)  –  EU  regulatory  requirements  managed  through  national  systems, 
connecting EU CSW-CERTEX directly 

69   Certain  regulatory  requirements  involve  supporting  documents  that  are  valid  for  a  certain  amount  of  a  given  product. 
Quantity  management  is  the  means  to  verify  that  this  amount  has  not  been  exhausted  before  allowing  goods  to  be 
released. 

70   There are currently no voluntary EU systems managing EU non-customs formalities related to Option 2. Dual use goods 
licences that fall under this category are still processed by national systems. DG TRADE is developing an EU voluntary 
system  (eDUES  licensing  system)  that  would,  in  principle,  not  make  information  from  all  Member  States  centrally 
available.  

71   These licences are currently managed, and the information is only available through national systems. 
72  The sectorial legislation is based on different Union competences in line with the provisions of the EU Treaties, involving 
in  most  cases  intracommunity  requirements  in  addition  to  formalities  affecting  international  trade.    Therefore,  the 
development of these centralised systems requires an individual analysis which takes into account the specific elements 
applicable to each policy domain.  

73   DG ENV has recently conducted a business and technological study resulting in a proposal for an EU implementation of 
the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The main objective of 
the project is to propose an architecture vision for the development of EU CITES electronic system that would address 
the business needs for e-permitting, support the identified CITES business processes and facilitate the communication and 
exchange of CITES permit and certificate information between all stakeholders involved in these processes. DG HOME 
has also conducted a study in 2019 to explore policy solutions to improve the implementation of Article 10 of the UN 
Firearms Protocol (UNFP) in relation to export authorisation, and import and transit measures for civilian firearms, their 
parts and components and ammunition. The study includes the option of setting up an electronic system to manage the 
export licensing procedure.   

Page 27 / 237 

 
 
                                                 
 
Source: DG TAXUD 

EU  CSW-CERTEX  would  establish  a  direct  connection  between  national  customs  systems 
and  existing  national  partner  competent  authorities’  systems  and/or  future  voluntary  EU 
systems.  

Option 2(ii) – Indirect connection 

EU  CSW-CERTEX  would  enable  national  customs  systems  to  access  relevant  information 
stored in the national partner competent authorities’ systems of other Member States through 
their national customs system. Thus, each national customs authority will be responsible for 
collecting  the  relevant  information  on  non-customs  regulatory  requirements  from  their  own 
national competent authority. 

Figure 7: Option 2(ii) – EU regulatory requirements managed through national systems, 
connecting EU CSW-CERTEX indirectly 

Source: DG TAXUD 

Option 3  – Interconnecting national  customs  systems  to national  non-customs regulatory 
requirements in another Member State 

This  option  would  cover  a  wide  spectrum  of  national  non-customs  regulatory  requirements 
managed through national systems, resulting in highly diverse examples (see Annex 8).  

Option 3 would put in place a legal framework for national customs administrations to access 
information  from  the  national  certification/licensing  systems  of  other  Member  States.  The 

Page 28 / 237 

 
 
 
 
need to access information on a national regulatory formality of another Member State would 
only arise in the context of centralised clearance74 whereby the economic operator can lodge 
a customs declaration at the customs office where his activity is established for goods, which 
are presented at another customs office in the EU. Similar to option 2, technical solutions for 
connecting EU CSW-CERTEX to national systems could be either direct or indirect. 

Option  4  –  Interconnecting  national  customs  systems  to  EU  non-customs  regulatory 
formalities digitally available in third countries  

Option  4  would  put  in  place  a  legal  framework  that  would  allow  customs  authorities  to 
electronically  access  information  and  verify  compliance  with  EU  regulatory  formalities 
requiring  third  country  supporting  documents.  Its  scope  covers  EU  regulatory  requirements 
for which there is no EU or national system, such as the Certificate of Origin, VI 1 document 
for wine imports and the Kimberley Process Certification for diamond imports.  

5.3.2  Group II: Business to government (B2G)  

Options  5-7  focus  on  different  ways  of  streamlining  reporting  processes  for  the  economic 
operators  to  customs  and  partner  competent  authorities  when  dealing  with  regulatory 
requirements  mentioned  above. These options  are mutually  exclusive, meaning only one of 
them could form part of a future policy choice. A continuation of the baseline scenario would 
mean  no  EU  action  at  the  front  end,  though  individual  Member  States  may  pursue  related 
initiatives at national level.  

Option 5 – Harmonised portal for economic operators to fulfil EU non-customs regulatory 
requirements 

This option would put in place a legal framework to give economic operators a harmonised 
portal  for  interacting  with  the  various  electronic  systems  used  to  deal  with  EU  regulatory 
requirements  of  partner  competent  authorities.  This  would  give  economic  operators  a 
common  portal  for  lodging  various  types  of  information  regardless  of  the  Member  State(s) 
and/or the partner competent authority involved. However, customs declarations would still 
need  to  be  lodged  separately  through  the  customs  systems  of  individual  Member  States, 
meaning  economic  operators  would  fulfil  regulatory  formalities  through  both  customs  and 
non-customs channels instead of through a single-entry point.  

This option could either cover only regulatory requirements of partner competent authorities 
for which relevant information is stored in EU systems, or a combination of EU and national 
systems.  Individual  Member  States  could  also  facilitate  access  between  the  portal  and 
national  systems  managing  national  regulatory  requirements  in  order  to  expand  its  scope. 
Technical  solutions  for  implementing  this  option  would  be  based  on  the  provisions  of  the 
Regulation  on  electronic  identification  and  trust  services  for  electronic  transactions  in  the 
internal  market  (eIDAS  Regulation)75,  which  facilitates  the  use  of  national  electronic 
identification systems across borders, as well the Commission’s Uniform User Management 
and Digital Signatures (UUM&DS) authentication system. 

74   Centralised clearance is one of the simplifications related to the placement of goods under a customs procedure of the 
Union Customs Code (UCC) that allows economic operators to centralise the accounting and payment of customs duties 
for all their customs transactions. Implementation of Centralised Clearance for Import is dependent on the development 
of an EU system that will allow the transfer of information between Member States in line with the milestones indicated 
in the UCC Work Programme. See also Annex 12. 

75   Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification 
and  trust  services  for  electronic  transactions  in  the  internal  market  and  repealing  Directive  1999/93/EC,  OJ  L  257, 
28.8.2014, p. 73–114. 

Page 29 / 237 

 
 
                                                 
Option  6  –  Harmonised  national  single-entry  points  for  economic  operators  to  fulfil 
customs and non-customs regulatory requirements 

Option 6 would put in place harmonised measures for the Member States to set up customs 
single windows at national level, providing economic operators with harmonised single-entry 
points to fulfil all customs and non-customs regulatory requirements.  

National  customs  authorities  would  act  as  a  hub  for  receiving  relevant  information  from 
economic  operators  on  behalf  of  partner  competent  authorities,  as  part  of  the  customs 
declaration  process.  This  solution  would  enable  economic  operators  to  submit  information 
related  to  non-customs  regulatory  requirements  in  addition  to  customs  data  at  the  time  of 
lodging  the  customs  declaration.  This  information  will  then  be  distributed  to  partner 
competent authorities’ systems via the EU CSW-CERTEX.  Depending on which of options 
1-4 this option is combined with, the result would allow for a degree of interoperability and 
process integration between Member States.  

Option 7 – EU single-entry point for economic operators to fulfil customs and non-customs 
formalities 

This  option  calls  for  the  development  of  a  centralised  EU  electronic  system  that  would 
provide (1) a common interface for economic operators to submit both customs declarations 
and  all  other  data  needed  to  fulfil  non-customs  regulatory  requirements  and  (2)  a  common 
repository that would replace existing national systems for import, export and transit. In other 
words, this option would introduce a single-entry point at EU level for all border formalities 
required  for  the  clearance  of  goods.  This  information  will  then  be  distributed  to  partner 
competent  authorities’ systems via the EU CSW-CERTEX as needed to  verify compliance. 
Due  to  the  specific  features  of  this  option,  the  way  it  could  be  combined  with  options  1-4 
differs  from  option  6  in  terms  of  interoperability  and  system  integration.  Given  that  its 
implementation  would  replace  existing  national  customs  systems  with  a  single  centralised 
system, this option could only be combined with a simplified version of option 1 that entails a 
single  connection  to  EU  CSW-CERTEX.  For  the  same  reason,  it  would  be  impossible  to 
implement option 7 alongside the indirect connection versions of options 2 and 3.  

5.3.3  Group  III:  Cross-cutting  options  for  registration  and  identification  of 

economic operators  

Option  8  –  Extend  the  use  of  the  Economic  Operator  Registration  and  Identification 
System (EORI) to partner competent authorities 

This  is  a  cross-cutting  option  that  aims  to  extend  the  use  of  the  Economic  Operator 
Registration and Identification system (EORI)76 to partner competent authorities. While this 
is not a standalone option, it would serve as a facilitation tool to implement G2G and B2G 
options. This would allow customs and partner competent authorities to exchange, collect and 
receive information about economic operators more easily, with the purpose of reducing the 
administrative  burden  on  economic  operators  and  facilitating  the  implementation  of  any  of 
the other policy options chosen. Two alternatives can be considered under this option:  

a)  Option  8(i)  would  extend  EORI  to  partner  competent  authorities  for 
registration, identification and validation purposes. This  sub-option would  imply 
the  registration  of  additional  businesses  who  are  not  registered  with  the  customs 

76   EORI is a database managed by DG TAXUD that assigns all economic operators engaging in customs operations with a 
unique number (the EORI number) that is used as an identifier for all dealings with customs authorities in the EU.  

Page 30 / 237 

 
 
                                                 
authorities, as EORI would become a common registration and identification number 
for customs and partner competent authorities involved in international trade.  

b)  Option  8  (ii)  would  grant  access  to  EORI  system  to  partner  competent 
authorities  for  validation  purposes.  This  would  mean  they  can  request  the  EORI 
number  from  economic  operators  in  the  context  of  their  formalities  and  validate  it 
against  the  EORI  systems,  but  not  register  on  the  basis  of  this  initiative  additional 
businesses which are not covered under the UCC77. 

As a reference point for the foregoing problem analysis and proposed options, a summary of 
the  intervention  logic  of  the  initiative  is  presented  in  the  figure  below.  It  provides  a  visual 
representation  of  the  links  between  the  identified  problems,  their  drivers,  the  specific 
objectives for further intervention and the options that are likely to achieve these objectives. 
Although  the  impacts  of  each  proposed  option  category  would  likely  influence  all  three 
objectives  to  a  limited  extent,  the  arrows  connecting  the  specific  objectives  to  the  policy 
options represent the most relevant links.  

Figure 8: Intervention logic 
Source: DG TAXUD 

5.4 Options discarded at an early stage 

The options have been screened to focus the analysis on the most viable ones. The screening 
exercise was carried out based on evidence collected from stakeholders in the project group 
and  Commission  services,  using  criteria  for  technical  feasibility,  effectiveness  and 
proportionality.  The  results  are  presented  in  the  table  below,  with  a  preliminary  judgement 
and explanation provided for each option and criterion. The last column states whether an in-
depth analysis or a limited analysis would be appropriate for each option. 

77   Article 5(5) of the UCC defines the economic operator as “a person, who in the course of his or her business, is involved 

in activities covered by the customs legislation”. 

Page 31 / 237 

 
 
 
                                                 
Table 3: Screening of the policy options 

Option 1 

Technically feasible 
Yes; the viability has been tested through 
the  EU  SW-CVED  pilot  and  EU  CSW-
CERTEX project. 

Likely to be effective 
Yes;  results  of  the  EU  SW-CVED  pilot 
and  initiatives  similar  to  this  option  at 
national  level  indicate  that  significant 
benefits could be expected in terms of all 
the policy objectives as defined.  

Proportionate 
Yes;  while  substantial  benefits  would  be 
expected,  this  option  uses  fairly  low-cost  DG 
TAXUD  middleware 
link 
existing/planned EU electronic systems. Evidence 
from  the  EU  SW-CVED  pilot  also  shows  just 
limited  costs  for  the  Member  States,  while 
economic operators would incur hardly any costs.  

order 

in 

to 

Option 2 

Option 3 

Option 4 

Option 5 

technical 

feasibility  has  been 
Yes; 
investigated  through  the  project  group, 
showing 
the  DG  TAXUD 
middleware could be used to link national 
systems and / or any relevant EU systems. 

that 

of 

No;  linking  the  systems  for  the  wide 
spectrum 
regulatory 
requirements  concerned  (see  Annex  8)  is 
unlikely  to  be  possible  using  the  EU 
CSW-CERTEX system.  

national 

Implementing  this  option  would  require 
changes  to  third-country  systems  that 
would  depend  on  bilateral  or  multilateral 
agreements  on  a  case-by-case  and 
country-by-country basis.  

Yes;  preliminary  research  carried  out  for 
the  policy  options  document  shows  that 
the technical developments for this option 
would be straightforward. 

investigation; 
Unclear  without  further 
benefits from key functions (e.g. quantity 
management)  would  depend  on  the  full 
participation of Member States.  

Unclear without further investigation; the costs to 
the  Member  States  could  be  substantial  and 
would need to be compared to the likely benefits.  

No;  information  on  national  regulatory 
formalities  of  another  Member  State 
would  only  be  required  in  the  context  of 
centralised 
which 
clearance 
alternative solutions are being explored78. 

for 

No;  the  major  investments  needed  at  national 
level  and  EU  level  to  link  each  of  the  many 
relevant  electronic  systems 
to  EU  CSW-
CERTEX would outweigh the benefits that would 
be realised. 

No;  preliminary  stakeholder  feedback 
suggests 
the  goods  movements 
involved  are  not  a  major  cause  of  the 
identified problems (see section 5.1).  

that 

No; despite the limited benefits, the costs to link 
EU, Member States and third country systems are 
likely to be substantial.  

No; while this option would put in a place 
a  common  portal  for  economic  operators 
to  deal  with  key  supporting  documents, 
they would still have to deal with customs 
authorities  separately,  strongly  limiting 
the gains for trade facilitation. 

No;  the  costs  to  DG  TAXUD  to  develop  the 
portal  and  for  partner  competent  authorities  and 
economic operators would be substantial and out 
of proportion to the limited potential benefits.  

Level of analysis 
In  depth  analysis;  this  option  is 
highly  feasible  and  likely  to  be 
effective and proportionate.  

In  depth  analysis;  while  this option 
is feasible and potentially effective, 
key aspects concerning the viability 
of  this  option  remain  unclear  and 
are subject to further investigation. 

Limited;  given  that  this  option  is 
neither  feasible  nor  likely  to  be 
effective or proportionate. 

Limited given that this option is not 
yet  technically  feasible  or  effective 
in 
identified 
problems.  

addressing 

the 

this  option 

Limited;  the  likely  ineffectiveness 
of 
the 
objectives  means  it  does  not  make 
sense to investigate it in depth.  

to  achieve 

78   From a legal perspective, centralised clearance (CC) enables economic operators to lodge a customs declaration at the customs office where their activity is established for goods presented 
at another customs office in the EU (Art. 179 UCC). The EU Commission is currently developing an IT system to support the exchange of relevant electronic information between these 
offices. Regarding the transmission of national supporting documents (certificates, licences, permits, etc.), potential technical solutions identified under this project include the e-Delivery 
platform (developed by DIGIT and already used in other customs projects) and the Common Communication Network (CCN2) - DG TAXUD’s central IT infrastructure - which is already 
supporting other electronic EU customs systems. These potential solutions explored in the context of CC offer more flexible and less costly alternatives than routing the information through 
EU CSW-CERTEX for all regulatory formalities that fall within the scope of Option 3.  

Page 32 / 237 

 
 
                                                 
Option 6 

Option 7 

according 

Technically feasible 
Yes;  this  option  leaves  key  aspects  to  be 
to 
defined 
national 
prerogatives, 
its  feasibility. 
increasing 
The  B2G  use  cases79  on  a  selection  of 
regulatory  requirements  also  show  that 
the necessary changes to the systems and 
trader interfaces can be developed.  

Yes; although it would require wholesale 
changes to the approach for implementing 
the provisions of the UCC.  

Likely to be effective 
Yes; the B2G use cases on a selection of 
regulatory  requirements  show  that  this 
option  is  likely  to  generate  substantial 
benefits for traders.  

Proportionate 
Unclear without further investigation; this option 
would  entail  considerable  development  and 
implementation  costs  for  the  Commission  and 
Member States authorities. Further data is needed 
to  estimate  these  and  compare  them  with  the 
likely benefits.  

Level of analysis 
evidence 
preliminary 
In-depth; 
shows  that  this  option  is  feasible 
and  likely  to  be  effective,  showing 
its  viability  and  meriting  in-depth 
investigation.  

Yes; the experience of the US shows that 
this  option  could  have  major  benefits  in 
terms  of  increased  efficiency  of  goods 
clearance  and  improved  compliance  / 
reduced fraud and errors.  

implementation  of 

The 
this  option  would 
radically  change  the  regulatory  and  operational 
the  Customs  Union,  allowing 
practices  of 
economic  operators  to  access  a  single  EU  portal 
for  international  trade  formalities.    The  costs  to 
the  Commission,  Member  States  and  economic 
operators  would  be  substantial  and  difficult  to 
ascertain without in-depth analysis.  

this  option 

In-depth;  while 
is 
technically  feasible  and  potentially 
effective,  key  aspects  concerning 
the  viability  and  proportionality  of 
this  option  remain  unclear,  subject 
to further investigation.  

Option 8(i) 

No; it would require major changes to the 
current  framework.  The  cases  where 
existing  registration  systems  should  be 
replaced by EORI are diverse and involve 
multiple  authorities.  Thus,  they  would 
need to be addressed individually. 

Yes; 
this  option  would  particularly 
benefit  economic  operators  by  providing 
a  single 
for 
customs and non-customs formalities.   

registration  mechanism 

(including 

those  based 

No; it would require many additional and diverse 
businesses 
third 
countries  or  involved  in  intra-  community  trade) 
to  register  in  EORI.  This  would  be  highly 
complex and costly and would not prevent some 
businesses  having  to  register  for  other  purposes 
such as VAT.    

in 

Limited; 
evidence 
preliminary 
shows that this option is not viable.  

Option 8(ii) 

Yes; the technical implementation of this 
option is straightforward.  

indicates 

Yes;  preliminary  evidence  based  on  a 
pilot  in  one  country  and  stakeholder 
feedback 
this  option  would 
make  it  much  easier  to  collect  and  share 
information on economic operators, since 
existing  systems  for  managing  economic 
operators 
not 
interoperable.  

disparate 

and 

are 

Yes;  preliminary  evidence  indicates  that  the 
likely  costs  would  be  low  compared  to  the 
benefits.  

analysis; 

preliminary 
In-depth 
evidence  indicates  that  this  option 
provides  a  feasible  and  practical 
way to facilitate the implementation 
of the other policy options.  

79   B2G use cases were carried out in the framework of the project group for CHED-A, Waste shipment, FLEGT and FGAS regulatory requirements led by Czech, Dutch and Spanish customs 

authorities and one trade association, with the coordination of DG TAXUD and collaboration of partner DGs. See Annex 1 and 2 for more information.   

Page 33 / 237 

 
 
 
 
                                                 
The  screening  of  the  policy  options  determined  that  three  options  and  one  sub-option  were 
unviable  due  to  a  lack  of  feasibility,  likely  effectiveness  and  /  or  proportionality.  These 
options are thus not analysed in depth. However, a brief overview of the economic, social and 
environmental  impacts  that  could  be  expected  if  these  obstacles  were  to  be  overcome  is 
provided in Annex 12. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section describes the approach to the analysis of the options, in terms of the sources of 
evidence and methods for estimating the impacts and applies this framework to assess options 
1,  2,  6,  7  and  8(ii),  in  terms  of  stakeholder  views,  direct  economic  impacts,  social  and 
environmental impacts and potential risks.  

6.1  Approach to the analysis of the options 

The main criteria to  assess  the policy options are closely linked to  the  general and specific 
objectives  of the initiative and can be grouped into direct  economic impacts  and social  and 
environment impacts. 

The direct economic impacts are comprised of one-off implementation and recurrent costs, 
as  well  as  savings  from  reduced  amounts  of  labour  and  out-of-pocket  expenses  (e.g.  for 
delays,  intermediaries,  storage  facilities  etc.)  needed  for  customs  authorities,  partner 
competent authorities and economic operators to enforce EU legislation and deal with goods 
clearance.  These  savings  would  relate  to  achievements  in  terms  of  the  first  and  second 
specific objective of enhanced cooperation and improved working practices between customs 
and  partner  competent  authorities,  and  to  the  third  specific  objective  of  data  harmonisation 
and  re-use  of  data  provided  by  economic  operators  when  fulfilling  the  customs  and  non-
customs formalities required for international trade, as they will all contribute to simplify the 
clearance  processes  for  economic  operators.  To  the  extent  possible,  the  analysis  seeks  to 
quantify and monetise these impacts  to  determine their net  costs or benefits  over time. The 
objectives are not referenced repeatedly in the analysis to enhance readability. 

The  approach  has  been  developed  with  a  view  to  the  complex  regulatory  framework  and 
diverse  operations  and  processes  at  stake.  In  particular,  it  is  noted  that  the  timing  for 
submission  of documents and extensiveness  of checks vary  by type of  good and regulatory 
requirement,  meaning  that  experiences  for  both  authorities  and  economic  operators  may 
differ depending on factors such as the Member State and nature of the goods in question. In 
addition,  the  cost  for  the  Member  States  to  implement  new  IT  infrastructure  differs 
substantially depending  on the maturity  of their  existing  IT  architecture,  arrangements with 
service  providers,  and  varying  capacity  requirements,  which  are  based  on  trading  volumes 
and profiles. Due to these issues, it is very difficult to extrapolate individual examples from a 
limited  number  of  Member  States  to  the  whole  EU.  Moreover,  in  many  cases,  national 
administrations were reluctant to provide detailed information on the costs of IT projects and 
process changes and time spent by officials to perform controls due to its political sensitivity. 
To obtain quantitative estimates despite these challenges, the analysis of direct impacts relies 
on plausible assumptions based on the available data and stakeholder feedback. For example, 
some participants in the project group, representing highly diverse Member States, provided 
insight into their IT infrastructures and the extent of likely changes needed to implement the 
different policy options, including on costs. While this input cannot be cited directly due to 
confidentiality  concerns,  it  allows  to  develop  plausible  estimates  for  a  range  of  scenarios. 
Similarly,  qualitative  data  about  business  processes  and  experiences  with  the  clearance  of 
certain  goods  is  used  to  come  up  with  estimates  concerning  time  savings  that  could  be 
expected from the introduction of a certain process improvement.  

Page 34 / 237 

 
In all cases, the high degree of diversity among Member States and regulatory requirements 
in  question,  as  well  uncertainty  regarding  future  changes,  makes  it  impossible  to  define 
simple figures  that could be applied to  the whole EU. At the same time,  the data, which is 
sensitive and not comprehensive, do not allow for detailed breakdowns by Member State. For 
this reason, EU-wide figures are used, based on plausible ranges with regard to the costs and 
potential changes that could be expected. Finally, to ensure the reliability of the ranges, these 
were validated in consultation with project group participants representing the Member States 
and trade associations.  

One-off  implementation  and  recurrent  costs  would  be  borne  by  the  EU  Commission, 
national  customs  authorities,  partner  competent  authorities  and  economic  operators. 
Implementation  costs  include  spending  on  IT  hardware  and  software,  process  change 
management,  training  and  support,  and  are  expected  to  be  phased  over  an  implementation 
period. The timing for these implementation periods has been developed in consultation with 
IT units at DG TAXUD and varies depending on the option. For most options (1, 2, and 6), 
this  implementation  period  would  be  seven  years.  This  timeframe  is  consistent  with 
experiences  of  other  customs  IT  projects  of  similar  size  and  scope  (including  the  well-
developed pilot solution EU CSW-CERTEX, which forms the basis for option 1). The time 
needed  for  development  and  implementation  is  much  longer  for  option  7  due  to  its  larger 
scale  and  complexity,  while  option  8(ii)  would  be  operationalised  much  more  quickly. 
Afterwards,  implementation  costs  will  be  replaced  by  recurrent  costs,  comprised  of 
maintenance, periodic updates, continued support and day-to-day operations. The table below 
lists  the  sources  used  to  estimate  the  costs  for  different  actors,  while  full  explanations  are 
provided in the sections on the impacts of each policy option. 

Table 4: Sources for cost estimates for involved actors 

Actor 
EU Commission 

National customs 
authorities and 
partner 
competent 
authorities 

Economic 
operators 

Source: DG TAXUD 

Based on data provided by DG TAXUD. 

Sources for cost estimates 

these  figures  was  verified  with 

Based  on  some  documentary  sources  (e.g.  technical  specifications)  and  interviews 
with experts and stakeholders. Despite the level of progress with national initiatives, 
very few Member States were able to provide hard data on IT and business costs80. 
The  credibility  of 
the  national  customs 
administrations  participating  in  the  project  group.  In  terms  of  variation,  larger 
Member States would typically incur larger costs while smaller Member Stats incur 
lower  costs.  However,  the  prevalence  of  fixed  costs  means  that  smaller  Member 
States would likely face costs that are relatively higher compared to their proportion 
of  international  trade.  At  the  same  time,  for  all  options  these  costs  are  much  lower 
than  would  be  incurred  if  individual  Member  States  had  to  develop  all  elements 
individually.   

The G2G options (i.e. options 1 and 2(i) and 2(ii)) and cross-cutting option 8 do not 
entail  any  front-end  changes  that  would  generate  costs  for  economic  operators. 
Option  6,  in  creating  a  single-entry  point  for  interactions  with  customs  and  non-
customs authorities, would require very slight adjustments related to the introduction 
of a few new data elements. However, these are deemed negligible both due to their 
small  scale  and  the  fact  that  implementation  would  be  phased  over  several  years. 
Option  7,  by  requiring  economic  operators  to  adjust  to  a  new  system  for  customs 
clearance, would involve some IT and training costs.  

80   Officials  were not authorised to share cost figures, which were considered sensitive in the context of national budget 
discussions.  Also,  it  is  difficult  to  extrapolate  from  the  Member  States  where  some  data  is  available  because  of 
differences in IT architecture and trade volumes. 

Page 35 / 237 

 
 
                                                 
The  direct  economic  benefits81  would  relate  to  reduced  administrative  burdens  and  are 
estimated based on a variant of the standard cost model82. The model works by multiplying 
the number of information obligations83 with  the cost  for different  stakeholders. Due to  the 
unavailability of sufficient data on the baseline costs, the research has allowed for estimates 
regarding  the  amount  of  time  saved  per  information  obligation  under  the  different  policy 
options. For each option, the model is then applied by multiplying the number of obligations 
(expressed in terms of the number of customs declarations for which supporting documents to 
comply  with  certain  non-customs  regulatory  requirements  are  required)  with  the  amount  of 
time saved. The latter is monetised using standard hourly labour costs. Each of these aspects 
is described in more detail below.  

a)  Number of affected customs declarations: estimates are derived based on extrapolations 
from  extensive real  data from  the Member States. More specifically, 15  Member States 
participating in the project group provided data on the numbers of customs declarations 
subject to certain regulatory requirements during the years 2015-2017. By assuming that 
the  numbers  of  relevant  declarations  varied  roughly  in  proportion  to  international  trade 
volumes, it was possible to extrapolate these figures to the whole EU using Eurostat trade 
statistics.  Since  the  envisaged  social  and  environmental  impacts  also  depend  to  a  great 
extent  on  which  customs  declarations  are  affected,  these  are  also  informed  by  these 
estimates. Since any of the policy options that is implemented would become operational 
gradually, the analysis assumes that implementation would be spread over a time period 
that is described in the analysis of each option. 

b)  Time  saved  for  each  operation  (in  minutes):  estimates  are  made  based  on  feedback 
from  national  officials  and  economic  operators  about  how  (1)  clearance  processes 
changed  after  the  implementation  of  EU  CSW-CVED  and  relevant  national  single 
window initiatives, and (2) the specific policy options would be likely to affect existing 
practices. While the time savings would be distributed across the Member States in line 
with  their  trading  volumes,  the  estimates  also  need  to  take  into  account  the  different 
starting  points  across  Member  States.  For  example,  relatively  lower  savings  would  be 
expected for the customs declarations that are already dealt with using the single window 
initiatives that are in place in a small number of Member States.84 Higher savings would 
be expected where less progress has been achieved at national level, such as the Member 
States  that  have  not  participated  in  EU  CSW-CERTEX  or  developed  a  similar  national 
solution  so  far.  Taking  these  aspects  into  account  as  well  as  the  inherent  degree  of 
uncertainty (see discussion below), estimates are presented in terms of a range of values 
for  the  plausible  time  savings.  It  is  also  noted  that  the  delays  and  process  redundancies 
that characterise the present situation (see section 2.3.1) have been found to affect SMEs 

81   The  direct  economic  benefits  could  be  expected  to  lead  to  indirect  benefits,  in  particular  improved  competitiveness 
derived from increased efficiency and reduced resource waste among EU firms. However, in order for these benefits to 
materialise (at a noticeable and measurable scale), the change in the time to needed goods clearance should be large and 
discrete, e.g. in the order of numbers of days per transaction rather than minutes or hours. Since none of the options are 
found to produce benefits at this scale, it is assumed that impacts on competitiveness are positive but minor, and likely 
to be experienced in a similar way for each policy option in line with the magnitude of the expected direct economic 
benefits. 

82   The standard cost model is a method for assessing administrative costs imposed by a regulation on, among other things, 
businesses and public administrations. It is based on the identification of information obligations whose costs for the 
regulatory addressees can be measured and quantified. Impact can be calculated by comparing the total costs under the 
baseline scenario with costs under a new intervention. However, such a comparison is not possible in this case because 
sufficient data on the costs of complying with given information obligations is not available.   
Information  obligations  can  be  defined  as  specific  legal  duties  to  gather,  process,  or  submit  information  to  a  public 
authority or third party. 

83  

84     For example, CHED certificates are already handled using the national single windows in France, Italy and Spain.  

Page 36 / 237 

 
 
                                                 
disproportionately. This is due to SMEs’ limited ability to make investments that would 
allow  them  to  handle  administrative  burdens  more  efficiently  and  unfamiliarity  with 
complex  processes.  For  example,  the  supporting  study  for  this  Impact  Assessment 
identified examples where senior staff of SMEs needed to physically transport documents 
between  competent  authorities  and  customs  offices  to  deal  with  a  single  declaration. 
Larger  companies  typically  deal  with  higher  volumes  of  declarations,  providing  the 
economies  of  scale  that  allow  them  to  put  in  place  more  efficient  processes  or  to 
outsource customs operations. Since all of the options seek to reduce burdens of this kind, 
SMEs  would  experience  comparatively  large  benefits  compared  to  other  economic 
operators, regardless of the policy option. The reductions in administrative burdens could 
also be expected to increase the number of SMEs participating in international trade85. 

c)  Labour costs (in EUR): the time saved for different actors can be monetised by applying 
a standard labour cost for staff of national authorities and economic operators. To derive 
this cost, Eurostat data on average salaries in EU public administration (adjusted to take 
account  of overheads, social security  contributions,  etc.) was divided by  OECD data on 
average hours worked per  year in  the EU Member States to  arrive at  an average hourly 
cost.  This  figure  was  then  weighted  based  on  the  extent to  which  given  Member  States 
engage  in  international  trade.  This  ensures  that  the  estimates  take  into  account  the 
differing  extent  to  which  individual  Member  States  would  be  affected  by  the  initiative. 
This leads to a figure of about EUR 24 per hour of labour.  

These  findings  on  costs  and  benefits  are  then  compared  using  cost-benefit  analysis  to 
determine the likely net impact of each policy option. The estimates are also supplemented 
with qualitative evidence to highlight potential exceptions and explain why certain impacts 
can be expected. As mentioned above, there is uncertainty in the estimates, especially related 
to  the  time  savings  that  the  policy  options  could  be  expected  to  generate.  This  is  in  part 
because  of  the  scarcity  of  concrete  data  that  could  be  extrapolated.  It  is  also  due  to  the 
varying  levels  of  complexity  and  amounts  of  time  needed  to  deal  with  the  processes  that 
would be affected by the initiative. This uncertainty is reflected in the ranges of values that 
are  used  for  the  estimated  costs  and  benefits.  The  ranges  are  particularly  large  for  the 
estimated benefits to reflect the diversity of impacts across Member States, in addition to the 
lack of reliable data.  

The mechanisms that would generate social and environmental impacts are very similar for 
all  of  the  policy  options  and  relate  mainly  to  the  effects  from  the  specific  objectives  of 
enhanced collaboration and improved working practices between authorities. As outlined in 
the  general  objective,  this  would  lead  to  better  enforcement  of  the  regulatory  requirements 
covered. This would stem from reduced fraud and errors, as well as better risk management 
and compliance with applicable rules during goods clearance. The proper enforcement of the 
EU-wide policies at stake will provide social and environmental benefits for EU citizens by 
ensuring their safety and security, improving the quality of imported products, protecting the 
environment and ultimately boosting innovation in the internal market. Given the existence of 
a  single  external  border  and  free  circulation  of  goods  within  the  EU,  these  benefits  are 
considered in terms of the EU as a whole. This is especially important because illicit traders 
often  seek  to  exploit  weaknesses  in  individual  Member  States,  regardless  of  their  final 
destination. Due to the sensitive and complex nature of the regulatory formalities in question, 
little data is available on indicators of interest, such as fraud levels or amounts of information 

85   As shown in the recent report ‘Making the WTO Trade Facilitation Agreement Work for SMEs’ (WTO 2016), customs 

and trade regulations are among the most important obstacles faced by SME exporters.  

Page 37 / 237 

 
 
                                                 
sharing between authorities responsible for goods clearance. For this reason, the analysis of 
these  impacts  is  conducted  mainly  qualitatively,  based  on  extensive  consultation  with  all 
affected stakeholders. The main differences between options are in scope (since the options 
cover  different  regulatory  requirements  and  thus  would  lead  to  benefits  in  different  policy 
areas) and magnitude (since the expected changes from some options are more important than 
others).  To  avoid  repetition,  the  mechanisms  are  described  in  depth  only  in  the  analysis  of 
option 1. The other options are analysed compared to the baseline in the same terms, using 
examples where useful.  

6.2  Analysis of the impacts of the policy options  

Option  1  –  Interconnecting  national  customs  systems  to  EU  non-customs  regulatory 
formalities digitally available at EU central level 

Stakeholder views 

Member State administrations  

Most Member States are favourable of this option as expressed in a survey of project group 
participants86 on the feasibility and desirability of the different policy options. In terms of the 
regulatory  requirements  covered,  broad  agreement  was  reached  on  significant  expected 
benefits, as described below: 

  Quicker and smoother goods clearance would in turn lower administrative costs.  
  Easier  sharing  of  information  would  reduce  the  duplication  of  tasks  between  different 

authorities, further increasing administrative efficiency. 

  Better  coordination  between  authorities  would  improve  enforcement  of  EU  legislation 

 

and data security (less information would have to be stored in multiple databases).  
Introduction of automated quantity management at EU level would reduce the scope for 
fraud and human error.  

  Participation  of  all  Member  States  in  EU  CSW-CERTEX  would  be  an  important  step 
towards fully digitised goods clearance, since it would push partner competent authorities 
to digitise their processes and thereby stop using paper-documents87.  

Criticism  of  this  option  is  limited  to  two  aspects:  first,  for  Member  States  already  having 
advanced  digital  initiatives,  mandatory  use  of  EU  CSW-CERTEX  could  risk  undermining 
efforts  that  have  already  been  made.  Secondly,  some  Member  States  felt  that  to  justify  the 
costs of this option it would be important to prioritise high-volume regulatory requirements, 
rather than immediately covering all regulatory requirements in its defined scope. 

Economic operators   

Trade associations in the project group and a range of economic operators interviewed during 
field visits expressed largely positive views, feeling that the benefits generated by this option 
would  be  important  in  terms  of  time  savings.  Moreover,  economic  operators  in  Member 
States with ongoing national initiatives similar to option 1 reported that these initiatives have 
allowed them to simplify the processes of submitting and handling the supporting documents 
related  to  relevant  regulatory  requirements.  For  example,  in  Italy  economic  operators 

86  Of  the  15  Member  States  responding  to  the  survey,  12  rated  it  highly  for  overall  desirability,  while  11  considered  it 
politically feasible and 13 considered technically feasible. These positive views were in part due to significant expected 
benefits, and in part to the relatively minor changes, this option would  require to national IT infrastructure, clearance 
processes and national legislation. 
Interviews with national officials and discussions in the project group show that this would resolve a problem whereby 
the lack of a  mandatory push from EU level prevents them  from  compelling partner competent authorities to digitise 
their systems and processes. 

87  

Page 38 / 237 

 
 
                                                 
reported that the full automation of certain documents eliminated the cost of transporting the 
documents  between  authorities,  benefiting  from  faster  clearance  and  fewer  delays.  The 
majority of economic operators responding to the public consultation felt that key features of 
option 1 were high priorities.  

Direct economic impacts 

Implementation and recurrent costs  

For  the  European  Commission,  the  starting  point  would  be  the  EU  CSW-CERTEX 
architecture,  which  is  already  functional  for  a  number  of  regulatory  requirements.  The 
additional implementation costs would relate to expanding its coverage, traffic capacity and 
functionalities  in  line  with  the  expected  features  of  this  option,  in  addition  to  associated 
change management, training and support. This would involve making connections between 
EU  CSW-CERTEX  and  several  existing  or  future  EU  electronic  systems  managing 
regulatory formalities. During phased implementation for years 1-788, DG TAXUD estimated 
implementation  and  running  costs  of  EUR  4.1m  per  year,  making  a  total  of  EUR  28.7m. 
From year 8 onwards, once the system is fully operational, costs were expected to drop, but 
only  by  about  20%  given  the  substantial  maintenance  and  need  for  continued  coordination 
and support for different actors at European and national levels. This would make for annual 
recurrent costs of about EUR 3.28m.  

For  Member  State  customs  and  partner  competent  authorities,  the  implementation  and 
running costs would be substantial, but not excessive. In practical terms, the implementation 
costs at Member State-level would relate to making the necessary connections, coupled with 
revisions  to  standard  operating  procedures,  training  and  support.  Recurrent  costs  would 
consist of ongoing maintenance and updates, as well as ongoing support for users. Consulted 
IT  experts  and  national  officials  confirmed  that  these  would  be  much  smaller  than  the 
Commission costs at the level of individual Member States, since much of the infrastructure 
would be dealt with at European level. At the least, yearly costs for the Member States would 
be about half the Commission costs, i.e. EUR 2.05m could be expected for implementation 
during  years  1-7,  followed  by  recurrent  costs  of  about  EUR  1.64m  from  year  8  onwards. 
However, if the changes required are more significant  (e.g. some Member States  choose to 
put in place measures to further increase security and reliability beyond the very high level 
that would be foreseen in the EU CSW-CERTEX IT architecture), then higher costs could be 
foreseen,  equal  to  the  Commission  costs  of  EUR  4.1m  per  year  from  years  1-7,  thereafter 
EUR 3.28m from year 8 onwards.  

These  estimates  assume  that  the  costs  would  be  lower  for  the  Member  States  already 
participating  in  the  EU  CSW-CERTEX  pilot  (albeit  only  to  a  minor  extent,  because  only  a 
limited number of regulatory formalities have been included so far). Similarly, the estimates 
also  consider  the  switching  costs  for  the  several  Member  States  with  functioning  national 
Single  Window  initiatives  in  place;  these  costs  are  deemed  minor,  because  they  would  be 
offset by reductions to maintain analogous infrastructure at national level.  

Table 5: Estimated implementation and recurrent costs for option 1 (in €m) 

88   The  estimated  seven-year  implementation  period  is  based  on  experience  of  EU  CSW-CERTEX,  which  this  option 
builds on. This takes into account a progress and continuous phase-in, during which additional non-customs regulatory 
requirements are continuously added and progressively become operational, thereby moving into a maintenance mode. 
The phase-in allows for different amounts of time needed for individual national customs authorities to connect to the 
system, and is broadly consistent with other EU customs IT projects of similar scale.  

Page 39 / 237 

 
 
                                                 
Implementation costs (years 1-7) 

Recurrent costs (year 8 onwards) 

EC  

4.1 / year (28.7 total) 

3.28 / year 

MS 
and 
customs 
competent authorities  

partner 

From 2.05 year  to 4.1m / year  
(14.35 to 28.7 total) 

1.64 / year to 3.28 / year 

Total  

From 6.15 / year to 8.2 / year  
(43.05 to 57.4 total) 

From 4.92 / year to 6.56 / year  

Source: Estimates based on  figures from DG TAXUD for EU Commission costs and Member State data and consultation 
with IT89 experts for MS cost  

The  Member  States  considered  the  economies  of  scale  from  EU-level  collaboration  and 
limited pressure on national budgets as key advantages of this policy option.  

Recurrent benefits  

For  customs  authorities,  this  option  would  lead  to  important  process  changes  that  would 
save significant time. In broad terms, instead of needing to ask economic operators to provide 
physical  documents  to  support  customs  declarations,  the  necessary  information  would  be 
delivered to customs IT systems (in the correct data format) electronically and securely from 
EU electronic databases where they are managed and stored. The change would be especially 
pronounced  for  regulatory  requirements  where  quantities  of  authorised  goods  can  be  split 
across  multiple  customs  declarations.  With  the  introduction  of  automated  quantity 
management, the verification would be instantaneous and secure, preventing any goods over 
the authorised quantity from being cleared. Having all information in electronic form makes 
it easier, where relevant, to coordinate checks with partner competent authorities. Moreover, 
the  nonstop  availability  of  automated  documentary  controls  would  substantially  improve 
operational efficiency for customs officials with no increase in resources. 

France,  Italy  and  Spain  reported  process  changes  and  significant  time  savings  for  customs 
officials  due  to  speeded  up  and  in  many  cases  automated  documentary  controls.  Member 
States, using the EU CSW-CVED pilot, envisaged similar improvements and savings. Based 
on the feedback, it can thus be assumed that substantial time savings are likely. However, the 
processes for dealing with some customs declarations have more room for improvement than 
others due to the diversity both in processes for different regulatory requirements, and across 
Member States.  

Since the available data covers only a small proportion of relevant customs declarations, it is 
not possible to formulate a generalised estimate that captures this diversity in a precise way. 
Instead, the estimate is  based on a range that aims  to  take account  of the uncertainty while 
maintaining  a  reasonable  degree  of  confidence  in  the  results.  This  range  was  estimated  to 
generate savings of 45 minutes per declaration at the high end and 30 minutes per declaration 
at the low end. Applying the standard cost model as described above, yearly benefits for EU 
customs authorities from time savings of EUR 49.5m to EUR 74.3m could be expected once 
implementation is complete.  

Processes  would  also  be  simplified  and  made  more  efficient  for  partner  competent 
authorities.  Instead  of  needing  to  provide  validated  supporting  documents  to  economic 
operators,  this  option  would  allow  the  automated  transfer  of  electronic  information  to 
customs  authorities.  Interviewees  agreed  that  envisaged  improvements  would  hold  true  in 
practice,  and  thereby  lead  to  some  time  savings.  However,  from  the  perspective  of  partner 

89   Consultation  with  IT  experts  supporting  the  ICT  assessment  of  the  initiative  for  developing  an  EU  Single  Window 
environment for customs (building on the policy work carried out by EU Single Window project group). See Annex 15. 

Page 40 / 237 

 
 
 
 
                                                 
competent  authorities,  the  time  spent  on  collating  and  sending  documents  was  considered 
relatively  small,  especially  compared  to  the  effort  needed  to  examine  the  documents  and 
carry  out  physical  controls.  Taking  this  into  account,  and  allowing  for  a  degree  of 
uncertainty,  the  savings  are  estimated  at  two  to  five  minutes  for  each  relevant  customs 
declaration. This would be expected to add up to substantial yearly benefits, from EUR 3.3m 
to EUR 8.3m.  

For economic operators, the option is expected to generate major efficiency gains and time 
savings.  The  G2G  connection  facilitating  the  transfer  between  authorities  would  reduce  the 
cases where economic operators would need to submit the supporting documents to customs. 
In  addition,  the  nonstop  availability  of  automated  documentary  controls  would  generate 
significant  time  savings  benefits  for  economic  operators  in  cases  where  declarations  are 
lodged outside working hours.  

In  France,  Italy  and  Spain  where  national  single  windows  have  been  introduced,  economic 
operators  described  concrete  changes  to  their  working  practices  that  have  resulted  in  major 
benefits.  For  example,  a  customs  broker  in  Italy  explained  that,  prior  to  the  national  single 
window,  the  operator  was  responsible  for  physically  transporting  documents  between 
competent partner authorities and the customs authority. This required considerable time and 
/  or  costs  from  courier  services,  in  addition  to  leading  to  delays  that  had  knock-on  effects 
such as storage costs and lost business from disappointed customers. These costs have now 
been cut to zero, since the supporting documents in question are sent electronically between 
authorities,  without  any  action  from  the  economic  operator.  Similarly,  the  national  single 
window  has  allowed  economic  operators  to  conduct  detailed  status  checks  on  their 
declarations  online,  avoiding  un-necessary  calls  to  the  authorities  or  trips  to  pick  up  goods 
that are not ready. The introduction of the single window has also led to coordinated checks 
between customs and partner competent authorities, avoiding the movement of containers at 
cost to the economic operators, as was previously the case. 

As  with  other  stakeholders,  the  nature  and  scale  of  the  time  savings  would  depend  on  the 
specificities  of  the  goods  in  question  and  Member  States  involved,  with  certain  economic 
operators experiencing much bigger improvements than others. Nonetheless, important gains 
appeared  widespread.  This  allows  for  an  estimate  for  potential  time  savings  similar  to 
customs  authorities,  at  a  range  of  30-45  minutes  per  relevant  declaration.  Applying  the 
standard cost model, this would generate annual benefits from reduced administrative costs of 
EUR  49.5m  to  EUR  74.3m.  As  noted  above,  SMEs  would  benefit  to  a  disproportionate 
extent. Some additional costs could also be expected from reduced fees for storage and other 
out-of-pocket  costs,  but  the  diversity  of  the  goods  involved  makes  it  too  hard  to  quantify 
these confidently.  

Taken together, the benefits for all stakeholders are expected to be significant, in the annual 
range  of  about  EUR  102.4m  to  EUR  156.9m,  once  full  implementation  is  achieved  from 
year 8. During years 1-7 implementation period, the envisaged benefits will be phased in, as 
the  gradual  integration  of  the  EU  electronic  systems  used  to  manage  the  regulatory 
requirements takes place.    

Table 6: Estimated benefits from option 1 
Customs 
authorities 
30-45 minutes 

Time savings / affected 
declaration 
Average labour cost / hour  

PCAs 

EOs 

Total 

2-5 minutes 

30-45 minutes 

N/A 

€24/hour 

Average no of affected 

4 128 (54% of declarations subject to relevant EU requirements)  

Page 41 / 237 

 
 
 
 
declarations (thousands) 

Annual 
benefits 
(€m) 

n
o
i
t
a
t
n
e
m
e
l
p
m

i

l
a
u
d
a
r
G

Year 1 

Year 2 

Year 3 

Year 4 

Year 5 

Year 6 

Year 7 

Year 8 onwards 

6.19-9.29  

12.39-18.58  

18.56-27.87  

24.77-37.16  

30.96-46.44  

37.16-55.73  

43.35-65.02  

49.54-74.31 

0.41-1.03 

0.83-2.06  

1.23-3.10  

1.65-4.13  

2.06-5.16  

2.48-6.19  

2.89-7.22  

3.30-8.26 

6.19-9.29  

12.39-18.58  

18.58-27.87  

24.77-37.16  

30.96-46.44  

37.16-55.73  

43.35-65.02  

49.54-74.31 

12,80-19.61  

25.60-39.22  

38.39-58.83  

51.19-78.44  

63.99-98.05  

76.79-117.66  

89.58-137.27  

102.38-156.88 

Source: Extrapolations based on declarations data from the MS participating in the project group, hourly costs based on 

Eurostat and OECD data and time estimates based on interviews in eight MS  

Cost-benefit analysis  

The  combined  analysis  for  expected  costs  and  benefits  shows  that,  in  terms  of  direct 
economic benefits alone, this option is likely to pay for itself within a short time. Net impacts 
would  be  positive  from  year  1,  ranging  from  about  EUR  95.8m  to  EUR  152m  once 
implementation  is  complete.  Importantly,  since  much  of  the  costs  would  fall  on  the 
Commission,  the net  benefits  for national  customs  and partner competent  authorities would 
be especially pronounced. The benefits for economic operators would be spread over a large 
number of individual organisations and would be achieved at little to no cost to them.  

Table 7: Cost-benefit analysis for option 1 
Year 3 

Year 1 

Year 2 

Year 4 

Year 5 

Year 6 

Year 7 

Year 8+ 

Costs (-€m, low and high ranges except for EC costs) 

EC 

MS customs 
and PCAs 

Total costs 

4.10  

2.05 
4.10  

6.15  
8.20  

4.10  

2.05 
4.10  

6.15  
8.20  

Benefits (€m, low and high ranges) 

MS customs 

MS PCAs 

EOs 

Total benefits  

6.19  
9.29  

0.41  
1.03  

6.19  
9.29  

12.80  
19.61  

12.38  
18.58  

0.83  
2.06  

12.38  
18.58  

25.60  
39.22 

Net impact (€m, low and high ranges) 

4.10  

2.05 
4.10  

6.15  
8.20  

18.58  
27.87  

1.24  
3.10  

18.58  
27.87  

38.40  
58.84  

4.10  

2.05 
4.10  

6.15  
8.20  

24.77  
37.15  

1.65  
4.13  

24.77  
37.15  

51.19  
78.43 

4.10  

2.05 
4.10  

6.15  
8.20  

30. 96  
46.44  

2.06  
5.16  

30.96  
46.44  

63.98  
98.04  

4.10  

2.05 
4.10  

6.15  
8.20  

37.15  
55.73  

2.48  
6.19  

37.15  
55.73  

4.10  

2.05 
4.10  

6.15  
8.20  

43.35  
65.02  

2.89  
7.22  

43.35  
65.02  

3.28  

1.64 
3.28 

4.92  
6.56  

49.54  
74.31  

3.30  
8.26  

49.54  
74.31  

76.78  
117.65  

89.59  
137.26  

102.38  
156.88  

Total 

4.60  
13.46  

17.40  
33.07  

30.19  
52.68  

42.99  
72.29  

55.79  
91.90  

68.59  
111.51  

81.38  
131.12  

95.82  
151.96  

Source: Analysis of cost and benefit data based on evidence collected from Commission and MS 

Social and environmental impacts 

The envisaged social and environmental impacts of this option would be felt first by customs 
and  partner  competent  authorities,  whose  ability  to  collaborate  effectively  would  be 
improved. Ultimately, EU citizens would benefit through better compliance and enforcement 
of the regulatory requirements concerned, which affect over 4m of the most sensitive goods 
movements  each  year,  thereby  having  significant  social  and  environmental  impacts  as 
described below. 

Better cooperation and coordination between authorities involved in goods clearance 

Page 42 / 237 

 
 
 
 
 
Member  States  with  national  single  window  initiatives  all  agreed  that  cooperation  and 
coordination  between  customs  and  partner  government  authorities  had  markedly  improved 
since  the  initiatives  had  been  established.  Putting  in  place  the  necessary  agreements  often 
took  time  and  a  certain  amount  of  political  will,  but  in  all  cases  quickly  led  to  important 
practical  benefits,  such  as  the  automated  sharing  of  information  and  carrying  out  of  joint 
controls.  More  informal  contact  between  authorities  has  also  reportedly  generated  further 
ideas to improve working practices and procedures, contributing to the better enforcement of 
relevant  regulatory requirements. Similar developments  were also  observed in  the countries 
taking part in EU SW-CVED pilot / EU-CSW-CERTEX and are expected in other Member 
States as likely benefits of this option. Moreover, implementation in all Member States would 
enhance  cooperation  and  coordination  even  further  by  providing  for  automated  and  highly 
reliable quantity management.  

Increased customs control capacity  

All  customs  declarations  subject  to  the  formalities  covered  by  this  option  would  be 
automatically verified. No corresponding increase in resources (or diversion from other tasks) 
would  be  needed  for  customs  authorities  to  systematically  perform  the  automated 
verification. In turn, this would enable customs authorities to expand their control capacity to 
additional goods that are currently not subject to manual verification90. 

Improved risk management  

Customs authorities in countries with national single window initiatives similar to this option 
have been able to obtain access (in a suitable format) to the data associated with supporting 
documents  from  non-customs  regulatory  requirements.  This  has  been  fed  into  risk 
management  systems,  allowing  algorithms  to  be  improved  and  contributing  to  better  and 
more efficient targeting of controls and enforcement of relevant regulatory requirements. In 
addition, the systematic automation of checks under this option will improve procedures for 
risk-based  inspection.  This  means  that  targeted  checks  would  be  limited  to  high-risk 
consignments  selected  for  manual  verification  (documentary  or  physical).  For  customs 
authorities,  this  would  significantly  improve  risk  assessment  procedures  and  their  ability  to 
focus on more substantial controls.   

Reduced instances of fraud and human error  

The  national  single  window  initiatives  similar  to  this  option  and  the  EU  SW-CVED  /  EU 
CSW-CERTEX  experiences  have  enabled  customs  authorities  and  partner  competent 
authorities  to  work  together  more  closely,  in  particular  through  carrying  out  joint  controls. 
According  to  interviewed  officials,  this  has made  fraud  easier  to  detect,  while  reducing  the 
scope  for  human  error.  As  explained  by  the  Italian  customs  authorities, automated  quantity 
management makes it much easier to prevent fraudulent traders from exploiting information 
gaps  between  authorities  in  different  Member  States  to  over-use  certificates.  Given  the  4m 
customs declarations that would be covered yearly by this option, even a small reduction in 
fraud or error rates would be very important.  

Better enforcement of and compliance with relevant regulatory requirements  

The  combined  effects  of  the  above-mentioned  impacts  would  be  better  enforcement  of  and 
compliance with non-customs EU regulatory requirements for goods involving more than 4m 
declarations per year, many of which are crucial for the protection of human health and the 
environment in the EU and beyond. These include policies aimed at: 

90   See section 2, Lack of interoperability (export and import of hazardous chemicals) 

Page 43 / 237 

 
 
                                                 
  Application  of  rules  on  animal  health  and  welfare,  plant  health  and  plant  protection 
with  regard  to  the  Common  Health  Entry  Documents  required  under  the  Official 
Controls Regulations; 

  Safeguarding  the  environment,  plant  and  animal  welfare,  through  the  FLEGT 
licensing  scheme  for  imports  of  timber  into  the  EU  to  fight  illegal  logging  and  its 
negative  environmental  impacts;  ODS  &  FGAS  licensing  system  to  ensure  that  the 
existing  restrictions  on  ozone-depleting  substances  (ODS)  and  fluorinated  gases 
(FGAS) are properly implemented; the Catch Certification Scheme for the imports of 
fishery products into the EU to fight illegal, unreported and unregulated fishing; the 
Certificate of Organic Inspection (COI) to ensure the validity of products labelled as 
organic;  the  Prior  Informed  Consent  (PIC)  Regulation  that  places  obligations  on 
companies  who  wish  to  import  or  export  hazardous  chemicals;  the  Waste  Shipment 
Regulation imposing regulations on movements of waste;  

  Protecting  cultural  heritage,  through  the  licensing  scheme  for  the  import  of  cultural 

goods; 

  Ensuring product safety and compliance, through connection with the Information and 
Communication  System  on  Market  Surveillance  (Article  34  of  Regulation  (EU) 
2019/1020). 

Obligatory  participation  in  the  initiative  is  also  expected  to  reduce  inconsistencies  between 
Member  States  and  establish  a  level  playing  field  for  economic  operators.  Several  customs 
and partner competent authorities highlighted the role this would play in furthering the single 
market, since it would reduce concerns in some countries about lax enforcement elsewhere.  

Potential risks 

This option builds on the EU CSW-CERTEX pilot which as shown in the recent evaluation 
has  proven  to  be  viable  and  viewed  favourably  by  both  Member  State  administrations  and 
economic operators. EU CSW-CERTEX is aligned with the Commission security standards 
and  is  deemed  to  be  cyber-secure.  The  risks  for  the  implementation  are  linked  to  the 
availability  of  human  and  financial  resources  and  thus  depend  on  the  outcome  of  the  next 
Multiannual  Financial  Framework  2021-2027  (MFF)91.  In  addition,  an  important  risk 
factor  arises  from  the  crosscutting  nature  of  the  option  and  the  diversity  of  non-customs 
regulatory formalities under scope, whose legislation and supporting electronic systems may 
evolve  over  time,  thereby  requiring  the  adequate  and  timely  implementation  of  updates  or 
other modifications. Similarly, the timely connections of 27 national customs systems to EU 
CSW-CERTEX  may  represent  an  additional  risk.  To  mitigate  these  risks  and  based  on  the 
experience  of  the  pilot  on  the  time  and  resources  needed  to  connect  the  systems  for  each 
formality, the development and implementation is phased over a period of seven years. 

Option  2  –  Interconnecting  national  customs  systems  to  EU  non-customs  regulatory 
formalities digitally available at Member State level 

Stakeholder views  

Member State administrations  

For the regulatory requirements included in option 2, Member State administrations foresaw 
benefits  largely  in  line  with  those  mentioned  for  option  1.  However,  perceived  practical 
difficulties and high costs to implement this option led respondents to the survey of Member 

91   COM (2018) 442 

Page 44 / 237 

 
 
                                                 
States participating in the project group to give it lower feasibility and desirability scores92. 
Similar  views  were  expressed  in  an  informal  poll  of  national  customs  authorities  taken  in 
May 2019 at the High-level seminar on the EU Single Window environment for customs in 
Bucharest.  

Economic operators  

Trade associations participating in the project group voiced positive opinions about option 2, 
which from their perspective closely resembled option 1. In order to maximise the benefits, 
trade associations felt that the future initiative should cover as many regulatory requirements 
as possible for a quicker and easier goods clearance.  

Direct economic impacts  

Implementation and recurrent costs 

For  the  European  Commission,  DG  TAXUD,  in  collaboration  with  Member  States  and 
partner  DGs  would  need  to  carry  out  the  developmental  work  needed  to  enable  the 
connections of existing national systems to EU CSW-CERTEX either directly (option 2 (i)) 
or indirectly (option 2 (ii)), while providing support to the Member States. This would require 
substantial  human  resources  and  IT  costs  to  develop  the  necessary  connections  and  to 
increase  the  capacity  of  EU  CSW-CERTEX  in  line  with  the  expected  additional  traffic. 
According  to  DG  TAXUD,  gradual  implementation  and  running  costs  for  the  years  1-7 
implementation period93 are estimated at about EUR 5m per year. From year 8 onwards, once 
the  system  is  fully  operational,  yearly  costs  would  drop  by  about  20%,  to  EUR  4m94. 
Importantly, similar costs would be expected from both option 2(i) and 2(ii). This is because 
the main cost drivers would relate to comparable technical developments changes related to 
business  rules,  transformation  tables,  quantities  reconciliation  and  process  alignments 
between customs and partner competent authorities. 

For  Member  State  customs  and  partner  competent  authorities,  the  costs  would  be 
substantial  largely  due  to  the  digital  fragmentation  of  the  regulatory  requirements  covered 
(see  section  2.2.1).  Therefore,  there  would  be  fewer  economies  of  scale  from  action  at  EU 
level. Given the decentralised availability of the information in national systems, individual 
connections  would  need  to  be  built  in  each  country  between  existing  national  electronic 
systems and EU CSW-CERTEX. It is assumed that about ten connections would be needed 
per Member State for the regulatory requirements covered. These connections are envisaged 
through direct (option 2(i)) and indirect (option 2(ii)) channels, with the following estimated 
costs: 

  Option  2(i)  covers  connections  between  partner  competent  authority  systems  and  EU 
CSW-CERTEX.  According  to  DG  TAXUD  and  Member  States  administrations,  this 
solution  would  be  complicated  and  thus  more  expensive  for  the  Member  States,  with 
estimates of EUR 300 000 per connection spread over 7 years of phased implementation, 

92   Less  than  half  (6  of  15)  considered  this  option  politically  feasible  (mainly  due  to  expected  costs  and  coordination 

challenges), while only just over half found it technically feasible and desirable (8 of 15). 

93   The estimated seven-year implementation period would provide enough time for the necessary connections to be made 
with EU CSW-CERTEX, as well as the development of national electronic systems for those regulatory requirements 
where such systems are not yet available. It also takes into account some variation between Member States in terms of 
the likely speed of progress. 

94    It should be noted that the costs to the Commission to implement this option would be higher than the costs it would 
incur  to  implement  option  1,  but  only  to  a  minor  extent.  However,  for  option  2  the  Commission’s  costs  represent  a 
much smaller proportion of total costs, since much of the effort required to implement option 2 concerns the national 
level.  

Page 45 / 237 

 
 
                                                 
 
adding up to EUR 3m per Member State and EUR 84m overall. Recurrent costs from year 
8 onwards are estimated to drop 20% to EUR 9.6m.  

  Option  2(ii)  covers  national  connections  between  partner  competent  authority  systems 
and  customs  systems,  which  would  then  be  connected  to  each  other  through  EU  CSW-
CERTEX.  As  the  cheaper  alternative,  costs  are  estimated  at  about  EUR  150  000  per 
connection  spread  over  7  years  of  phased  implementation,  adding  up  to  EUR  1.5m  per 
Member State and EUR 42m for the whole EU. Recurrent costs from year 8 onwards are 
estimated to drop 20% to EUR 4.8m. 

Table 8: Estimated implementation and recurrent costs for option 2 (in €m) 

EC  

Implementation costs (years 1-7)  Recurrent costs (year 8 onwards) 
5.0 / year (35.0 total) 

4.0 / year 

MS 
customs 
competent authorities  

and  partner 

From 6.0 year to 12.0 / year  
(42.0 to 84.0 total) 

4.80 / year to 9.60 / year 

Total  

From  11.0  /  year  to  17.0  /  year  
(77.0 to 119.0 total) 

From 8.80 / year to 13.60 / year  

Source: Estimates based on figures from DG TAXUD for European Commission costs and Member State data for MS costs   

Recurrent benefits  

Compared to the baseline, the recurrent benefits for the regulatory requirements covered by 
option  2  would  be  similar  to  those  expected  for  option  1.  However,  the  expected  benefits 
would  be  limited  since  not  all  Member  States  have  developed  national  certification  or 
licensing  systems  to  manage  all  formalities  covered  by  this  option.  This  means  that  some 
supporting  documents  will  still  be  available  on  paper,  thereby  hindering  a  full  electronic 
exchange of the relevant regulatory requirements and limiting the potential time savings that 
would  be  expected  from  full  digitalisation.  This  limitation  is  important  because  the 
persistence of any paper documents for given regulatory requirements often creates a need for 
time-consuming manual checks. This acts as a brake on the potential benefits of this option, 
which are thus estimated at about 15-20 minutes per declaration for customs authorities and 
economic operators, and 2-5 minutes per declaration for partner competent authorities. Once 
fully  operational,  this  option  would  be  expected  to  generate  substantial  benefits  from  time 
savings  of  EUR  34.5m  to  EUR  48.5m  per  year,  spread  across  the  EU  and  the  different 
stakeholders involved in goods clearance.  

Table 9: Estimated benefits from option 2 

Time savings / affected 
declaration 
Average labour cost / hour  

Average no of affected 
declarations (thousands) 
Year 1 
Annual 
benefits 
(€m) 

Year 2 

n
o
i
t
a
t
n
e
m
e
l
p
m

i

l
a
u
d
a
r
G

Year 3 

Year 4 

Year 5 

Year 6 

Year 7 

Year 8 onwards 

Customs 
authorities 
15-20 minutes 

PCAs 

EOs 

Total 

2-5 minutes 

15-20 minutes 

N/A 

2 695 (35% of declarations subject to relevant EU requirements) 

€24/hour) 

2.02-2.70 

4.04-5.39 

6.06-8.09 

8.09-10.78 

10.11-13.48 

12.13-16.17 

14.15-18.87 

16.17-21.56 

0.27-0.67 

0.54-1.35 

0.81-2.02 

1.08-2.70   

1.35-3.37 

1.62-4.04 

1.89-4.72 

2.16-5.39 

2.02-2.69 

4.04-5.39 

6.06-8.09 

8.09-10.78 

10.11-13.48 

12.13-16.17 

14.15-18.87 

16.17-21.56 

4.31-6.06 

8.62-12.13 

12.94-18.19 

17.25-24.26 

21.56-30.32 

25.87-36.38 

30.19-42.45 

34.50-48.51 

Page 46 / 237 

 
 
 
 
 
 
 
 
 
Source: Extrapolations based on declarations data from the Member States participating in the project group, hourly costs 

based on Eurostat and OECD data and time estimates based on stakeholder interviews in eight Member States  

Cost-benefit analysis  

This  option  would  generate  substantial  benefits  from  time  savings,  especially  for  customs 
authorities and economic operators. However, it would incur very high costs, especially for 
Member State administrations due to a lack of economies of scale. At best, this could deliver 
net benefits from  year 2, and yearly gains of about EUR 39.7m once fully operational. The 
less  optimistic  scenario  would  produce  net  benefits  from  year  4,  with  yearly  gains  of  EUR 
20.9m once fully operational.  

Table 10: Cost-benefit analysis for option 2 
Year 3 

Year 1 

Year 2 

Year 4 

Year 5 

Year 6 

Year 7 

Year 8+ 

Costs (-€m, low and high ranges except for EC costs) 

EC 

MS customs 
and PCAs 

Total costs 

5.00  

6.00  
12.00  

11.00  
17.00  

5.00 

6.00  
12.00  

11.00  
17.00  

Benefits (€m, low and high ranges) 

MS customs 

MS PCAs 

EOs 

Total benefits  

2.02  
2.70  

0.27  
0.67  

2.02  
2.70  

4.31  
6. 07  

4.04  
5.39  

0.54  
1.35  

4.04  
5.39  

8.62  
12.13  

Net impact (€m, low and high ranges) 

5.00  

6.00  
12.00  

11.00  
17.00  

6.06  
8.09  

0.81  
2.02  

6.06  
8.09  

12.93  
18.20  

5.00  

6.00  
12.00  

11.00  
17.00  

8.09  
10.78  

1.08  
2.70  

8.09  
10.78  

17.26  
24.26  

5.00  

6.00  
12.00  

11.00  
17.00  

10.11  
13.48  

1.35  
3.37  

10.11  
13.48  

21.56  
30.33  

5.00  

6.00  
12.00  

11.00  
17.00  

12.13  
16.17  

1.62  
4.04  

12.13  
16.17  

25.88  
36.38  

5.00  

6.00  
12.00  

11.00  
17.00  

14.15  
18.87  

1.89  
4.72  

14.15  
18.87  

30.19  
42.46  

4.00  

4.80  
9.60  

8.80  
13.60  

16.17  
21.56  

2.16  
5.39  

16.17  
21.56  

34.50  
48.51  

Total 

-12.69  
-4.94  

-8.38  
1.13  

-4.06  
7.19  

0.25  
13.26  

4.56  
19.32  

8.87  
25.38  

13.18  
31.45  

20.90  
39.71  

Source: Analysis of cost and benefit data based on evidence collected from European Commission and Member States 

Social and environmental impacts 

Compared to the baseline, the envisaged social and environmental impacts of option 2 would 
be  important  and  of  a  similar  nature  as  those  described  for  option  1.  However,  while 
improving  coordination  between  customs  and  partner  competent  authorities,  this  option 
would  not  factor  in  supporting  documents  issued  in  Member  States  without  a  national 
certification  or  licensing  system.  In  these  cases,  functionalities  such  as  automated  quantity 
management at EU level would not be possible, thus bringing fewer benefits in terms of risk 
management  improvement  and  reduced  fraud  and  error.  On  the  other  hand,  this  option 
provides  the  unique  possibility  to  generate  important  benefits  in  fields  where  no  EU 
electronic  system  exists.  While  its  scope  is  limited  to  about  2.7  million  declarations,  these 
relate to regulatory requirements that are typically highly sensitive and crucial for the well-
being  of  EU  citizens.  The  benefits  of  this  option  would  thus  entail  improvements  to 
regulations  related  to  the  control  of  agricultural  imports  and  exports  (i.e.  AGRIM  and 
AGREX  licences);  the  system  to  control  trade  of  dual  use  items  to  ensure  that  the  EU 
complies  with  its  international  commitments  and  responsibilities,  especially  regarding  non-
proliferation  (i.e.  preventing  the  spread  of  nuclear  weapons);  the  requirements  on  import, 
export and transit of  firearms, their parts and ammunition to  fight  illicit manufacturing  and 
trafficking in firearms; controls on imports, exports and transits of chemical substances used 
for  the  manufacture  of  illicit  synthetic  drugs  to  address  the  increasing  threat  posed  by  the 

Page 47 / 237 

 
 
 
manufacture  of  synthetic  drugs  in  western  Europe  by  preventing  the  diversion  of  these 
substances;  CITES  licences  to  protect  endangered  plants  and  animals;  and  measures  to 
prevent the introduction and spread of invasive alien species and their negative consequences 
for the environment.   

Potential risks 

While  this  option  carries  risks  similar  to  those  described  under  option  1,  it  also  entails 
additional serious risks to successful implementation. In particular, the many connections that 
would  be  needed  in  order  to  incorporate  each  regulatory  formality  into  the  system  increase 
the  likelihood  of  bottlenecks,  especially  at  Member  State  level  where  the  Commission  has 
little direct  involvement. These  could  delay or preclude full implementation. Moreover, the 
lack of enthusiasm for this option among Member State administrations, combined with the 
significant  costs  that  they  would  incur,  create  a  risk  that  participation  would  be  limited  or 
delayed,  especially  if  resources  are  constrained  by  other  developments  at  national  or 
international level.  

Option  6  –  Harmonised  national  single-entry  points  for  economic  operators  to  fulfil 
customs and non-customs regulatory requirements 

Stakeholder views  

Member State administrations  

Member  State  administrations  have  expressed  positive  views  about  this  option.  Among  the 
B2G options, it was  ranked highest  for overall desirability according to  a survey of project 
group  members.  It  was  also  the  only  B2G  option  receiving  mostly  favourable  scores  for 
political and technical feasibility.  

The informal poll of (mostly) Member State customs authorities at the High-level seminar on 
an EU customs single window, conducted in Bucharest in May 2019, showed high levels of 
satisfaction,  mainly  attributed  to  the  envisaged  benefits  of  the  initiative95.  Despite  the 
generally  positive  views,  some  Member  States  voiced  concerns  about  the  feasibility  and 
desirability  of  this  option.  Within  the  project  group,  several  Member  States  felt  that  the 
technical solutions would be costly and difficult to prioritise over the coming years due to the 
focus on other IT projects such as those required as part of the UCC Work Programme. A few 
Member States also worried about organisational problems related to the envisaged role for 
national customs authorities. It was explained that, while this option would rely on customs 
authorities coordinating between various partner competent authorities and acting as a hub for 
receiving information from economic operators, in some Member States customs would not 
be empowered to play this role. This would make the option difficult for these Member States 
to implement.  

Economic operators  

Three of the four trade  associations completing  the survey in  the project  group viewed this 
option as the most or second-most desirable of the B2G options. More specifically, option 6 
was considered a compromise solution that would simplify clearance procedures and address 
key  problems  that  would  not  be  resolved  by  G2G  collaboration  only,  such  as  the  need  to 
submit similar information to multiple authorities for the same movements. Given that some 
Member  States  have  already  started  making  progress  on  national  single  windows,  option  6 

95   See Annex 2 (High Level Seminar on the EU SW environment for customs initiative) for further details on the results of 

the informal poll.  

Page 48 / 237 

 
 
                                                 
was  also  seen  as  an  effective  way  to  harness  existing  momentum  and  avoid  duplicating 
efforts. 

Some  economic  operators  were  critical  of  this  option  because  it  would  still  require  dealing 
with different single-entry points in each Member State. This residual complexity was seen to 
limit the benefits for traders in comparison with more integrated solutions (such as option 7).  

Direct economic impacts  

Implementation and recurrent costs 

Compared to the baseline, the implementation and recurrent costs for option 6 are limited to a 
certain  extent  because  only  the  B2G  elements  of  a  future  initiative  are  considered.  Any 
necessary G2G elements would be implemented as part of the G2G option package.  

The European Commission would incur implementation costs related to its role in steering 
and  coordination.  These  would  entail  mapping  the  data  needs  for  the  EU  regulatory 
requirements  covered,  the  development  of  technical  specifications  and  harmonised  data 
models  to  be  used  by  customs  and  partner  competent  authorities  for  the  national  customs 
single windows. For most of the regulatory requirements, the Commission would also incur 
costs  associated  with  relaying  data  between  national  single  windows  and  EU  partner 
competent  authority  systems  through  EU  CSW-CERTEX.  There  would  also  be  a  need  to 
provide training and support to Member State administrations. DG TAXUD estimates these 
costs at about EUR 35m, spread over years 1-796, amounting to EUR 5m per year. Recurrent 
costs would be about EUR 3m per year.  

The  implementation  costs  for  this  option  would  be  borne  by  Member  State  customs  and 
partner competent authorities. Member State administrations would need to adapt their IT 
systems and business processes so that the data for customs and non-customs purposes can be 
lodged at a single-entry point and reused as appropriate. The business use cases97, based on 
data from Spain and the Czechia, indicate that about EUR 1.75m would be needed to develop 
and  implement  option  6  in  these  Member  States.  Interviews  with  other  Member  State 
administrations showed that complex IT environments and procurement processes would lead 
to  much higher costs. Since most Member State administrations did  not provide data, these 
are cautiously estimated at around EUR 3.5m based on consultation with IT experts98. Given 
the uncertainty, these are taken as low and high ranges for costs that, extrapolated to  cover 
the whole EU, would amount to EUR 49m to EUR 98m for implementation. This would be 
spread over 7  years of phased implementation,  meaning  costs of EUR 7m  to  EUR 14m  per 
year.  Recurrent  costs  would  also  be  substantial  due  to  the  continued  need  for  coordination, 
maintenance, and support, but would be much lower than the costs for initial implementation, 
estimated at EUR 4.2m to EUR 8.4m yearly.  

Table 11: Estimated implementation and recurrent costs for option 6 (in €m) 

EC  

Implementation costs (years 1-7) 
5.0 / year (35.0 total) 

Recurrent costs (year 8 onwards) 
3.0 / year 

MS  customs  and  partner  From 7.0 year to 14.0 / year  

4.20 / year to 8.40 / year 

96  

In addition to the development of EU components, the implementation period allows most importantly for the Member 
States to put in place the necessary changes at national level. While some Member States could be expected to do this 
fairly  quickly,  given  different  starting  points  a  phase-in  of  seven  years  was  deemed  necessary  to  ensure  full 
participation.  

97   B2G use cases carried out for CHED-A and FLEGT regulatory requirements by Czech and Spanish customs authorities, 

with the coordination of DG TAXUD and collaboration of partner DGs. See Annexes 1, 2 and 4 for more information. 

98   Consultation  with  IT  experts  supporting  the  ICT  assessment  building  on  the  policy  work  carried  out  by  EU  Single 

Window project group). See Annex 15. 

Page 49 / 237 

 
 
 
                                                 
competent authorities  

(49.0 to 98.0 total) 

Total  

From 12.0 / year to 19.0 / year  

From 7.20 / year to 11.40 / year  

(84.0 to 133.0 total) 

Source: Estimates based on figures from DG TAXUD for European Commission costs and consultation with IT experts for 

Member State costs   

Recurrent benefits  

Option 6 is estimated to affect about 4.9m customs declarations per year, comprising 64% of 
declarations  subject  to  relevant  EU  regulatory  requirements.  It  is  expected  to  simplify 
clearance  processes  for  customs  and  partner  competent  authorities,  while  revolutionising 
them for economic operators.  

For  customs  and  partner  competent  authorities,  the  business  use  cases  report  that 
efficiency savings would be realised from earlier access to information (in particular in case 
of the use of pre-lodged declarations), improved coordination, and quicker verification of the 
documents  and  data  submitted  by  economic  operators.  However,  since  this  option  will  not 
affect the way authorities verify and record information, these improvements are considered 
incremental  rather  than  fundamental.  The  B2G  use  cases,  combined  with  interviews  on 
expected  improvements,  indicated  likely  time  savings  per  relevant  customs  declaration, 
estimated  at  5-10  minutes  for  customs  authorities,  and  1-2  minutes  for  partner  competent 
authorities. Given the number of customs declarations affected, this would generate benefits 
of nearly EUR 9.8m to EUR 19.6m per year for customs authorities and EUR 3.9m to EUR 
9.8m per year for partner competent authorities, once full implementation is realised.  

Much  bigger  time  savings  are  expected  for  economic  operators,  for  whom  the  business 
processes  for  lodging  customs  and  non-customs  data  would  be  significantly  improved. 
Instead  of  needing  to  submit  documents  to  different  authorities  at  different  times,  and  in 
different  formats,  this  option  would  rationalise  the  process,  allowing  customs  and  non-
customs data to  be submitted and dealt with  together. This  is  consistent with  findings from 
the US single window99 provided by US Customs and Border Protection (CBP)100.  

It is difficult to translate these general findings and examples into quantified estimates of the 
likely  savings,  especially  given  the  diversity  of  regulatory  requirements  involved  and 
different starting points across Member States. For this reason, a conservative range of 45-60 
minutes per relevant declaration is used, taking into account both declarations where savings 
may run into hours or even days, and others where existing processes save only minutes. In 
total, this would generate yearly benefits from EUR 88.2m to EUR 117.6m, spread across the 
many  businesses  involved  in  international  trade,  once  full  implementation  is  achieved.  The 
overall benefits from time savings from this option are expected to be very significant, in the 
annual  range  of  about  EUR 102.0m  to  EUR  147.0m,  once  full  implementation  is  achieved 
from year 8 onwards.  

Table 12: Estimated benefits from option 6 
Customs 
authorities 

PCAs 

EOs 

Total 

Time savings / affected declaration 

5-10 minutes 

2-5 minutes 

45-60 minutes 

N/A 

99   The  Automated  Commercial  Environment  (ACE)  is  the  primary  single  window  system  used  by  U.S.  CBP  for  trade 
information  processing  and  risk  management  activities.  ACE  is  continually  adapted  to  meet  changing  needs  with 
automated procedures that speed legitimate trade and improve CBP’s ability to assess risk.  

100   According  to  CBP’s  assessment  of  the  single  window  since  its  implementation  in  2018,  the  benefits  for  economic 
operators have included the reduction of data redundancies, easier monitoring of the status of requests and automated 
validation of documents related to a number of regulatory requirements. 

Page 50 / 237 

 
 
 
 
 
                                                 
Average labour cost / hour  

€24/hour 

Average 
declarations (thousands) 

no 

of 

affected 

4 899 (64% of declarations subject to relevant EU requirements) 

Annual 
benefits 
(€m) 

Year 1 

Year 2 

Year 3 

Year 4 

Year 5 

Year 6 

Year 7 

n
o
i
t
a
t
n
e
m
e
l
p
m

i

l
a
u
d
a
r
G

1.23-2.45 

2.45-4.90 

3.67-7.35 

4.90-9.80 

6.12-12.25 

7.35-14.70 

8.57-17.15 

0.49-1.23 

0.98-2.45 

1.47-3.67 

1.96-4.90 

2.45-6.12 

2.94-7.35 

3.43-8.57 

11.02-14.70 

12.74-18.37 

22.05-29.40 

25.48-36.75 

33.07-44.09 

38.21-55.12 

44.09-58.79 

50.95-73.49 

55.12-73.49 

63.69-91.86 

66.14-88.19 

76.43-110.23 

77.16-102.89 

89.17-128.61 

Year 8 onwards 

9.80-19.60 

3.92-9.80 

88.19-117.59 

101.91-146.98 

Source: Extrapolations based on declarations data from the Member States participating in the project group, hourly costs 

based on Eurostat and OECD data and time estimates based on stakeholder interviews in eight Member States.  

Cost-benefits analysis  

While  costly,  option  6  is  expected  to  generate  extremely  large  benefits  for  economic 
operators.  Taking  into  account  incremental  benefits  for  customs  and  partner  competent 
authorities, it is  envisaged that net  benefits  would be positive in  year 1 or  year 2, then rise 
considerably. Once fully operational, net benefits ranging from EUR 90.5m to EUR 139.8m 
would be expected.  

Table 13: Cost-benefit analysis for option 6 

Year 1 

Year 2 

Year 3 

Year 4 

Year 5 

Year 6 

Year 7 

Year 8+ 

Costs (-€m, low and high ranges except for EC costs) 

EC 

MS 
customs 
and PCAs 

Total costs 

5.00  

7.00  
14.00  

12.00  
19.00  

5.00  

7.00  
14.00  

12.00  
19.00  

Benefits (€m, low and high ranges) 

MS 
customs 

MS PCAs 

EOs 

Total 
benefits  

1.22  
2.45  

0.49  
1.22  

11.02  
14.70  

12.73  
18.37  

2.45  
4.90  

0.98  
2.45  

22.05  
29.40 

25.48  
36.75  

Net impact (€m, low and high ranges) 

Total 

-6.26  
6.37  

6.48  
24.74  

5.00  

7.00  
14.00  

12.00  
19.00  

3.67  
7.35  

1.47  
3.67  

33.07  
44.09  

38.21  
55.11  

19.21  
43.12  

5.00  

7.00  
14.00  

12.00  
19.00  

4.90  
9.80  

1.96  
4.90  

44.09  
58.79  

50.95  
73.49  

31.95  
61.49  

5.00  

7.00  
14.00  

12.00  
19.00  

6.12  
12.25  

2.45  
6.12  

55.18 
73.49  

63.75  
91.86  

44.69  
79.86  

5.00  

7.00  
14.00  

12.00  
19.00  

7.35  
14.70  

2.94  
7.35  

66.14  
88.19  

76.43  
110.24  

5.00  

7.00  
14.00  

12.00  
19.00  

8.57  
17.15  

3.43  
8.57  

77.16  
102.89 

89.16 
128.61  

3.00  

4.20  
8.40  

7.20  
11.40  

9.80  
19.60  

3.92  
9.80  

88.19  
117.58  

101.91  
146.98  

57.43  
98.23  

70.17  
116.61  

90.51  
139.78  

Source: Analysis of cost and benefit data based on evidence collected from European Commission and Member States 

Social and environmental impacts 

Expectations  from  stakeholders,  the  business  use  cases  and  experiences  of  the  US  single 
window indicate that major improvements could be expected in all of the envisaged impact 
areas. 

Page 51 / 237 

 
 
 
 
 
Better cooperation and coordination between authorities involved in goods clearance 

This  option  calls  for  customs  to  act  as  a  hub  for  receiving  information  from  economic 
operators  related  to  a  range  of  non-customs  regulatory  requirements.  Since  customs 
authorities  would  be  responsible  for  developing  and  forging  agreement  with  partner 
competent authorities on business processes for the exchange of relevant data, this would lead 
to  increased  coordination  between  them.  More  practically,  once  implemented,  this  option 
would  harmonise  data  models  between  customs  and  partner  competent  authority  systems, 
allowing them to  share information  more easily.  This  was described as a  key benefit in  the 
CHED-A business use case, as well as of the US single window.  

Improved risk management  

Risk management relies on the timely provision of relevant data. By increasing the amount of 
electronic data obtained from economic operators as part of the pre-lodged declaration, and 
making  it  easier  to  share  among  authorities,  this  option  could  improve  risk  management 
substantially.  With  few  exceptions,  stakeholders  in  most  Member  States  agreed  with  this 
view, and saw it as  an  advantage for this  option. The business  use  cases  showed that these 
expected improvements would be likely to materialise. In the CHED-A case, it was noted that 
data  harmonisation  would  allow  customs  authorities  to  develop  more  detailed  profiles  of 
economic  operators  for  the  purposes  of  risk  analysis.  Improved  risk  management  has  also 
been cited as a key outcome of the US single window.  

Reduced instances of fraud and human error  

The  B2G  case  studies  considered  better  targeted  and  reduced  controls  as  key  benefits  of 
improved  information  sharing  and  increased  digitalisation  between  customs  and  partner 
competent authorities. In this regard, the CHED-A use case emphasised that submitting key 
data and documentation only once would greatly reduce the scope for errors and fraud.   

Better enforcement of and compliance with relevant regulatory requirements  

The  impacts  described  above  would  combine  to  improve  enforcement  of  the  non-customs 
regulatory  requirements  included  in  this  option.  As  with  the  G2G  options,  enhanced  B2G 
collaboration would improve the implementation of a number of highly sensitive regulatory 
requirements,  leading  to  benefits  across  a  number  of  policy  domains.  These  include  the 
application  of  rules  on  animal  health  and  welfare,  plant  health  and  plant  protection  with 
regard  to  the  CHED  documents  required  under  the  Official  Controls  Regulations;  food  and 
vegetable  standards  as  specified  in  the  Certificate  of  Conformity;  and  safeguarding  the 
environment,  plant  and  animal  welfare  through  the  FLEGT  licensing  scheme,  ODS  and 
FGAS licensing system; cultural heritage through the licensing systems for cultural imports 
and exports. In turn, these improvements would help level the playing field between Member 
States  and,  by  increasing  incentives  for  authorities  across  borders  to  trust  each  other, 
furthering the single market and objectives of the Customs Union.  

Potential risks  

Apart  from  the  financial  risks,  which  are  common  to  options  1  and  2,  this  option  carries 
certain  operational  risks  due  its  technical  complexity  and  large  costs.  These  relate  in 
particular  to  Member  State  administrations,  which  would  need  to  adapt  and  implement 
national  single-entry  points.  Especially  if  resources  are  constrained,  some  Member  States 
may need time to implement their solution. However, the option is designed to mitigate these 
risks to the extent possible. Firstly, phased implementation will allow the Member States to 
make progress  at  their own pace. Member States that move quickly will  be start  benefiting 
earlier,  while  others  wait  until  resources  are  available.  Secondly,  the  development  of 

Page 52 / 237 

 
 
harmonised technical specifications would generate economies of scale, making the creation 
of  a  national  single-entry  point  less  costly  than  would  otherwise  have  been  the  case.  This 
attracted enthusiasm from Member State administrations, speaking to this option’s viability.   

Option 7– EU single-entry point for economic operators to fulfil customs and non-customs 
formalities 

Stakeholder views  

Member State administrations  

In  a  survey  of  Member  States  taking  part  in  the  project  group,  customs  administrations 
expressed  some  interest  in  this  option.  Six  of  15  Member  States  considered  it  their  most-
favoured option for B2G collaboration, while four Member States ranked it second. However, 
very few respondents found this option to be feasible, with only 5 Member States describing 
it as politically feasible, and just three Member States describing it as technically feasible.  

Follow-up discussions showed these concerns to be fundamental. Nearly all administrations 
agreed  that,  while  option  7  could  be  held  up  as  a  goal  for  the  long  term,  in  the  short-to-
medium  term  it  would  be  unrealistic.  Two  main  reasons  were  given  for  this.  First, 
implementation  of  this  option  at  national  level  would  require  significantly  more  resources 
than  are  currently  available.  This  is  due  in  large  part  to  the  IT  investments  required  to 
implement  the UCC. As shown in  the latest E-Customs Annual  Report, the Member States 
are  currently investing about  EUR 140m  annually  on the UCC systems,  leaving  little room 
for  additional  major  IT  projects.  Second,  this  option  would  require  replacing  existing  IT 
systems for import, export and transit with a centralised EU system. Beyond the expense of 
making  such  a  transition,  this  would  interfere  with  horizontal  IT  integration  at  the  national 
level.  More  specifically,  implementation  of  this  option  would  remove  the  connections  that 
have  been  built  up  over  time  between  customs  authorities  and  other  national  and  local 
authorities  in  areas  such  as  tax,  excise  and  law  enforcement.  There  were  concerns  that 
restoring these connections would not be possible, due both to technical challenges and other 
issues such as data protection concerns.  

Economic operators  

While  trade  representatives  taking  part  in  the  project  group  acknowledged  the  challenges 
inherent in this option, it was their clear favourite among the options for B2G cooperation. In 
part, this was because trade associations felt it would achieve benefits for economic operators 
similar to those that could be expected from option 6, especially the establishment of a single-
entry  point  for  customs  declarations  and  documents  required  for  certain  non-customs 
regulatory requirements.  

Follow-up  discussions  and  responses  to  the  public  consultation  showed  that  economic 
operators  also  preferred  this  option  for  its  ability  to  streamline  and  harmonise  customs 
processes  throughout  the  EU,  regardless  of  whether  goods  were  subject  to  non-customs 
regulatory requirements. For example, several trade associations pointed to option 7 as a way 
to  improve  problems  with  the  obligations  related  to  the  UCC,  such  as  arrival  notifications, 
presentation  notices  and  temporary  storage  declarations.  They  were  also  interested  in  the 
possibility  to  lodge  customs  declarations  at  a  single  EU  point  regardless  of  the  destination, 
providing an overall centralised clearance mechanism for both import and export operations. 
Given that the costs for economic operators associated with this option would be minor, these 
additional benefits led to it being the most positively viewed.  

Page 53 / 237 

 
 
Direct economic impacts  

Implementation and recurrent costs  

Option 7 consists of an EU-level single-entry point for B2G cooperation. This would require 
a higher degree of centralisation for core customs functions than is currently the case. More 
specifically,  a  new  centralised  system  would  replace  existing  national  systems  for  import, 
export  and  transit.  This  new  system  would  cover  all  B2G  functions  related  to  the  initiative 
(namely the interface for receiving information from economic operators related to customs 
and relevant non-customs regulatory requirements). In principle, it would also need to cover 
functions  outside  the  scope  of  the  initiative  but  currently  fulfilled  by  national  customs 
systems.  These  include  handling  the  lodging  and  processing  of  customs  declarations, 
recording  decisions,  accounting  for  customs  duties,  and  interacting  with  various  other 
systems  at  EU,  national  and  in  some  cases  at  local  levels  (e.g.  tax  authorities,  regional 
authorities, port  community systems).  In other  words, this option would place a centralised 
system  at  a  critical  point  in  the  process  for  all  EU  trade  in  goods.  This  would require very 
high levels of reliability, security and speed for the sharing of information between different 
actors at EU and national levels. 

The new centralised system would thus cover a broader range of functions and require more 
interconnections  with  national  systems  than  any  existing  European  customs  IT  system  and 
thus entail significant complexity and technical challenges. This would lead to very important 
costs  for  the  Commission  and  Member  States.  All  economic  operators  that  engage  in 
international  trade  (rather  than  just  those  involved  in  the  trade  of  goods  subject  to  relevant 
regulatory requirements) would also incur some minor costs in order to begin using the new 
system. To interpret  the  estimates, it is  worth  noting the  reporting  costs of a similar Single 
Window solution  recently implemented in  the United States. According to  the US Customs 
and  Border  Protection,  this  cost  about  EUR  10 000m  over  ten  years  of  development.  Since 
the  EU  handles  more  trade,  and  since  option  7  would  deal  with  the  complexities  of 
integrating  systems  in  the  vastly  differing  IT  environments  of  the  EU  Member  States, 
considerably higher costs could be expected a priori.  

The European Commission would be responsible for developing the system and thus would 
be expected to bear high initial costs. The most comparable centralised system is the Import 
Control System 2 (ICS2), which is currently in development. According to DG TAXUD, the 
Commission’s  development  costs  for  ICS2  are  about  EUR  400m.  However,  the  centralised 
system needed for option 7 would be much more complex than ICS2 in terms of data to be 
handled,  interconnections  with  other  systems  and,  given  important  differences  between  the 
administrative  and  IT  arrangements  across  Member  States,  a  high  degree  of  flexibility. 
Moreover, a central common repository for all declaration data would be needed to ensure the 
data is available to customs and partner competent authorities across the EU to a sufficiently 
high  level  of  reliability.  Given  this,  DG  TAXUD  officials  involved  in  the  ICS2  project 
estimated  that  the  centralised  system  needed  for  option  7  would  be  similar  to  develop  ten 
projects  of  a  similar  level  of  complexity  to  ICS2,  leading  to  an  estimated  cost  of  about 
EUR 4000m over a period of seven years.  

From  year  8  onward,  the  Commission  would  work  with  the  Member  States  to  make  the 
necessary connections and begin rolling out the system. As with other major IT projects such 
as those mandated under the UCC, gradual implementation is expected over a period of about 
five  years,  with  full  operation  in  all  Member  States  from  year  13  onwards.  Yearly  costs 
would  drop  at  once  the  main  development  work  is  finished  but,  as  with  other  major  IT 
projects, only by about 20% per year, to EUR 457.1m. This is due to the extensive effort that 

Page 54 / 237 

 
 
would be needed to maintain and update the system, provide support and coordinate with the 
Member States on an ongoing basis.  

While the Commission would bear overall responsibility for the development of the system, 
the  Member  States  would  also  be  heavily  involved  and  incur  significant  costs.  During  the 
seven  years  while  the  system  is  under  development,  the  Member  States  would  need  to 
conduct  extensive  preparatory  work  in  order  to  lay  the  ground  for  the  upcoming  changes. 
This would entail participation in numerous working groups both with the Commission and 
between  the  many  authorities  who  would  be  affected,  analyses,  adaptations  to  related 
systems, conformance testing, piloting, training, consultation and information campaigns.  

Once the system has been developed, further substantial effort would be needed to implement 
it at national level. This would again involve unprecedented levels of complexity, because the 
system would replace legacy systems for import, transit and export that have been place for a 
long  time  and  gradually  improved  in  line  with  customs  and  wider  administrative  needs. 
Putting in place a totally new system would demand extensive efforts not only from customs 
authorities,  but  also  from  partner  competent  authorities  that  need  to  interact  with  customs, 
including  both  partner  competent  authorities  directly  involved  in  the  Single  Window 
initiative and others, such as tax authorities, the police, security services etc. Once the system 
is in place, recurrent costs would relate to continuous coordination between relevant actors at 
national and European levels, the adaptation and implementation of updates and support.  

Estimating  the  Member  State  costs  is  difficult,  in  part  because  there  are  no  examples  of  a 
centralised system replacing such an integral part of the national IT infrastructure, and in part 
due  to  the  high  levels  of  diversity  between  Member  States.  To  arrive  at  realistic  estimates 
despite this difficulty, data in the E-customs annual reports101 is used. The reports provide a 
breakdown  of  costs  for  the  Commission  and  Member  States  related  to  the  development, 
implementation  and  running  of  IT  projects  included  in  the  Multi-Annual  Strategic  Plan  for 
Customs  (MASP-C)102,  covering  a  wide  range  of  centralised  and  distributed  systems.  The 
reports show that about 40% of relevant IT spending is typically incurred by the Commission, 
while the remaining 60% is incurred by the Member States as a whole. This ratio has held for 
recent years despite the diversity of projects and their state of development. It is thus assumed 
that it would also hold broadly for the centralised system needed for option 7. However, there 
is  also  considerable  uncertainty  due  to  the  lack  of  comparable  IT  projects  and  different 
situations across Member States. For this reason, ranges are provided, with a low estimate of 
the Member States incurring 50% of total  public costs, and a high estimate of the Member 
States  incurring  70%  of  total  public  costs.  In  figures,  the  estimates  thus  range  from  EUR 
4 000m  to  EUR  9 333m  during  the  seven  years  of  development,  with  a  drop  of  20% 
thereafter, leading to yearly costs of EUR 457.1m to EUR 1 066.7m.  

Finally, some costs would also be borne by economic operators, who would need to adapt 
their IT systems and processes, and provide training to staff, in order to engage with the new 
system.  Indications  from  economic  operators  are  that  such  costs  would  be  relatively  minor 
and limited to small IT investments and training of staff on a per company basis. However, 
the  number  of  companies  affected  is  large,  because  the  new  system  would  be  used  by  all 
economic operators  engaging in  international  trade, not  only those  engaging in  the trade of 
goods  covered  by  the  Single  Window.  It  is  thus  assumed  that  all  economic  operators 
engaging in international trade would incur a one-off cost of about EUR 500 to EUR 1 000, 
spread over the five years of implementation. According to Eurostat, about 1.4m companies 

101 https://ec.europa.eu/taxation_customs/general-information-customs/electronic-customs_en#heading_3 
102 https://ec.europa.eu/taxation_customs/general-information-customs/electronic-customs_en#heading_2 

Page 55 / 237 

 
 
                                                 
engaged  in  international  trade  in  2017.  This  would  amount  to  EUR  700m  to  EUR 1 400m 
over the five years during which the system is rolled out.  

Table 14: Estimated implementation and recurrent costs for option 7 (in EUR millions) 

Costs  during  years  of 
development 1-7 

Costs  during  years  of 
implementation 8-12 

Recurrent  costs  from 
year 13 onwards 

EC  

571.4 / year (4 000.0 total) 

457.1 / year (2 285.7 total) 

457.1 / year  

customs 

and 
competent 

MS 
partner 
authorities  

From  571.4  to  1 333.3  /  year 
(4 000.0 to 9 333.3 total) 

From  457.1  to  1 066.7  /  year 
(2 285.7 to 5 333.3 total) 

From  457.1  to  1 066.7  / 
year  

EOs 

Total  

No costs  

From  140.0  to  280.0  /  year 
(700.0 to 1 400.0 total) 

No costs 

From 1 142.9 to 1 904.8 / year 
(8 000.0 to 13 333.3 total) 

From 1 054.3 to 1 803.8 / year 
(5 271.4 to 9 019.0 total) 

From  914.3  to  1 523.8  / 
year 

Source: Estimates based on figures from DG TAXUD, E-Customs Annual Implementation Reports and consultation with IT 

experts.  

Recurrent benefits  

This  option  would  affect  the  same  4.9  m  customs  declarations  and  lead  to  the  comparable 
process improvements as with option 6. The dynamics as described under option 6 can thus 
be considered to also apply to option 7 and are not repeated here. The benefits would thus be 
especially significant  for economic operators, with more moderate benefits for customs and 
partner competent authorities as follows:  

  For customs authorities, from about EUR 9.8m to EUR 19. 6m per year;  
  For partner competent authorities, about EUR 3.9m to EUR 9.8m per year; 
  For economic operators, about EUR 88.2m to EUR 117.6m per year.  

Taken together, the benefits for all stakeholders are expected to be significant, in the annual 
range of about EUR 102.0m to EUR 147.0m, once full implementation is achieved from year 
13.  During  the  implementation  period  from  years  8-12,  the  envisaged  benefits  would  be 
phased in as Member States gradually begin operating the new system.  

It  is  also  important  to  note  that  this  option  would  have  benefits  for  economic  operators 
beyond the scope of the initiative that are not examined here in detail. More specifically, it 
would  lead  to  a  streamlining  of  the  Customs  Union,  allowing  economic  operators  to  lodge 
customs declarations at the single EU point regardless of destination (i.e. overall centralised 
clearance mechanism), and putting in  place the same interface for economic operators. The 
diversity  of  customs  declarations  and  procedures  required  for  different  goods  makes  it 
difficult to estimate the scale of these benefits accurately, but they would likely range from 
seconds up to several minutes for each customs declaration.  

Table 15: Estimated benefits from option 7 
Customs 
authorities 

PCAs 

EOs 

Total 

Time savings / affected declaration 

5-10 minutes 

2-5 minutes 

45-60 minutes 

N/A 

Average labour cost / hour (€m) 

€24/hour 

Average 
declarations (thousands) 

no 

of 

affected 

4 899 (64% of declarations subject to relevant EU requirements) 

Annual 
benefits 

Years 1-7 

No benefits while system under development 

a
r
G

l
a
u
d

l
p
m

Year 8 
i
e
t
a
m
t
n
e

i

n
o

1.6-3.3 

0.7-1.6 

14.7-19.6 

17.0-24.5 

Page 56 / 237 

 
 
 
 
 
 
 
(€m) 

Year 9 

Year 10 

Year 11 

Year 12 

Year 13 onwards 

3.3-6.5 

4.9-9.8 

6.5-13.1 

8.2-16.3 

9.8-19.6 

1.3-3.3 

2.0-4.9 

2.6-6.5 

3.3-8.2 

3.9-9.8 

29.4-39.2 

44.1-58.8 

58.8-78.4 

73.5-98.0 

34.0-49.0 

51.0-73.5 

67.9-98.0 

84.9-122.5 

88.2-117.6 

101.9-147.0 

Source: Extrapolations based on declarations data from the MS participating in the project group, hourly costs based on 

Eurostat and OECD data and time estimates based on interviews in eight MS  

Cost-benefit analysis  

Despite the large expected benefits, the extremely high costs for this option make it unlikely 
to  be  cost-effective,  at  least  in  terms  of  direct  economic  impacts  alone.  No  benefits  at  all 
would be realised during an initial seven years of development. After this, the benefits would 
gradually  come  online.  But  even  once  fully  operational,  the  yearly  running  costs  would  far 
exceed  the  benefits,  leading  to  large  negative  net  yearly  impacts  ranging  from  EUR  -
1 421.9m to EUR -767.3m. In other words, this option would cost several times more than the 
expected benefits, even excluding development costs and looking at the best-case scenario.  

Table 16: Cost-benefit analysis for option 7 

Years 1-7  Year 8 

Year 9 

Year 10 

Year 11 

Year 12 

Year 13+ 

Costs (-€m, low and high ranges except for EC costs) 

EC 

MS customs and 
PCAs 

EOs 

Total costs 

4 000.0  

4 000.0  
9 333.3  
-  
-   

8 000.0  
13 333.3  

Benefits (€m, low and high ranges) 

MS customs 

MS PCAs 

EOs 

Total benefits  

None 

457.1  

457.1  
1 066.7  
140.0  
280.0  

1 054.3  
1 803.8  

1.6  
3.3  

0.7  
1.6  

14.7  
19.6  

17.0  
24.5  

Net impact (€m, low and high ranges) 

457.1  

457.1  
1 066.7  
140.0  
280.0  

1 054.3  
1 803.8  

3.3  
6.5  

1.3  
3.3  

29.4  
39.2  

34.0  
49.0  

457.1  

457.1  
1 066.7  
140.0  
280.0  

1 054.3  
1 803.8  

4.9  
9.8  

2.0  
4.9  

44.1  
58.8  

51.0  
73.5  

457.1  

457.1  
1 066.7  
140.0  
280.0  

1 054.3  
1 803.8  

6.5  
13.1  

2.6  
6.5  

58.8  
78.4  

67.9  
98.0  

457.1  

457.1  
1 066.7  
140.0  
280.0  

1 054.3  
1 803.8  

8.2  
16.3  

3.3  
8.2  

73.5  
98.0  

84.9  
122.5  

457.1  

457.1  
1 066.7  
- 
-  

914.3  
1 523.8  

9.8  
19.6  

3.9  
9.8  

88.2  
117.6  

101.9  
147.0  

Total 

-13 333.0  
-8 000.0  

-1 786.8  
-1 029.8  

-1 769.8  
-1 005.3  

-1 752.9  
-980.8  

-1 735.9  
-956.3  

-1 718.9  
-931.8  

-1 421.9  
-767.3  

Source: Analysis of cost and benefit data based on evidence collected from Commission and MS 

Social and environmental impacts  

This option would put in place a single-entry point for goods subject to certain EU regulatory 
requirements (i.e. affecting the same declarations as would be affected under option 6). The 
expected  social  and  environmental  impacts  would  thus  be  comparable  to  the  impacts  of 
option  6  as  described  above.  These  begin  with  improved  cooperation  and  coordination 
between  authorities  involved  in  goods  clearance,  which  would  lead  to  improved  risk 
management and reduced instances of fraud and human error, in turn improving enforcement 
and compliance with the regulatory requirements in question.  

Potential risks  

Page 57 / 237 

 
 
 
This  option  carries  a  number  of  financial  and  operational  risks  due  to  its  broad  scope  and 
complexity. Financially,  this option would entail very large costs, both  for the Commission 
and Member State administrations. After long development and implementation periods, high 
recurrent costs would continue. This creates a risk that changing priorities at EU or national 
levels  could  make  the  necessary  resources  unavailable  at  some  point  in  the  future, 
endangering the initiative. Operational risks  would follow,  since the full participation of all 
Member  States  is  needed  for  many  of  this  option’s  functions.  Similarly,  this  option  puts  a 
single  centralised  EU  system  at  a  critical  point  in  the  EU’s  infrastructure  for  international 
trade. While the highest service standards can be followed (indeed, this in part explains the 
significant costs of this option), relying on one centralised system for all import, export and 
transit  declarations  means  that  any  outages,  data  breaches  or  other  problems  would  have 
larger repercussions than would be expected under the current system of systems distributed 
across the Member States.  

Option  8 (ii) –  Extend  the use of the Economic Operator Registration and Identification 
System (EORI) to partner competent authorities 

Stakeholder views  

Stakeholders  from  partner  DGs  within  the  Commission  and  Member  States  have  been 
consulted103 to  gauge their perceptions towards extending the use of EORI beyond customs 
purposes. Both sets of stakeholders have expressed very positive views. In the context of its 
national  single  window,  France  has  already  opened  the  use  of  EORI  to  partner  competent 
authorities  at  national  level  for  a  number  of  non-customs  regulatory  requirements  and  has 
reported positive experiences so far.  

Direct economic impacts 

Implementation and recurrent costs 

This  option  can  be  conceptualised  as  an  instrument  to  improve  the  implementation  of  any 
options it would be packaged with, as the EORI number could be an essential identification 
key  to  facilitate  sharing  and  cross-referencing  of  information.  It  would  entail  minor 
implementation  and  recurrent  costs  for  the  Commission,  national  customs  and  national 
partner competent authorities.  

On  the  European  Commission  side,  since  the  EORI  system  already  exists,  the  main 
implementation  costs  would  relate  to  expanding  the  capacity  of  the  system  to  handle 
increased traffic and providing a certain amount of training and support to partner DGs. For 
these,  the  main  costs  would  involve  building  the  necessary  connections  to  EORI,  updating 
their  systems  to  handle  EORI  data,  and  dealing  with  any  necessary  change  management, 
training and support. Once fully implemented, only a small amount of ongoing support and 
maintenance  would  be expected above that which takes place  for the system as  it currently 
exists.  According  to  estimates  from  DG  TAXUD,  it  would  take  three  years  to  make  the 
necessary connections, at a cost of EUR 0.3m  for the first  year, EUR 0.25m for the second 
year and EUR 0.2m for the third year, after which yearly operating costs of EUR 0.07m are 
foreseen. This would total EUR 1.0m for implementation during years 1-7, and EUR 0.07m 
annually from year 8 onwards.  

103   For partner DGs, the consultation took the form of a survey that was carried out in mid-2019 with DGs responsible for a 
number  of  regulatory  requirements  (DGs  AGRI,  CLIMA,  ENV,  HOME,  MARE,  MOVE,  SANTE  and  TRADE). 
Member State customs authorities were consulted on this option as part of an informal poll conducted during the High-
level seminar on the EU Single Window environment for customs, which took place in Bucharest during May 2019.  

Page 58 / 237 

 
 
                                                 
For  Member  State  authorities,  the  costs  would  be  concentrated  on  the  partner  competent 
authorities who are not already using EORI. Since the system is developed and maintained at 
European  level,  these  are  expected  to  be  relatively  minor  and  focused  on  updating  their 
systems so as to handle and use EORI data, where appropriate. Estimates from DG TAXUD 
and consultations with  IT experts put these at the same level as the Commission costs. The 
expected implementation and recurrent costs are summarised in the table below. 

Table 17: Estimated implementation and recurrent costs for option 8 (€m) 

EC  

MS  customs  and  partner 
competent authorities  

Total  

Implementation costs (years 1-7)  
0.03 for year 1, 0.25 for year 2,  
0.20 for year 3, thereafter 0.07 / year  
(1.03 total) 

0.30 for year 1, 0.25 for year 2,  
0.20 for year 3, thereafter 0.07 / year  
(1.03 total) 

0.60 for year 1, 0.50 for year 2,  
0.40 for year 3, thereafter 0.14 / year  
(2.06 total) 

Recurrent costs (year 8 onwards) 

0.07 / year 

0.07 / year 

0.14 / year  

Source:  Estimates  based  on  figures  from  DG  TAXUD  for  European  Commission  costs  and  Member  State  data  and 

consultation with IT experts for MS costs   

Recurrent benefits  

As  a  tool  to  facilitate  the  implementation  of  other  options,  option  8  (ii)  is  not  expected  to 
generate  benefits  on  its  own,  but  rather  would  improve  the  implementation  of  any  other 
policy  option  with  which  it  is  combined  by  slightly  increasing  its  benefits.  It  enables 
incremental  improvements  in  the  ability  of  customs  and  partner  competent  authorities  to 
identify traders and to  exchange, cross-reference and verify information  pertaining to them. 
Based  on  feedback  from  the  Commission  and  national  officials,  this  is  estimated  as  an 
increase of about 2,5% on top of the time savings that would be realised through any option 
package.  This  means  that  the  exact  impact  compared  to  the  baseline  thus  depends  on  the 
option package and cannot be looked at in isolation. For this reason, the figures related to the 
benefits of option 8 (ii) are presented in the next section on the comparison of options.  

Cost-benefit analysis  

As presented in the next section, the low costs and incremental benefits of option provide a 
cost-effective  way  to  further  increase  the  efficiency  of  clearance  processes.  The  net  benefit 
would depend on the option package with which option 8 (ii) is coupled, but in all cases this 
option would be expected to add benefits without significantly affecting cost-effectiveness.  

Social and environmental impacts 

Consultation  with  the  Commission  and  Member  States  indicates  that  this  option  would 
provide minor social and environmental impacts.  

7.  HOW DO THE OPTIONS COMPARE? 

As  explained  in  section  5,  the  retained  options  can  be  combined  to  form  distinct  policy 
choices, which are as follows104:   

104  As indicated in section 5, it should be noted that it would also be technically possible to implement option packages that 
include Option 2 on its own, namely options 2+8, options 2+6 and options 2+6+8. However, given that option 1 builds 
on the existing EU CSW-CERTEX project by expanding it to all Member States and covers the more accessible category 
of regulatory formalities to interconnect, it would not make any logical sense to put in place option 2, which covers a 
different category of formalities without firstly implementing option 1. 

Page 59 / 237 

 
 
 
                                                 
  Baseline scenario: under the baseline scenario, EU-level collaboration would continue 
through  voluntary  use  of  EU  CSW-CERTEX,  while  some  Member  States  would 
pursue individual national initiatives.   

  G2G  collaboration  only:  enhanced  G2G  collaboration  and  system  interoperability 
could be pursued either through option 1 on its own, or option 1 combined with either 
or both of options 2 and 8(ii)105;  

  G2G and B2G collaboration: to also pursue B2G collaboration, options 6 or 7106 could 

be combined with any of the G2G choices listed above107.  

The options packages are compared in terms of several criteria, namely effectiveness in terms 
of  achievement  of  objectives,  efficiency  (i.e.  cost-effectiveness),  coherence  in  relation  to 
relevant  policies,  and  proportionality.  This  leads  to  an  overall  comparison  to  identify  the 
preferred package of options.  

Effectiveness  

The  three  specific  objectives  relate  to  a  governance  framework  for  cooperation  and 
interoperability  between  customs  and  partner  competent  authorities,  improved  working 
practices and processes for goods clearance, and harmonisation and re-use by authorities of 
data  provided  by  economic  operators.  Because  these  objectives  are  closely  linked  and 
mutually reinforcing, it is more meaningful to examine effectiveness in terms of the two main 
elements  of  the  general  objective.  The  first,  “improve  enforcement  of  regulatory 
requirements”,  is  focused  on  improved  coordination  and  information-sharing  between 
authorities  and  the  resulting  social  and  environmental  benefits.  The  second,  “facilitate 
international trade”, relates to the reduced enforcement costs and administrative burden and 
resultant savings that are envisaged for customs authorities, partner competent authorities and 
economic operators. For both elements, the likely impacts can be estimated by adding up the 
benefits for each of the policy options (as elaborated in section 6) that form each package of 
options. Further, in considering effectiveness, it must be borne in mind that the full benefits 
would  not  be  achieved  immediately.  Instead,  these  would  be  phased  in  gradually.  For  all 
packages except those containing option 7, the phase-in would proceed at an even pace over 
seven  years. This means that any packages containing a combination of options 1, 2, 6 and 
8(ii) would realise full benefits from year 8 onwards.  

Packages  containing  option  7  would  entail  more  extensive  changes  to  the  existing  customs 
environment  and  therefore  require  more  time  for  implementation  than  the  other  options. 
Therefore, no benefits at all would be achieved during an initial seven years for development. 
Implementation  would  then  be  phased  over  a  period  of  five  years.  This  means  that  any 
package containing option 7 would realise full benefits only from year 13 onwards.  

105  The combination of options includes: option 1; options 1 + 2; options 1 + 8(ii); options 1 + 2 + 8(ii). See Annex 17 for an 

overview of the policy options.  

106  Given  that  option  7  would  replace  existing  EU  customs  systems  with  a  single  centralised  system,  this  would  be 
combined with a simplified version of option 1 that entails a single connection of EU CSW-CERTEX to the option 7 
system.  Thus, if implementing options 1 and 7 together, the Member States  would not incur the costs associated  with 
option 1. Similarly, it would only be feasible to implement option 7 alongside the direct connection version of option 2 
(i.e. 2(i)).  

107  The combination of options includes: options 1 + 6; options 1 +2 + 6; options 1 + 6 + 8(ii); options 1 + 2 +  6 + 8(ii)); 
options 1 +7; options 1 + 2 + 7; options 1 + 7 + 8(ii); options 1 + 2 + 7 + 8(ii). See Annex 17 for an overview of the 
options. 

Page 60 / 237 

 
 
                                                 
Improve enforcement of EU non-customs regulatory requirements  

Each option package would be expected to generate improvements to the enforcement of EU 
non-customs regulatory requirements, according to a similar causal chain. This relates to the 
social  and  environmental  impacts  described  in  section  6  and  would  entail  enhancing 
cooperation and facilitating the sharing of information between the authorities responsible for 
goods  clearance,  thereby  allowing  for  improvements  to  risk  management  processes  and 
reduced  instances  of  fraud  and  human  error.  This  would  in  turn  generate  improved 
compliance  and  enforcement  of  the  non-customs  legislation  falling  under  the  scope  of  the 
policy options that comprise each of the packages.  

Since  the  packages  differ  in  terms  of  which  non-customs  regulatory  requirements  are 
covered, it would be expected that the packages with the broadest scope would be the most 
effective  to  improve  enforcement.  The  following  factors  also  explain  the  relative 
effectiveness of the different packages:  

  Within  the  different  packages,  option  1  would  generate  the  most  significant 
improvements  to  enforcement  due  to  its  relatively  broad  coverage  of  non-customs 
regulatory  requirements,  and  its  high  degree  of  effectiveness  in  terms  of  enhancing 
G2G collaboration.  

  Options 6 and 7 would also generate important gains in terms of enforcement within 
certain packages. As detailed in section 6, these would result from the ability of these 
options  to  increase  levels  of  data  harmonisation  and  interoperability  in  a  way  that 
could not be achieved without B2G cooperation. The outcome of option 6 and option 
7 would be comparable, but materialise much faster for packages containing option 6 
than for those containing option 7.  

 

 

In  contrast,  the  additional  improvements  on  enforcement  of  including  option  2  are 
relatively  limited.  As  detailed  in  section  6,  this  option  would  not  fully  extend  key 
functionalities,  most  importantly  automated  quantity  management,  to  the  regulatory 
requirements that it covers108. This means that manual checks would still be necessary 
in many cases.  

Including  option  8(ii)  within  any  package  does  not  necessarily  impact  their 
effectiveness in terms of improved enforcement. This option only improves the ability 
of customs and partner competent authorities to identify traders and constitutes a tool 
to  facilitate  the  exchange,  cross-reference  and  verification  of  information  between 
customs and partner competent authorities systems.  

Concluding from the above, it can be said that, once full implementation is achieved, option 
packages  including  both  options  1  and  2,  in  addition  to  either  option  6  or  7,  would  be  the 
most effective to improve enforcement compared to the baseline. These benefits could also be 
marginally increased by adding option 8(ii) to any package. Packages comprised of the same 
options  but  not  including  option  2  would  generate  benefits  that  are  only  modestly  reduced. 
The smallest benefit in terms of improved enforcement would be expected from the packages 
made up of just option 1 or options 1+8(ii). However, given the major benefits expected from 
option  1,  even  these  benefits  would  far  exceed  the  baseline.  Finally,  for  the  packages 
containing  option  7,  a  major  disadvantage  is  that  the  benefits  would  take  much  longer  to 
materialise than for any other packages.  

108  The  reason  for  this  is  that  automated  quantity  management  would  only  be  possible  under  option  2  for  the  regulatory 
requirements  for  which  all  Member  States  have  a  digitalised  systems  in  place.  This  is  not  the  case  for  most  of  the 
regulatory requirements covered by Option 2.  

Page 61 / 237 

 
 
                                                 
Facilitate international trade 

Effectiveness in terms of trade facilitation can be expressed mainly as per the direct economic 
benefits  resulting  from  streamlined  goods  clearance  for  customs  authorities,  partner 
competent authorities and economic operators. Quantified and monetised estimates for each 
individual  option  are  presented  in  section  6.  To  estimate  the  benefits  for  the  different 
packages, the benefits of the options included in given packages can simply be added up (e.g. 
the  benefits  of  package  1+2  are  comprised  of  the  benefits  of  option  1  plus  the  additional 
benefits of option 2).  

The  main  considerations  for  the  comparison  are  presented  below.  For  the  purpose  of 
simplicity,  the  figures  below  refer  to  annual  benefits  once  full  implementation  is  achieved. 
Annex 13 contains comprehensive and detailed data on benefits for both full implementation 
and phase-in periods.  

  The  most  important  direct  economic  benefits  could  be  expected  from  the  packages 
with  the  widest  scope  in  terms  of  coverage  of  EU  non-customs  regulatory 
requirements.  These  would  affect  the  largest  numbers  of  customs  declarations  and 
allow  for  the  benefits  of  both  G2G  and  B2G  elements.  For  example,  the  narrowest 
package  (containing  just  option  1)  would  generate  total  annual  benefits  from 
EUR 102.3m  to  EUR 156.9m.  For  options  1+2+6+8(ii)  or  1+2+7+8(ii),  the  benefits 
would  be  much  larger,  ranging  from  EUR 244.8m  to  EUR 361.2m  under  options 
1+2+6+8(ii) or 1+2+7+8(ii).  

  Much  of  benefits  to  customs  and  partner  competent  authorities  would  be  achieved 
through the G2G cooperation envisaged in option 1, while the lion’s share of potential 
benefits  for  economic  operators  (including  SMEs)  would  require  B2G  collaboration 
from either option 6 or option 7. For example, benefits for customs authorities would 
range  under  option  1  from  EUR 49.5m  to  EUR 74.3m  under  option  1,  and  from 
EUR 77.4m  to  EUR 118.4m  under  options  1+2+6+8(ii)  or  1+2+7+8(ii).  While  the 
difference is between these option packages is substantial, it is far larger with regard 
to  economic  operators.  As  with  customs  authorities,  these  would  see  benefits 
estimated at EUR 49.5m to EUR 74.3m under option 1, but the benefits for economic 
operators under option 1+2+6+8(ii) or 1+2+7+8(ii) would range from EUR 157.7m to 
EUR 218.8m.  

  Since option 7 would harmonise the entire IT environment for customs throughout the 
EU, the packages containing it would also improve processes for goods clearance for 
all traders engaging in international trade (as elaborated in section 6.2).  

  As elaborated in  section 6.2, option 2 contributes only moderately to  the benefits  to 
any option package since manual checks would still be necessary for the verification 
of  supporting  documents  issued  in  any  Member  State  without  a  national  electronic 
system.  

  Because it is more complex and requires much bigger changes to existing customs IT 
infrastructure, the implementation period is substantially longer for option 7 than for 
option  6.  Thus,  while  the  long-term  benefits  are  comparable,  the  benefits  would 
materialise  much  more  quickly  for  packages  containing  option  6  than  for  packages 
including option 7 (which would have no benefits at all for seven years, and only then 
undergo gradual implementation during a period of 5 years). This leads to significant 
differences in the scale of expected benefits during  years 1-12 that need to be taken 
into account for the comparison.  

Page 62 / 237 

 
 
  Overall, the largest benefits for trade facilitation could be expected from either option 
packages 1+2+6+8(ii) or 1+2+7+8(ii), meaning that these two packages are the most 
effective  in  facilitating  trade.  Taking  all  stakeholders  into  account,  these  benefits 
would  range  from  EUR 244.8m  to  EUR 361.2m  annually.  However,  package 
1+2+6+8(ii) would begin to bring benefits from year 1 and be fully operational from 
year  8  onwards,  while  (as  mentioned  above)  option  1+2+7+8(ii)  would  achieve  no 
benefits until year 8, and full benefits only from year 13. Packages without option 2 
would  achieve  benefits  on  a  smaller  but  comparable  scale.  These  would  be  in  the 
range of EUR 209.4m to EUR 311.5m annually for package 1+6+8(ii) or 1+7+8(ii) or 
EUR 204.3m to EUR 303.9m for package 1+6 or 1+7. 

Efficiency 

The  cost-effectiveness  of  the  different  packages  can  be  derived  by  dividing  the  benefits 
achieved  in  terms  of  trade  facilitation  by  costs  to  the  Commission,  national  authorities  and 
economic  operators.  Since  benefits  to  improved  enforcement  were  considered  qualitatively, 
these are not factored into the quantitative calculations, implying a conservative estimate of 
the  efficiency109.  However,  both  aspects  of  effectiveness  are  influenced  by  the  coverage  of 
the options packages in terms of EU non-customs regulatory requirements, with the broader 
packages generating larger benefits. For this reason, the most advantageous packages in terms 
of  enforcement  tend  to  also  be  the  most  advantageous  in  terms  of  trade  facilitation.  In  this 
way, the comparison of cost-effectiveness based on the quantitative benefits also holds true in 
terms of effectiveness as a whole. The points below summarise the main considerations for 
the comparison, while the table in Annex 13 contains detailed figures on costs and benefits 
for all packages, both during phase-in periods and once full implementation is achieved.  

  Among the G2G options, ratio of benefits  to  costs of option 1 is  very high, ranging 
EUR 16 to  EUR 32 once fully implementation  is  achieved. The cost-benefit ratio of 
option 2 is much lower, at EUR 3 to EUR 6. This means that all packages containing 
option 1, but not option 2, provide much better value for money than the ones that do 
contain option 2.  

  While neither of the G2G options 6 or 7 provide as high a cost-benefit ratio as option 
1,  the  packages  including  these  would  allow  much  greater  benefits  to  be  achieved, 
especially for economic operators, than the packages consisting of G2G action only. 
Moreover, the packages  including either option 6 or option 7 for  B2G action would 
lead to additional, comparable benefits for the enforcement of important non-customs 
regulatory requirements and trade benefits that, while not quantifiable, are likely to be 
important.  

  Among the options for B2G action, option 6 is relatively cost-effective, with expected 
benefits  on  its  own  of  EUR 9  to  EUR 20  expected  from  each  EUR  spent  once  it  is 
fully  operational.  The  most  advantage  package  including  B2G  action  is  package 
1+6+8(ii),  which  would  generate  net  benefits  ranging  from  EUR 191.3m  to 
EUR 299.2m. This entails economic benefits from EUR 12 to EUR 25 for every EUR 
spent. 

109   In this approach, benefits are underestimated, while costs considered fully. As benefits from improved enforcement are 
distributed  in  the  same  way  as  benefits  from  trade  facilitation,  the  order  in  the  assessment  of  the  efficiency  of  the 
various packages remains the same. 

Page 63 / 237 

 
 
                                                 
  Benefits would be expected to exceed costs in year 1 for packages made up of option 
1  and  options  1+8(ii),  while  this  would  only  be  expected  from  year  2  onwards  for 
packages made up of options 1+2, 1+2+8(ii), 1+2+6 and 1+2+6+8(ii).  

  Any  package  containing  option  7  would  generate  large  negative  impacts  because  it 
would  entail  a  very  expensive  overhaul  of  the  entire  IT  environment  for  customs. 
Once fully operational, from year 13, even the most cost-effective package including 
option  7  (i.e.  option  1+7)  would  entail  negative  annual  economic  impacts  of  EUR -
1 319.5m  to  EUR -610.4m.  In  other  words,  each  EUR  spent,  this  package  would 
generate  only  EUR 0.13  to  EUR 0.33  in  benefits.  Moreover,  packages  containing 
option  7  would  incur  large  costs,  with  no  benefits  at  all,  during  years  1-7,  and 
continued large net negative impacts during gradual implementation from years 8-12. 
Unlike  other  packages,  economic  operators  would  also  incur  some  implementation 
costs for packages containing option 7.  

  Stakeholder views on the different options depended strongly on expected efficiency 
and thus echoed the above. Thus, option 1 received nearly unanimous support as part 
of any option package, because the experience of EU CSW-CERTEX showed that the 
envisaged benefits could be achieved at and relatively limited cost. Similarly, option 6 
received strong support as a means of delivering on the full single window concept in 
a manageable way. Option 8(ii), though limited in  scope, was  appreciated by nearly 
all stakeholders as a way to further streamline processes. The only options with low 
support were option 2, which was seen as complex and expensive, despite relatively 
limited  benefits,  and  option  7.  The  latter  was  appreciated  by  economic  operators, 
since they would experience the benefits while incurring only minor implementation 
costs.  But  customs  authorities  considered  option  7  unrealistically  expensive  and 
therefore did not support it.  

Coherence  

The  breadth  of  the  initiative,  which  relates  to  international  trade  and  is  focused  not  just  on 
customs  but  on  a  wide  range  of  non-customs  regulatory  requirements,  makes  its  alignment 
with  other  EU  and  international  policies  and  standards  especially  important.  Relevant 
initiatives include:  

  High-level  EU  policy  aims  to  establish  a  Single  Window  environment  for  customs. 
These  are  elaborated  in  Article  4,  paragraph  6  of  the  e-Customs  Decision  (Decision 
No 70/2008/EC), which calls on the Member States and Commission to “endeavour to 
establish  and  make  operational  a  framework  of  single  window  services”.  The  2014 
Venice Declaration follows this by referring to a progressive action plan to implement 
an  EU  Single  Window  environment  for  customs  and  to  establish  a  legal  framework 
for  its  development.  In  addition,  the  2016  Communication  on  “Developing  the  EU 
Customs  Union  and  Governance”  announced  the  Commission’s  plans  to  find  a 
workable  solution  for  the  development  and  creation  of  an  EU  Single  Window 
environment for customs. This is echoed in the 2018 Biennial Report on the Progress 
in  Developing  the  EU  Customs  Union,  which  identified  the  EU  Single  Window 
environment for customs as a priority area. 

  EU  policy  aims 

the  digitalisation  of  government  services  and 
interoperability,  most  importantly  the  EU  eGovernment  Action  Plan  2016-2020, 
which seeks to increase the efficiency of public services by removing existing digital 

regarding 

Page 64 / 237 

 
 
barriers,  reducing  administrative  burdens  and  improving  the  quality  of  interactions 
between  national  administrations110    and  the  Tallinn  Declaration,  which  (inter  alia) 
sets  objectives  on  digital-by-default  for  interactions  between  citizens  and businesses 
and principles of once-only and interoperable by default111. 

  Other EU customs policies, most importantly the Union Customs Code, which aims to 
put in place a modern and electronic customs environment and to encourage the use of 
modern  tools  and  technology  to  promote  the  uniform  application  of  customs 
legislation  and  modernised  approaches  to  customs  control.  Related  to  this  are  the 
extensive  customs  IT  projects  detailed  in  the  UCC  Work  Programme,  and  aligned 
with  the  MASP-C,  which  ensures  the  operational  planning  and  implementation 
timeline of all customs IT projects112. 

 

International  initiatives,  most  importantly  the  WTO  Trade  Facilitation  Agreement 
ratified  by  the  EU113  in  2015,  the  UNECE  Recommendation  33  and  the  Single 
Window  Compendium  of  the  WCO,  all  of  which  call  for  the  development  of 
advanced  single  window  solutions,  including  single-entry  points  for  economic 
operators.  

While the objectives as defined in section 4 are consistent with these initiatives, the different 
option packages relate to them in different ways.114 More specifically:  

  The continuation of the baseline scenario would not be coherent because it would fail 
to achieve the various EU policy aims listed above. In addition, some Member States 
would also pursue national initiatives, entrenching solutions that are not interoperable 
and exacerbating the problems described in section 2. 

  The  packages  based  mainly  on  G2G  cooperation  are  generally  consistent  with  the 
different  policy  aims,  would  support  the  implementation  of  EU  sectoral  legislation 
and  help  the  EU  to  take  a  consistent  approach  towards  international  initiatives. 
However,  these  options  packages  would  fail  to  establish  a  “Single  Window”  as  the 
term  as  commonly  understood  and  defined  internationally,  i.e.  as  a  facility  which 
allows parties involved in trade and transport to lodge standardised digital information 
and  electronic  documents  with  a  single-entry  point  to  fulfil  all  import,  export  and 
transit-related regulatory requirements115.  

  Within the G2G options, option 1 is considered highly coherent, because it makes use 
of the existing EU CSW-CERTEX architecture and electronic systems developed by 
partner DGs.  

  Option  2 is  less coherent.  By  establishing connections  between the national  systems 
used  to  manage  some  non-customs  EU  regulatory  requirements,  it  could  discourage 

110 COM/2016/0179 final 
111 https://ec.europa.eu/digital-single-market/en/news/ministerial-declaration-egovernment-tallinn-declaration  
112  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. 
6–20. 

113  https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015D1947&qid=1591603516369&from=EN 
114  It  is  also  noted  that  all  option  packages  would  be  highly  secure  and  compliant  with  the  General  Data  Protection 
Regulation  and  any  relevant  sectoral  legislation.  Since  there  are  no  important  distinctions  between  the  packages,  this 
aspect is not emphasised in the comparison.  

115  See UNECE Recommendation 33 on establishing a Single Window: 

https://www.unece.org/fileadmin/DAM/cefact/recommendations/rec33/rec33_trd352e.pdf.  It  should  also  be  noted  that 
the recommendation has been revised in consultation with DG TAXUD and other key stakeholders, among other things 
to ensure adequate considerations of regional customs unions such as the EU Customs Union.  

Page 65 / 237 

 
 
  
                                                 
 
the development of centralised non-customs solutions at EU level. Moreover, it does 
not  provide  for  quantity  management,  which  is  a  key  element  of  improved 
information-sharing  between  customs  and  partner  competent  authorities  based  in 
different Member States.  

  The packages  including B2G cooperation (i.e. including either option 6 or option 7) 
would  establish  a  true  Single  Window  environment,  thus  working  towards  wider 
policy  aims  and  conforming  to  international  best  practices.  The  packages  including 
option 6 would do this while remaining consistent with the UCC and MASP-C. This 
defines  certain  customs  functions  as  being  centralised,  while  others,  particularly  the 
IT systems for import, export and transit, are either national or distributed. However, 
option  7  would  be  incoherent  with  the  UCC  because  it  would  oblige  the  Member 
States to implement a centralised solution for these core customs functions. It would 
also  be  inconsistent  with  the  EU  eGovernment  principles  of  re-use  of  systems  and 
interoperability where possible instead of developing wholly new systems.  

Proportionality  

Proportionality refers to the extent to which an initiative is as simple as possible, does not go 
beyond what is necessary to achieve its objectives, and limits its scope to those aspects that 
the  Member  States  cannot  achieve  on  their  own.  The  packages  including  combinations  of 
options 1, 6 and 8(ii) take simple approaches that  make the most of existing infrastructure, 
limiting themselves to areas where the potential EU added value is highest. 

The  proportionality  of  packages  containing  option  2  is  less  pronounced,  because  it  would 
require  significant  resources  to  partially  achieve  the  objectives.  Similarly,  but  more 
importantly,  option  7  renders  any  package  that  includes  it  deeply  disproportionate.  Beyond 
poor  cost-effectiveness,  packages  containing  option  7  would  also  centralise  the  entire 
customs environment. This would go beyond the UCC and transform (at high cost) the daily 
business  of  many  actors  beyond  those  involved  in  the  EU  non-customs  regulatory 
requirements covered by the initiative. While centralising the customs IT infrastructure could 
generate  major  benefits,  it  would  be  hard  to  justify  in  the  name  of  the  Single  Window 
environment alone.  
Overall comparison and identification of the preferred option  

The table below depicts the results of the comparison, in terms of scores for each package of 
options  and  criterion.  Pluses  (+)  and  minuses  (-)  are  used  to  denote  whether  the  package 
would  perform  better  or  worse  than  under  the  continuation  of  the  baseline  scenario.  An 
eleven-point scale is used, such that five pluses (+++++) means ‘would perform better than 
the baseline to a great extent’, 0 means ‘would not differ from the baseline scenario’ and five 
minuses (-----) means ‘would perform worse than the baseline to a great extent’. Given their 
similar importance, the criteria are not weighted but rather considered equally to identify the 
preferred option. The following considerations explain the scores for the different criteria and 
packages116.  

  Effectiveness: with  regard to  both improved enforcement and trade facilitation, high 
scores  are  given  based  on  the  broadest  coverage  in  terms  of  EU  non-customs 
regulatory requirements and possibilities for both G2G and B2G elements. Narrower 
coverage  is  equated  with  proportionately  lower  scores.  The  packages  containing 

116 Since the additional benefits from option 8(ii) are only incremental, the packages including it are not given higher scores 
than  the  similar  packages  that  do  not  include  it.  Nonetheless,  adding  option  8(ii)  to  any  package  can  be  considered  to 
make it more desirable on the margin. 

Page 66 / 237 

 
 
                                                 
option 6 would generate comparable benefits to those containing option 7 once fully 
operational117.The scores are numerically proportionate, such that a package receiving 
++ would be expected to result in double the savings, or improve the enforcement for 
regulatory  requirements  affecting  twice  as  many  customs  declarations,  as  a  package 
receiving +. 

  Cost-effectiveness:  Option  1  is  the  most  cost-effective  option,  meaning  that  the 
packages  aside  from  option  1  on  its  own  and  options  1+8(ii)  are  less  cost-effective. 
Packages made up of options 1+6 and 1+6+8(ii) are nearly as cost-effective, while the 
limited cost-effectiveness of option 2 reduces the scores  of packages  that  contain it. 
All  packages  containing  option  7  received  negative  scores,  since  their  costs  are 
significantly  larger  than  their  benefits.  These  scores  are  also  proportionate,  with  an 
option  package  receiving  ++  being  roughly  twice  as  cost-effective  as  a  package 
receiving +.  

  Coherence:  packages  containing  just  G2G  action  would  still  work  towards  policy 
goals  and  thus  would  be  more  coherent  than  the  baseline  scenario.  However,  since 
B2G cooperation is needed to achieve the single-entry points called for in existing EU 
policy documents, the highest scores are reserved for packages containing both G2G 
and B2G elements.  Option 2 is  considered to  reduce the coherence of packages that 
contain  it,  since  it  would  preclude  the  development  of  EU  electronic  systems  to 
manage certain EU non-customs regulatory requirements. Packages containing option 
7 have been scored negatively, because of major incoherence related to the division of 
customs  responsibilities between  the  EU  and  Member  States  as  defined  in  the  UCC 
and MASP-C. The scores represent a qualitative assessment of the findings and thus 
do not have any numerical relationship.   

  Proportionality:  taking  into  account  the  general  objectives  of  this  initiative  and  the 
outreach of each option package, combinations 1+6 and 1+6+8(ii) score the highest, 
while  option  2  detracts  from  the  scores  of  packages  that  contain  it.  Due  to  its 
disproportionate  nature,  negative  scores  are  given  to  packages  containing  option  7 
since it far  exceeds  what  is  necessary to  achieve the objectives of this  initiative.  As 
with coherence, the scores are based on a qualitative assessment of the findings.  

 

Identification of the preferred package: packages 1+6 and 1+6+8(ii) receive the most 
favourable  scores.  Despite  not  providing  the  most  benefits  in  absolute  terms,  these 
packages  are  comparatively  cost-effective,  coherent  and  proportionate.  Since  the 
inclusion of option 8(ii) adds some incremental benefits without imposing substantial 
costs, the preferred package is thus options 1+6+8(ii). 

Table 18: Comparison of option packages to the baseline scenario118 

117 Regarding trade facilitation, the benefits of packages containing option 7 would take significantly longer materialise than 
the benefits of packages containing option 6. However, packages containing option 7 would also, by improving customs 
clearance  processes  generally,  generate  some  additional  benefits  for  all  economic  operators  engaging  in  international 
trade. Taking these two elements into account, the scores given for packages containing option 7 are given the equivalent 
scores to similar packages containing option 6. 

118  Given that option 7 would replace existing EU customs systems with a single centralised system, this would be combined 
with  a  simplified  version  of  option  1  that  entails  a  single  connection  of  EU  CSW-CERTEX  to  the  option  7  system. 
Similarly, it would only be feasible to implement option 7 alongside the direct connection version of option 2 (i.e. 2(i)).   

Page 67 / 237 

 
 
                                                 
Baseline 

G2G collaboration only 

G2G and B2G collaboration  

0 

0 

1 

1+2 

1+8(ii) 

1+2+8(ii) 

1+6 

1+2+6 

1+6+8(ii) 

1+2+6+8(ii) 

1+7 

1+2(i)+7 

1+7+8(ii) 

1+2(i)+7+8(ii) 

+++ 

++++ 

+++ 

++++ 

++++ 

+++++ 

++++ 

+++++ 

+++ 

++++ 

+++ 

++++ 

0 

++ 

+++ 

++ 

+++ 

++++ 

+++++ 

++++ 

+++++ 

++++ 

+++++ 

++++ 

+++++ 

0 

0 

0 

++++ 

+ 

++++ 

+ 

+++ 

+ 

++++ 

++ 

---- 

----- 

---- 

+++ 

++ 

+++ 

+++ 

++ 

+++ 

++ 

++ 

++++ 

+++ 

++++ 

+++ 

- 

-- 

- 

+++ 

++ 

+++ 

++ 

---- 

----- 

---- 

----- 

-- 

----- 

Improve 
enforcement 
of regulatory 
requirements 
Facilitate 
international 
trade 

s
s
e
n
e
v
i
t
c
e
f
f

E

Efficiency -  
Cost-effectiveness 
Coherence 

Proportionality  

Source: DG TAXUD 

8.  PREFERRED OPTION 

The  foregoing  analysis  points  towards  a  policy  choice  comprised  of  option  package 
1+6+8(ii)119, inclusive of the following elements:   

Option category 

Overview 

I:  G2G 

Group 
back-end 
cooperation  to  make  it  easier 
for 
partner 
competent  authorities  to  share 
information 

customs 

and 

II:  B2G 

Group 
front-end 
cooperation aimed at improving 
operators’ 
economic 
interactions  with  customs  and 
partner competent authorities 

Group III: Expansion of the use 
of EORI 

Option  1:  makes  EU  CSW-CERTEX  mandatory, 
increases  its  functionality  (to  include  features  such  as 
automated  quantity  management) 
expands 
coverage to  all EU non-customs regulatory  formalities 
for which relevant information required by customs for 
clearance is available at central level. 

and 

Option  6  (harmonised  national  single  windows):  each 
Member  State  to  establish  an  integrated  declaration 
system  that  would  allow  for  joined  up  submission  by 
economic operators of information required by customs 
and  partner  competent  authorities  for  a  range  of  EU 
regulatory  formalities.  This  allows  for  delivery  of  the 
full  single  window  concept,  with  the  Commission 
playing a steering role as regards EU formalities. 

Option  8(ii):  to  facilitate  collaboration  between  the 
different  authorities  involved  in  international  trade, 
EORI  will  be  opened  up  so  that  partner  competent 
authorities can use it for validation purposes. 

This package offers several relative advantages. It received the highest levels of stakeholder 
support.  It  is  also  expected  to  generate  significant  direct  economic  impacts,  totalling  EUR 
192.3m to EUR 299.2m annually once fully operational. While the total economic impact is 
less than for the most expansive option packages, the value for money of the preferred option 
package is nearly 1.5 times higher, showing its proportionality. This is in addition to wider 
trade  benefits  that  are  likely  to  be  substantial  but  could  not  be  quantified.  In  terms  of 

119 An overview of the practical implications by stakeholder group and the summary of the costs and benefits of the preferred 

option package is provided in Annex 3. 

Page 68 / 237 

 
 
 
 
 
 
 
                                                 
environmental and social impacts, this package would combine the major benefits of option 1 
with  additional  gains  from  the  increased  data  harmonisation  and  interoperability  expected 
from  option  6,  as  well  as  incremental  benefits  from  option  8(ii)  related  to  better  economic 
operator identification. Only minor benefits would be foregone from not including option 2. 
Overall, it can thus be said that this package maximises the EU’s ability to act as a catalyst 
for  the  single  window  concept,  providing  a  framework  for  implementing  EU  policy 
applicable  to  goods  clearance  that  is  effective  and  proportionate,  and  demonstrating  high 
value for money.                                                                                                        

To  address  the  continually  changing  digital  landscape  over  the  long-term,  the  preferred 
options package builds on the principles of flexibility, adaptability and efficiency. This will 
help produce a future-proof solution that can easily expand progressively to incorporate new 
Union  non-customs  formalities  from  diverse  policy  domains  as  they  become  digitalised. 
Moreover, this strategy presents opportunities for integrated solutions rather than rigid ones 
developed in a piecemeal fashion. This would allow to cater for the diversity of the Member 
States  situations  with  the  potential  to  scale  up  the  capacity  of  EU  CSW-CERTEX,  while 
accommodating future trends and uncertainties.   

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The  Commission  will  ensure  that  arrangements  are  in  place  to  monitor  and  evaluate  the 
functioning of the EU SW environment for customs and evaluate it against the main policy 
objectives. Regular monitoring will rely to the extent possible on EU level sources, such as 
disaggregated reports on Customs Union Performance and EU CSW-CERTEX business and 
IT deliverables and statistics. National customs administrations who are gatekeepers for other 
relevant  data,  such  as  statistics  on  clearance  times,  will  be  consulted  to  determine  whether 
and to what extent it will also be possible to use other sources.  

Six  years  after  the  entry  into  force  of  the  legislation  and  every  three  years  thereafter,  the 
Commission  should  submit  to  the  European  Parliament  and  the  Council  a  report  on  the 
functioning  of  the  EU  SW  environment  for  customs,  including  an  overall  evaluation  of  the 
EU CSW-CERTEX system. It should examine results achieved against objectives and assess 
the  continuing  validity  of  the  underlying  rationale  and  any  implications  for  future  options. 
Given that the initiative will not yet be fully implemented at the time of the first evaluation, 
the focus will be to take stock of progress, identify areas for improvement and come up with 
recommendations  for  the  future.  The  second  evaluation  will  take  a  more  summative 
approach, with a view to the achievement of objectives and comparison with what could have 
been  expected  otherwise.  The  success  of  the  initiative  will  be  contingent  on  meeting  the 
specific  objectives,  and  in  particular  on  introducing  an  effective  EU-wide  quantity 
management  functionality  for  the  non-customs  formalities  under  consideration.  The 
Commission will evaluate the functioning of the EU SW environment for customs in light of 
the  improved  digital  collaboration  between  customs  and  partner  competent  authorities 
involved  in  goods  clearance  to  ensure  simplified  processes  for  economic  operators  and  the 
efficient enforcement of Union non-customs formalities.   

The following table provides the operational objectives, progress indicators and data sources, 
which  would  be  used  to  inform  against  these  indicators.  The  monitoring  indicators  are 
expected  to  be  collected  where  possible  on  an  ongoing  basis  by  the  EU  CSW-CERTEX 
system.  For  evaluation  purposes,  annual  statistics  will  be  computed  and  compared  between 
successive years. Where possible, a comparison with the baseline situation taken as the trend 
or average of the three years that precede the entry into operations can be used. 

Page 69 / 237 

 
 
Specific objective 

Operational objectives 

Enhance 
cooperation 
between  customs  and 
competent 
partner 
authorities  involved  in 
international trade  

  Develop  and  implement  business  and  IT 
projects needed to connect Member States 
systems 
and  EU 
systems 
customs 
managing regulatory formalities 

 

Increase communication and collaboration 
between  customs  and  partner  competent 
authorities   

Progress indicator 
NB: indicators refer to customs clearance for the goods 
covered by the initiative 
  Number  of  connections  developed  between  EU  systems 
managing regulatory formalities and EU CSW-CERTEX  
  Number  of  non-customs  regulatory  formalities  covered 

by the initiative in a given year 

  Number of Member States using the EU CSW-CERTEX 

per given formality at a given year 

  Development  of  new  key  functionalities  for  EU  CSW-

CERTEX  

  Number  of  agreements  (e.g.  MoUs)  between  DG 
TAXUD and partner DGs for formalities covered by the 
initiative  
Perceived strength of coordination between customs and 
PCAs   

 

  Number  of  steering  committees  of  customs  and  partner 

competent authorities set up at national level.  

Improved  enforcement 
cross-border 
of 
regulatory 
requirements  

  Reduce  fraud  and  errors  associated  with 

  Number of declarations subject to automated exchange of 

 

clearance processes at EU borders  
Improve  risk  management  procedures  for 
goods clearance at EU borders 

information processed via EU CSW-CERTEX 

  Number  of  requests  per  Member  State  to  the  EU  CSW-

CERTEX  

Data sources 

  Business and IT deliverables and statistics 

/ reports   

  Business and IT statistics and reports  
 

Evaluations of  relevant  customs  and  non-
customs policies  
Survey of customs and PCAs 

 

IT statistics and reports 

 
  Customs Union Performance reporting 
 

Evaluations of  relevant  customs  and  non-
customs policies  
Survey of customs and PCAs 

  Number  of  discrepancies  detected  through  automated 

 

cross-checking of information 

  Number  of  fraud  attempts  detected  through  automated 

cross-checking of information  

  Hit 

rate  of  documentary  controls 

the 
systematic automated cross-check enabled by EU CSW-
CERTEX) 

(following 

Simplified 
goods 
clearance  processes  for 
economic operators 

  Use  electronic  means  and 

improved 
coordination  between  authorities  involved 
with  goods  clearance  to  streamline  and 
simplify processes for economic operators  

  Hit  rate  of  physical  controls  (following  the  systematic 

automated enabled by EU CSW-CERTEX) 

  Volume of non-compliant goods seized / refused entry  
 

Proportion of automated controls not followed by manual 
intervention (documentary or physical controls)   
  Average time needed for clearance of relevant goods  
 

Level  of  satisfaction  and  agreement  that  processes  have 
improved among EOs  
Status  of  work  to  define  common  data  sets  between  the 
customs declaration and the formalities under scope   

 

 
 
 

IT statistics and reports 
Survey of customs and PCAs 
Survey of economic operators  

Source: DG TAXUD

  Number  of  customs 

integrated  declarations 

lodged 

through national single windows 

Page 70 / 237 

 
 
ANNEX 1: PROCEDURAL INFORMATION 

Lead DG, DEcide Planning/CWP references  

The initiative on the EU Single Window environment for customs was carried out under the 
leadership of the Directorate-General  for Taxation and Customs Union (DG TAXUD). The 
agenda planning reference is PLAN/2017/1149.  

Organisation and timing 

No EU legislation is currently in place for the EU Single Window environment for customs. 
DG TAXUD started gathering feedback for the impact assessment in December 2016, when 
it established the EU Customs Single Windows Project Group (the project group) to study a 
possible framework to develop the EU Single Window environment for customs including its 
legal  aspects.  DG  TAXUD  received  political  validation  for  the  legal  initiative  on  20  June 
2017.   

An  interservice  steering  group,  chaired  by  the  Secretariat  General  (SG),  supported  the 
steering  of  the  project  and  allowed  to  integrate  views  of  other  DGs  and  services.  The 
interservice steering group included colleagues from the Directorage-General for Agriculture 
and  Rural  Development  (DG  AGRI),  the  Directorate-General  for  Climate  Action  (DG 
CLIMA),  the  Directorate-General  for  Communications  Networks,  Content  and  Technology 
(DG CNECT), the Directorate-General for Informatics (DG DIGIT), the Directorate-General 
for  Environment  (DG  ENV),  the  Directorate-General  for  Internal  Market,  Industry, 
Entrepreneurship  and  Small  and  Medium-sized  Enterprises  (DG  GROW),  the  Directorate-
General  for  Migration  and  Home  Affairs  (DG  HOME),  the  Legal  Service  (LS),  the 
Directorate-General for Maritime Affairs and Fisheries (DG MARE), the Directorate-General 
for Mobility and Transport (DG MOVE), the Directorate-General for Health and Food Safety 
(DG  SANTE),  the  Secretariat  General  (SG),  and  the  Directorate-General  for  Trade  (DG 
TRADE).  The  interservice  steering  group  met  several  times  between  March  2018  and 
January 2020. 

A  brief  chronology  of  significant  milestones  leading  to  the  adoption  of  the  draft  impact 
assessment is provided below: 

Date 

20/06/2017 

02/03/2018 

Activity 

Political validation of the legal initiative 
1st meeting of the interservice steering group 

04/05/2018 

Publication of the Inception Impact Assessment 

09/10/2018 

Launch of stakeholder consultation (14 weeks) 

17/01/2019 

End of stakeholder consultation 

16-17/05/2019 

High-level seminar  

10/01/2020 

Last  meeting 
group 
before  submission  of  the  impact  assessment  report  to  the 
Regulatory Scrutiny Board 

interservice 

steering 

the 

of 

17/02/2020 

Launch of the interservice steering group written procedure before 
submission of the report to the Regulatory Scrutiny Board 

13/03/2020 

Submission to the Regulatory Scrutiny Board 

Page 71 / 237 

 
 
29/04/2020 

Presentation to the Regulatory Scrutiny Board 

05/05/2020 

15/06/2020 

Negative opinion of the Regulatory Scrutiny Board 

group 
Last  meeting 
before  resubmission  of  the  impact  assessment  report  to  the 
Regulatory Scrutiny Board 

interservice 

steering 

the 

of 

18/06/2020 

Resubmission to the Regulatory Scrutiny Board 

15/07/2020 

17/07/2020 

Positive opinion of the Regulatory Scrutiny Board 

Last  meeting 
group 
on  the  final  version  of  the  impact  assessment  report  and  legal 
proposal 

inter-service 

steering 

the 

of 

Consultation of the Regulatory Scrutiny Board 

The draft impact assessment report was submitted to the Commission’s Regulatory Scrutiny 
Board (RSB) on 13 March 2020. Following the meeting on 29 April 2020, the RSB issued a 
negative  opinion  on  5  May  2020,  suggesting  several  areas  for  further  improvement.  The 
revised report was resubmitted on 18 June 2020. The Board issued a positive opinion on 15 
July  2019.  The  RSB  recommendations  for  both  submissions  along  with  the  changes 
introduced in the text are summarised below:  

Table 19: Consultation of the Regulatory Scrutiny Board 

1st RSB Opinion - Recommendations 

Changes introduced in the revised version 

(B) Summary of findings 

(1) The report does not provide a clear 
vision of what the Commission aims 
to achieve, over what timeframe, and 
the place of this initiative in this 
vision. 

(2) The range of the analysed options 
does not seem complete, especially 
regarding centralised national 
databases. Reasons for discarding 
some options are not well justified. 

the  vision  of  what 

The  introductory  section  has  been  revised  to 
further  explain 
the 
Commission  aims  to  achieve  within  a  specific 
timeframe.  The  development  of  a  framework 
for  digital  cooperation  between  customs  and 
partner  competent  authorities  is  central  to  this 
vision.  

The  options  were  analysed  based  on  the 
objectives  of  this  initiative  and  the  varying 
levels of participation by the Member States in 
the voluntary EU project (EU CSW-CERTEX) 
or  engagements  with  national  single  window 
initiatives.  Section  5.3  (Description  of  the 
policy  options)  explains  that  the  potential 
development  of  centralised  national  databases 
falls outside the scope of this initiative since it 
would  require  individual  analyses  for  each 
regulatory  formality  under the scope of option 
2  and  additional 
input  from  all  relevant 
stakeholder  groups.  Sections  5.3  and  6.2 

Page 72 / 237 

 
 
 
 
 
 
(3) The impact analysis is not complete 

and does not sufficiently explain how 
it applies judgment criteria. It does 
not present in sufficient detail the 
relevant impacts in particular across 
different Member States 

(C) What to improve  

(1) The report should present a long-

term vision of what the Commission 
wants to achieve and over what 
timeframe. The report should 
elaborate how this initiative can be a 
stepping-stone towards a fully 
integrated system. Thus, it should 
better acknowledge the gradual 
approach to develop a single point of 
entry for all customs related 
procedures.   

(2) Within this framework, the report 
should provide a range of options 
that reflects the key political choices. 
It should be clearer on how the 
options were developed and what 
they comprise. The description of the 
options should include a better 
explanation of how centralising 
national databases fits in the options 
design. The report should analyse in 
more depth the discarded option for 
a single-entry point at EU level for all 
border formalities that appears to 
have strong stakeholder support and 
potential to meet the objectives of the 
initiative. 

(3) The baseline should better take into 

account what would happen if the EU 
does not act now. It should clearly 
outline how the current situation 
differs across Member States and 
what solutions Member States might 
implement on their own. The report 

(Analysis of the impacts of the policy options) 
provide an in-depth analysis of option 7, which 
is  assessed  at  the  same  level  of  detail  as  the 
other options retained for further analysis.  

Section  7  (How  do  the  options  compare?)  is 
revised to provide more detail on the judgment 
criteria for the comparison of the options. The 
impacts are further developed in more detail in 
section  6  (What  are  the  impacts  of  the  policy 
options?)  to  explain  the  differing  situations 
across  Member  States  relating  to  costs  and 
benefits.  

The  revised  introductory  section  addresses 
these points by further articulating the vision of 
what the Commission aims to achieve within a 
specific  timeframe  for  the  implementation  of 
the  EU  Single  Window  Environment  for 
customs.  

The  description  of  the  options  (section  5.3) 
explains  more  clearly  how  the  options  were 
developed  and  why  centralised  national 
databases have not been proposed as an option 
since 
their  potential  development  requires 
individual  assessments  of  each  regulatory 
formality  under  the  scope  of  option 2  in  line 
with the corresponding Union competences set 
out in the EU Treaties. Option 7 is analysed in 
depth,  in  terms  of  stakeholder  views,  direct 
economic  impacts,  social  and  environmental 
impacts and potential risks. 

Sections  2.5  and  2.6  of  the  initial  report  have 
been  consolidated  into  a  revised  section  2.5 
(How  will  the  problem  evolve?)  to  reflect  the 
logical  continuation  of  the  analysis  of  the 
consequences.  Section  5.2  (Ongoing  impacts 
without  any  further  EU  policy  action)  is 
substantially  reworked  to  better  reflect  the 

Page 73 / 237 

 
 
 
 
 
should better consider the potential 
impact of such solutions. 

evolution  of  the  current  situation  without 
additional  EU  intervention.  A  new  Annex  16 
was  added  focusing  on  individual  case  studies 
carried  out 
in  eight  EU  Member  States 
regarding the existing situation, economic costs 
and benefits, and other relevant impacts of the 
policy options. 

(4) The report should strengthen the 
impact analysis. Although it 
quantifies costs and benefits, it does 
not sufficiently account for varying 
impacts on different actors. It should 
be more transparent about the net 
benefits across Member States. It 
should expand on the support by 
member countries. It should point 
out how this goes beyond what 
participation in the trial phase 
suggests. The report should better 
explain the logic behind the analysis 
of cost savings. 

(5) The analysis should better assess 
social, environmental and SME 
impacts. The report needs to explore 
potential risks and uncertainties 
(operational or other) related to 
implementing each of the options. It 
should analyse the extent to which 
the preferred option is future proof.   

(6) When comparing options, the report 
should be more transparent how it 
takes into account the views of 
different categories of stakeholders. 
The report does not explain why 
some views are weighted more 
heavily. 

impacts  on 

Section  6.1  (Approach  to  the  analysis  of  the 
options)  has  been  revised  to  account  for 
varying 
the  different  actors 
involved.  EU-wide  figures  are  used  based  on 
plausible  ranges  with  regard  to  the  costs  and 
potential  benefits  that  could  be  expected. 
Section  6.1  also  provides  a  more  detailed 
analysis  of  impacts,  including  cost  savings  by 
ensuring  that  the  estimates  take  into  account 
the  differing  extent 
individual 
Member  States  would  be  affected  by  the 
initiative.  

to  which 

Sections  6.1  (Approach  to  the  analysis  of  the 
options) and 6.2 (Analysis of the impacts of the 
policy  options)  have  been  revised  to  further 
assess  the  social  and  environmental  benefits 
and  potential  implementation  risks  for  each 
option.  The  impacts  of  the  policy  options  on 
SMEs  are  addressed  in  section  6.1.  Section 
2.3.1  (Delays  and  inefficient  use  of  financial 
and 
the 
resources) 
consequences  of 
the  problem  for  SMEs, 
particularly  in  terms  of  the  disproportionate 
effects of current process redundancies on their 
participation in international trade. 

analyses 

human 

The  introduction  to  section  7  (How  do  the 
options  compare?)  is  revised  based  on  the 
compulsory  criteria  (efficiency,  effectiveness, 
coherence  and  proportionality)  outlined 
in 
tool#  12  of  the  Better  Regulation  Guidelines. 
The 
relies  on 
stakeholder input as a criterion for comparison. 

report  no 

revised 

longer 

2nd RSB Opinion - Recommendations 

Changes introduced in the revised version 

Page 74 / 237 

 
 
 
 
 
  
 
 
(B) Summary of findings 

(4) Given 

in 

the  approximations  and 
assumptions 
the  net  benefit 
analysis, the report is not sufficiently 
transparent  about 
the  potential 
uncertainties of the actual results. 

(5) The  comparison  section  does  not 
stakeholder 

integrate 

sufficiently 
views. 

Section  6.1  (Approach  to  the  analysis  of  the 
options)  further  explains  that  the  potential 
uncertainties  in  the  actual  results  are  attributed 
to  the  scarcity  of  concrete  data  that  could  be 
extrapolated  and 
levels  of 
complexity associated with clearance processes. 

the  varying 

Section  7  (How  so  the  options  compare)  has 
been  revised  to  integrate  the  views  of  the 
stakeholder  groups  on  the  expected  efficiency 
of the viable options. 

(C) What to improve  

(7) The report could better reflect the 

gradual approach of the initiative in 
the objectives. 

Section  4.2  (Specific  objectives)  has  been 
revised to  further explain that the objectives of 
the initiative will be achieved gradually over the 
course of the next decade.  

(8) Given the approximations and 
assumptions in the net benefit 
analysis, the report should be more 
transparent on the uncertainty of the 
results. The analysis should more 
explicitly assess the effect on SMEs 
across all relevant options. It should 
acknowledge that the benefits are 
unevenly distributed across Member 
States. The report could discuss the 
extent to which the combination of 
the preferred options are future 
proof. 

(9) The comparison section could 

integrate stakeholder groups’ views 
on the viability of the options into 
the assessment criteria. The 
effectiveness assessment should focus 
on specific objectives, instead of the 
general ones. The report could be 
clearer how the scale used to 
compare the options was applied. 

Source: DG TAXUD 

Evidence, sources and quality 

Section  6.1  (Approach  to  the  analysis  of  the 
options)  has  been  revised  to  explain  that  the 
uncertainty  in  the  results  of  the  expected  time 
savings  is  attributed  to  the  scarcity  of  concrete 
data that could be extrapolated and the varying 
levels  of  complexity  associated  with  clearance 
processes.  Section  6.1  further  assesses  the 
current  disproportionate  effects  on  SMEs, 
arguing 
in  administrative 
burdens triggered by the relevant options could 
be  expected  to  increase  their  participation  in 
international trade. Section 8 (Preferred option) 
addresses  the  reasons  why  the  combination  of 
the preferred options package is future proof. 

reductions 

that 

Section  7  (How  do  the  options  compare)  has 
been  revised  to  integrate  the  views  of  the 
stakeholder  groups  on  the  expected  efficiency 
of  the  viable  options  and  to  clarify  the  reasons 
for using the  general  objectives to  examine the 
effectiveness criteria. Further explanations have 
also  been  added  to  address  the  scores  for  each 
package of options and criterion. 

Evidence  was  gathered  from  existing  documentary  sources  including  legislation  and  other 
policy documents, customs and trade statistics, evaluations and reports on relevant policies, 

Page 75 / 237 

 
 
 
 
 
and  information  on  related  initiatives.  Particularly  relevant  were  the  following  pre-existing 
documents:  

  Evaluation of the electronic customs implementation in the EU120; 

  EU CSW-CVED and EU CSW-CERTEX pilot project documentation, including: 

  EU CSW-CVED guidelines 

  EU CSW-CERTEX business case121 

  EU CSW-CERTEX FLEGT guidelines  

  EU CSW-CERTEX COI guidelines 

  Evaluation and reports of various non-customs policies relevant to the initiative, such 

as: 

o  Report  of  the  Environmental  Investigation  Agency  on  illegal  trade  in 

hydrofluorocarbons122 

o  Evaluation of the ODS Regulation (DG CLIMA) 

o  Study  on  the  improvement  of  the  EU  system  of  export  authorisation,  and 
import and transit measures for civilian firearms, their parts and components 
and ammunition (DG HOME).  

o  Final report of the Forum pilot project on the control of PIC 

o  Final  report  data  and  information  collection  for  EU  dual-use  export  control 

policy review 

These  were  based  on  extensive  consultation  about  the  pre-existing  situation,  and  thereby 
provide evidence of the initiative’s underlying rationale.  

During the impact assessment project, the following additional evidence was gathered: 

a)  Consultation  of  the  EU  Customs  Single  Window  Project  Group  (the  project  group). 
This  included  five  written  questionnaires  (on  volumes  of  relevant  supporting 
documents; clearance processing times and costs; views to further develop option 6; 
experiences  with  EU  CSW-CVED  pilot;  and  a  follow-up  to  fill  gaps  from  previous 
consultations),  a  survey  on  the  feasibility  and  desirability  of  the  different  policy 
options,  and  the  results  of  discussions  taking  place  during  period  project  group 
meetings.  Important  challenges  and  constraints  were  encountered  in  evidence 
collection  resulting  from  an  extremely  complex  situation.  This  is  due  in  part  to  the 
need  to  consider  over  30  regulatory  requirements,  all  involving  specific  legislation, 
business  processes  and  stakeholders,  and  also  to  the  diversity  of  the  27  Member 
States, whose authorities have different starting points, IT architecture, priorities and 
cost  structures.  While  qualitative  data  on  experiences  and  expectations  is  ample, 
quantitative  data  is  scarce,  and  limited  to  a  small  proportion  of  Member  States  and 
relevant  regulatory  requirements.  In  many  cases,  stakeholders  were  unaware  of  the 
e.g. precise costs and amounts of time associated with dealing with given regulatory 

120   Evaluation  of 

the  electronic  customs 

implementation 

in 

the  EU  Final 

report 

(21 

January  2015), 

https://ec.europa.eu/taxation_customs/sites/taxation/files/docs/body/ecust_evaluation_final_en.pdf  

121   Business Case – EU Customs Single Window: Certificates exchange (December 2016) 
122   https://eia-international.org/wp-content/uploads/EIA-report-Doors-wide-open.pdf 

Page 76 / 237 

 
 
                                                 
requirements. For some national authorities, the data was considered too sensitive to 
share,  since  it  was  claimed  that  central  governments  would  reclaim  any  expected 
savings from a new initiative. 

b)  Four  B2G  use  cases:  To  obtain  the  necessary  insight  for  the  analysis  of  the  policy 
options on B2G collaboration, the project group decided to carry out a series of B2G 
use  cases  for  a  limited  number  of  regulatory  requirements  (CHED-A  and  CHED-D, 
FLEGT, Waste Shipment  formalities and FGAS). Member State customs authorities 
in  Spain,  Czechia  and  the  Netherlands  and  a  trade  association  (participating  in  the 
project group) respectively led these use cases, with the coordination of DG TAXUD 
and the collaboration of  the partner DGs. A pilot conducted between Spain  and DG 
SANTE to test the feasibility of option 6 supplements the use case on CHED-A and 
CHED-D certificates.  

c)  Field visits to eight Member States: To facilitate much of the detailed insight needed 
on the existing situation, costs, benefits and other likely impacts of the policy options, 
and  experiences  of  EU  CSW-CVED  so  far.  The  sample  included  Czechia,  France, 
Germany,  Ireland,  Italy,  the  Netherlands,  Romania  and  Spain.  Each  case  study  was 
comprised  of  10-15  mainly  face-to-face  interviews  with  customs,  partner  competent 
authorities  and  economic  operators,  and  a  review  of  relevant  documentation.  These 
largely  provided  the  desired  evidence,  though  it  was  difficult  to  obtain  quantitative 
data  on  some  aspects,  such  as  likely  implementation  costs  at  national  level  and 
amounts  of  time  spent  on  given  clearance  procedures.  Nonetheless,  the  case  study 
interviews  provided  the  information  needed  to  make  reasonable  assumptions  about 
these issues and thereby informed the quantitative estimations.   

d)  Commission officials working with various regulatory requirements in different DGs. 
Continuous  exchanges  of  expertise  and  best  practices  took  place  among  affected 
Commission DGs on dedicated topics to build up the internal expertise needed for this 
impact  assessment.  In  April  2018,  a  two-day  technical  workshop  was  held  in 
Washington  D.C.  between  U.S.  Customs  and  Border  Protection  officials  and 
representatives  from  DG  TAXUD,  DG  AGRI  and  DG  ENV  to  exchange  best 
practices  on  single  window  development  and  implementation.  The  results  of  these 
exchanges  were  regularly  discussed  and  validated  at  meetings  of  the  interservice 
steering  group.  This  coordinated  data  collection  and  analysis  approach  proved 
instructive in ensuring the overall quality of the impact assessment report.  

e)  Views  of  economic  operators  through  the  project  group  participating  trade 

associations, targeted interviews and the open public consultation. 

f)  Available  data  from  the  EU  CSW-CVED  pilot  on  the  volumes  of  declarations 
requiring  CED,  CVED-A  and  CVED-P  for  four  participating  countries  (Czechia, 
Estonia,  Ireland  and  Latvia)  were  combined  with  qualitative  information  to  make 
estimations  on  time  saved  for  different  stakeholders  in  the  assessment  of  the 
efficiency of the EU CSW CVED pilot. 

The following diagram illustrates the methods used to provide evidence for the preparation of 
the impact assessment. The triangulation of data sources collected from the consultation work 
strengthened the validity of the research. 

Page 77 / 237 

 
 
External expertise used for the impact assessment:  

The project group set up in December 2016 provided a framework for continuous exchanges 
among different experts in the field. This include customs policy and IT experts of Member 
States  customs  administrations,  professionals  from  the  trade  community  representing 
different business domains, specialists from partner competent authorities at EU and national 
level and representatives of the main international organisations related to international trade 
and experienced in single window facilitation tools (WCO, WTO and UNECE).  

In  addition,  DG  TAXUD  commissioned  an  external  study  to  evaluate  the  EU  CSW-CVED 
pilot and EU CSW-CERTEX and to support the impact assessment. The external study report 
was written by Oxford Research, Coffey, Economisti Associati and wedoIT and published in 
March 2020123. This impact assessment has been further supplemented by the ICT assessment 
of impacts derived from the initiative assigned to other external consulting services.  

123   https://tinyurl.com/ybbcbd42 

Page 78 / 237 

 
 
 
 
 
 
 
                                                 
ANNEX 2: STAKEHOLDER CONSULTATION  

Introduction  

This  synopsis  report  provides  a  summary  of  the  stakeholder  consultation  carried  out  in  the 
scope  of  the  impact  assessment.  In  serves  both  to  present  the  outcome  of  the  consultation 
activities and to show how the input has been taken into account.  

Given the many actors that would be affected by and involved in implementing the EU Single 
Window environment  for customs, stakeholder consultation  has from  the beginning formed 
an integral part of the policy development process. The consultation began in existing fora, 
and  was  formalised  in  the  consultation  strategy  developed  for  the  Inception  Impact 
Assessment published in May 2018124 and continued until late 2019. The consultation aimed 
to  provide  international  trade  stakeholders  and  the  wider  public  with  the  opportunity  to 
express their views on all relevant elements, as well as to gather specialised input on specific 
issues. The consultation responses have thus formed a vital part of the evidence base for the 
impact  assessment,  as  well  as  satisfying  transparency  principles  and  helping  to  define 
priorities for the future initiative.  

Consultation strategy  

The consultation strategy in the Inception Impact Assessment acknowledged the importance 
of feedback from both international trade stakeholders and the wider public. On this basis, it 
defined the groups to be consulted and stipulated that both a public consultation and targeted 
methods  would  be  carried  out.  Overall,  feedback  was  sought  from  and  collected  from  the 
following stakeholders:  

-  Member States’ customs authorities;  

-  Partner competent authorities (i.e. the Commission and Member States’ partner 

competent authorities or agencies) that rely on customs to control or implement their 
policies at the border. Among these are veterinary, sanitary, phytosanitary, agricultural 
and fisheries, environmental, pharmaceutical authorities, etc. 

-  Economic operators dealing with cross-border goods movement, both in terms of 

individual companies and as represented by national, European and/or international trade 
and business associations. They can be grouped according to their function for trade 
transactions:  

o  Manufacturers,  retailers  and  wholesalers  who  are  active  in  the  business  of 
purchasing  and/or  selling  goods,  particularly  those  subject  to  the  policies  of 
partner competent authorities;  

o  Importing / exporting businesses; 

o  Shipping  and  transport  companies  that  organise  and  take  care  of  the  physical 
movement  of  goods,  or  arrange  commercial  transportation  in  the  case  of  freight 
forwarders and logistics companies;  

o  Port and airport operators, terminal handlers, stevedores and warehouse operators, 

who are involved in the physical movement of goods; 

o  Customs  and  other  intermediaries,  who  are  involved  in  the  fulfilment  of 
procedures, including brokers and any businesses that provide a service to one or a 

124   https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-2382035 

Page 79 / 237 

 
 
                                                 
number  of  parties  in  the  supply  chain,  usually  in  form  of  data  processing  and 
information exchange; 

o  EU  businesses  compliant  with  EU  regulatory  requirements  that  are  affected  by 
distortion of competition due to the uneven enforcement of these requirements. 

- 

International  organisations  related  to  international  trade  and  customs,  such  as  UNECE, 
WCO and WTO;  

-  Other  interested  groups  such  as  academics/researchers,  professional  consultants  and 

interested citizens. 

In addition to the feedback on the Inception Impact Assessment and the public consultation, a 
range  of  targeted  methods  were  used.  These  preceded  the  direct  work  on  the  impact 
assessment  with  discussions  in  in  the  frame  of  the  related  EU  SW-CVED  and  EU  CSW-
CERTEX  projects,  and  existing  fora  such  as  the  Electronic  Customs  Coordination  Group 
(ECCG), the Trade Contact Group (TCG) and the Customs Business Group (CBG).  

A range of specific targeted activities were then carried out, many of which within or making 
use  of  the  project  group125  that  was  set  up  to  define  the  scope  of  the  EU  Customs  Single 
Window  and  to  elaborate  on  the  legal  and  policy  instruments  suitable  for  this  initiative. 
Consultation  in  this  forum  included  five  written  questionnaires,  a  survey  on  the  feasibility 
and  desirability  of  the  different  policy  options  and  the  results  of  discussions  taking  place 
during regular project group meetings and follow-up phone interviews.  

More detailed feedback and evidence was collected from a sample of eight Member States in 
the form of case study visits. These were each comprised of 10-15 interviews with customs 
authorities, partner competent authorities and individual businesses. Additional data was also 
collected at a High-Level Seminar hosted by the Romanian Presidency in May 2019 and a set 
of ‘use cases’ related to future B2G collaboration, as well as a number of general interviews 
with  stakeholders  from  different  groups  (national  members  of  trade  associations,  transport 
intermediaries, international organisations and various affected Commission DGs.  

Methodology and tools for processing the data 

The  consultation  activities  allowed  for  the  collection  data  of  both  a  qualitative  and 
quantitative  nature,  which  were  processed  and  analysed  systematically  using  appropriate 
techniques.  Qualitative  data  (including  interview  responses)  was  coded  according  to  key 
themes,  then  reviewed  and  analysed  from  different  angles  and  presented  in  narrative  form. 
Quantitative data (including survey responses and figures provided by stakeholders) was be 
processed  using  Excel,  and  analysed  using  statistical  methods  such  as  frequency  counts, 
cross-tabulations  and  simple  trends.  Results  were  presented  in  terms  of  tables,  charts  and 
graphs.  

Results of the public consultation activities 

Feedback on the Inception Impact Assessment  

The Inception Impact Assessment was published on 4 May 2018. Its purpose was to outline 
the  context  of  the  problem,  introduce  policy  options  for  targeted  EU  level  intervention,  the 
potential  impact  of  the  initiative  on  other  policy  areas,  and  the  main  features  of  the 
consultation strategy. Stakeholders were able to provide feedback until 1 June 2018.  

125   Customs  2020  Project  Group  to  study  a  possible  framework  to  develop  the  EU  Single  Window  environment  for 

customs (EU-SW) including the legal context.  

Page 80 / 237 

 
 
                                                 
Five  contributions  were  received  on  the  Inception  Impact  Assessment.  The  respondents 
shared concerns about the existing challenges and welcomed the initiative and its objectives. 
All  respondents  viewed  the  single  window  as  an  important  facilitation  measure  that  would 
keep  the  EU  economy  competitive  in  the  global  marketplace.  They  highlighted  that  the 
development of a new legal framework would encourage the mandatory participation of the 
Member  States  in  the  EU  Single  Window  environment  for  customs.  According  to  one 
respondent, entry and exit formalities should also be accommodated within a comprehensive 
customs single window framework. 

Public Consultation 

The public consultation was launched on 9 October 2018. It remained open until 17 January 
2019 for a total of just over 14 weeks (i.e. longer than the usual 12 weeks to take into account 
the winter holiday period). A questionnaire was available online in all official EU languages 
(except  Irish,  due  to  resource  constraints)  and  promoted  among  the  members  of  trade 
associations, relevant national authorities and other stakeholders. It consisted of 24 questions, 
divided  into  three  sections,  focused  on  respondents’  profiles,  experiences  with  cross-border 
operations,  and  opinion  on  potential  policy  measures.  Stakeholders  could  also  upload 
additional  contributions.  A  synopsis  of  the  consultation  has  been  published  on  the  Europa 
website126.  

The  consultation  showed  widespread  agreement  about  the  existence  and  seriousness  of  the 
problems as identified in the impact assessment and welcomed the possibility of EU action to 
address  these.  In  total,  371  valid  responses  were  received,  most  of  which  represented 
businesses127. 

Figure 9: Question #2.3 of the public consultation: Which of the following best describes you? 

Over 80% of respondents reported having direct involvement in customs operations, the vast 
majority of which expected significant benefits from an EU Single Window environment for 
customs.  Most  respondents  were  also  micro,  small,  or  medium  enterprises  (MSME).  Being 
disproportionately  affected  by  the  current  problems,  these  expected  large  gains  from  the 
streamlined  trade  compliance  that  would  come  from  the  new  initiative.  Small  enterprises 
were the largest segment of respondents, with 77 businesses, and five trade associations and 
organisations  belonging  to  the  group.  The  most  represented  Member  States  were  France, 

126    

https://ec.europa.eu/taxation_customs/sites/taxation/files/eu_sw_environment_4_customs_public_consultation_summar
y_report_en.pdf 

127   Ten double entries and empty responses were also received, but not retained for the analysis.   

Page 81 / 237 

 
 
 
                                                 
Germany, Italy, Spain, the UK, the Netherlands and Poland, while the most represented non-
EU countries were China and the United States.   

Between one fifth and one third of the businesses involved in the cross-border movement of 
goods  reported  that  their  customs  declarations  involve  CED,  CVED-A,  or  CVED-P 
certificates,  the  processes  for  which  would  be  among  the  first  to  improve  when  the  new 
initiative is implemented.  

Respondents highlighted key issues and challenges that currently affect negatively the work 
of  organisations  involved  in  the  cross-border  movement  of  goods  in  the  EU.  Most  notably 
these  issues  had  to  do  with  the  delays  in  customs  clearance,  continued  use  of  paper 
documents,  re-submission  of  the  same  information,  insufficient  support  from  authorities, 
differing  data  requirements  among  Member  States,  and  inappropriate  use  of  customs 
certificates,  all  of  which  would  be  addressed  in  the  proposed  initiative.  The  majority  of 
MSME and larger businesses confirmed that these issues translate into concrete problems in 
their  activities,  such  as  additional  operational  costs  for  training,  services,  reporting 
obligations,  etc.  Around  35  respondents  also  indicated  other  issues  affecting  cross-border 
operations, including a lack of coordination among authorities. 

Figure  10:  Question  #3.3  from  the  public  consultation:  To  what  extent  you  think  that  the  issues 
listed below negatively affect organisations involved in the cross-border movement of goods in the 
EU? 

Page 82 / 237 

 
 
 
 
Strong  support  was  expressed  for  further  EU  action  to  improve  the  trade  and  transport  of 
goods across borders. The potential objectives for a new initiative were considered important 
by over 90% of respondents.  

Figure  11:  Question  #4.1  from  the  public  consultation:  Possible  EU  action  to  improve  the  trade 
and transport of goods across borders is likely to focus on one or more of the following objectives. 
Please indicate how important each of these objectives is to you and your organisation. 

Page 83 / 237 

 
 
 
 
All  proposed  changes  triggered  by  new  EU  action  were  expected  to  have  very  positive 
impacts  on  business  operations,  particularly  on  the  reduction  of  administrative  burden,  the 
equal treatment of economic operators and the fight against fraudulent activities. 

Figure  12:  Question  #4.2  Compared  to  the  current  situation,  what  impacts  do  you  think  the 
following  changes  would  have  on  organisations’  operations  in  the  movement  of  goods  across 
borders? 

Page 84 / 237 

 
 
 
 
Figure 13: Question #4.3 […] Please indicate what kind of effects (positive or negative) you think 
that the changes mentioned in question 4.2 would have on the following:  

Other possible impacts of the proposed changes raised by some of the respondents, referred 
to aspects similar to those covered by Question 4.3 (particularly reduction in administrative 
burden, equal treatment of operators, and increased control thanks to enhanced fight against 
fraudulent activities). A couple of respondents pointed out that this may also translated in an 
increase in operators’ confidence in their ability to avoid mistake, and the related operators’ 

Page 85 / 237 

 
 
 
 
confidence in authorities. Finally, in another couple of cases, respondents pointed out that an 
EU action may have a negative on impacts on economic operators, particularly SME, in terms 
of costs to adapt to the changes. 

Results of the targeted consultation activities 
Project Group on the EU Customs Single Window128  

A  project  group  was  set  up  to  define  the  scope  of  the  EU  Customs  Single  Window  and 
elaborate the legal and policy instruments suitable for the initiative. Launched in December 
2016, the project group continued to meet regularly until June 2019, combining the expertise 
of customs and IT delegates from 19 Member States administrations and six representatives 
of trade associations.129 The project group provided a valuable forum for sharing experiences, 
carrying  out  the  preliminary  work  on  the  introduction  of  the  draft  legal  proposal,  and 
collecting  data  for  the  purposes  of  the  impact  assessment.  Its  activities  were  further 
augmented  by  promoting  the  participation  of  leading  experts  from  the  World  Customs 
Organisation  (WCO),  United  Nations  Economic  Commission  for  Europe  (UNECE),  World 
Trade Organisation (WTO) and academia. 

The project group held 13 regular meeting sessions during its duration. Ten of these meetings 
took  place  in  various  locations  across  the  EU  hosted  primarily  in  the  premises  of  national 
customs administrations. These onsite experiences allowed for knowledge sharing on a wide 
range of national initiatives on the single window from both a customs and IT perspective.  

Principally, the project  group analysed and discussed issues and trends related to the single 
window  concept  at  EU  and  national  level  to  assess  the  gap  between  the  current  situation 
faced  by  administrations  and  economic  operators  and  its  outlook  for  the  future.  Among  its 
deliverables, the project group collaborated closely to develop the problem definition and the 
policy objectives and policy options that were taken forward as part of the study to support 
impact assessment.   

Much  of  the  data  collection  for  the  impact  assessment  took  place  in  the  framework  of  the 
project  group. This  included five written questionnaires (on volumes of relevant  supporting 
documents;  clearance  processing  times  and  costs;  views  to  further  develop  option  6; 
experiences with EU SW-CVED; and a follow-up to fill gaps from previous consultations), a 
survey  on  the  feasibility  and  desirability  of  the  different  policy  options,  and  the  results  of 
discussions taking place during period project group meetings.  

A survey was also carried out to analyse the policy options defined for the impact assessment. 
Although preferences  about  the potential scope of a new initiative were diverse in  terms  of 
the  ambition  of  commitments  at  national  and  EU  levels,  both  the  Member  States  and  trade 
associations showed strong will for new EU action to improve the current situation.  

Among  its  key  findings,  the  survey  concluded  that  in  terms  of  the  political  and  technical 
feasibility  for  the  G2G  solutions,  Member  States  indicated  a  clear  preference  for  option  1 
focusing on regulatory requirements managed through EU electronic systems. Option 2 also 
received strong support from about half of the Member States. Among the responses related 
to the B2G exchanges, option 6 on interoperable national Customs Single Windows emerged 
as the favoured choice. Its flexibility was seen as a major advantage allowing Member States 

128  Customs 2020 Project Group to study a possible framework to develop the EU Single Window environment for customs 

(EU-SW) including the legal context.  

129  Representatives  of  industry  associations  engaged  in  regular  consultations  at  Union  level  through  the  Trade  Contact 

Group platform on the development and implementation of customs policy. 

Page 86 / 237 

 
 
                                                 
to pursue their own initiatives while benefiting from a degree of standardisation that would 
benefit  traders.  The  majority  of  trade  associations  believed  that  apart  from  the  baseline 
scenario, all the other options would to some extent make clearance processes smoother for 
their members.  

B2G use cases 

Consultation in the project group and early case study fieldwork showed that evidence on the 
policy options for B2G collaboration was especially hard to obtain. This was because there is 
no experience in this domain and the practical implications of these options had not yet been 
worked through in enough detail. To obtain the necessary insight, it was thus decided that the 
project group will carry out a series of B2G use cases to analyse the potential application of 
option 6 to a limited number of regulatory requirements. The use cases were led by Member 
State  customs  authorities  in  Czechia,  the  Netherlands  and  Spain  and  one  trade  association 
(participating  in  the  project  group),  with  the  coordination  of  DG  TAXUD  and  the 
collaboration of the partner DGs. They covered regulatory requirements for the import of live 
animals,  sustainable  and  legal  forest  management,  waste  shipment  and  fluorinated 
greenhouse  gases. The  B2G use cases showed the applicability  of this approach to  the first 
two formalities and the difficulties of its implementation in the context of the other two. In 
addition, a pilot is being conducted between Spain and DG SANTE to test the feasibility of 
the single-entry point concept for CHED-A certificates. 

Field visits in 8 MS 
Eight  country130  case studies  were carried out  between October 2018 and February 2019 to 
provide evidence for the impact assessment. By collecting and analysing data on the current 
situation and expected future developments, the case studies aimed to generate insight on the 
nature and scale of any existing problems and likely impacts of the policy options defined for 
the potential new initiative. The eight Member States were selected with a view to covering 
complementary  areas  of  interest  and  achieving  a  degree  of  representativeness  for  instance 
with regard to the types of border crossing.  

Each  case  study  consisted  of  10-15  interviews  with  customs  officials,  partner  competent 
authorities,  and  economic  operators  and  a  review  of  relevant  documents.  The  case  studies 
revealed  detailed  insight  on  the  existing  situation  and  experiences  with  the  EU  SW-CVED 
pilot project, costs, benefits and other likely impacts of the policy options. The research was 
narrowed  down  to  national  specificities  and  varied  according  to  geography,  trading  profile, 
administrative  set-up  and  participation  (or  not)  in  the  EU  SW-CVED  and  EU  CSW-
CERTEX).  Although  it  was  difficult  to  obtain  quantitative  data  on  certain  aspects,  such  as 
likely  implementation  costs  at  national  level  and amounts  of  time spent  on  given  clearance 
procedures,  the  case  study  interviews  provided  evidence  to  make  reasonable  assumptions 
about these issues.   

High Level Seminar on the EU Single Window environment for customs initiative 

The  EU  Romanian  Presidency  hosted  a  two-day  high-level  seminar  in  Bucharest  on  16-17 
May 2019 on the initiative related to the establishment of an EU Single Window environment 
for customs. This seminar was jointly organised with DG TAXUD with the participation of 
senior  management  officials  from  national  customs  administrations,  candidate  countries, 
representatives of trade associations and keynote speakers from the US Customs and Border 
Protection, UNECE, the World Bank and the EC DIGIT.  

130   Czechia, France, Germany, Ireland, Italy, the Netherlands, Romania and Spain. 

Page 87 / 237 

 
 
                                                 
The  objective  of  the  Seminar  was  to  present  and  discuss  with  the  senior  management  of 
national customs administrations and representatives of trade associations the policy options 
identified during the impact assessment exercise. A series of workshops were held to address 
the relevance of the policy options in the government-to-government (G2G) and business-to-
government  (B2G)  context,  with  informal  polls  conducted  to  gauge  support  for  different 
policy options. 

In view of the G2G cooperation, the meeting participants expressed strong, nearly unanimous 
support  for  the  establishment  of  a  legal  framework  to  govern  the  exchange  of  information 
between  customs  and  partner  competent  authorities,  particularly  as  it  relates  to  the 
verification of supporting documents to the customs declaration, hosted in EU systems. This 
layer of G2G cooperation is already running in parallel with the EU Customs Single Window 
Certificates Exchanges (EU CSW-CERTEX) pilot. The meeting participants expressed strong 
support for the development of a legal framework for the EU Single Window environment for 
Customs, which will legitimate the EU CSW-CERTEX and build on current initiatives.  

Support  was  also  provided with  preconditions  for the development  of a legal  framework to 
allow  the  interoperability  between  customs  and  national  certification  systems  for  EU 
supporting  documents  to  the  customs  declaration.131  However,  this  option  deserved  a  more 
detailed  analysis,  including  the  identification  of  the  list  of  procedures  and  certificates  in 
scope,  efficient  allocation  of  resources,  responsibilities,  timing  and  funding,  and  the 
establishment of benchmark measures for success.   

Most notably, national customs authorities expressed their views on viable policy options in 
an  informal  poll  taken  at  this  seminar.  The  poll  revealed  a  widespread  perception  that  the 
connections that would be facilitated by option 2 are important. On the other hand, while few 
respondents  were  not  enthusiastic  with  this  option,  most  offered  support  with  pre-
conditions132 as shown in the graph below.   

Figure 14: High-level seminar – support for option 2 (G2G) 

Source:  

Informal poll of participants (mainly from national customs authorities) at the High-level seminar on the EU 
Single Window environment for customs initiative 

Asked  whether  harmonised  single  access  points  at  national  level  would  be  desirable,  87% 
responded  either  ‘fully  desirable’  or  ‘quite  desirable’  as  demonstrated  in  the  graph  below. 
The reasons given for these responses corresponded to the envisaged benefits of the initiative, 

131   Pre-conditions included a need for more funding, voluntary implementation or a very long implementation timeframe. 
In addition, several respondents did not think Option 2 should be pursued until EU systems had been developed for the 
regulatory requirements covered, which de facto would mean incorporating Option 2 into Option 1. 

132   Pre-conditions included a need for more funding, voluntary implementation or a very long implementation timeframe. 
In addition, several respondents did not think Option 2 should be pursued until EU systems had been developed for the 
regulatory requirements covered, which de facto would mean incorporating Option 2 into Option 1. 

Page 88 / 237 

 
 
 
                                                 
including  cutting  costs,  increasing  efficiency,  simplification,  faster  clearance  and  release  of 
goods, better reuse of data, increased effectiveness of controls and better risk management.  

Figure 15: High-level seminar – support for option 6 (B2G) 

Source:  

Informal poll of participants (mainly from national customs authorities) at the High-level seminar on the EU 
Single Window environment for customs 

With  respect  to  the  B2G  interaction,  it  was  concluded  that  the  possibility  of  establishing 
harmonised  access  points  at  national  level  to  fulfil  customs  and  non-customs  formalities 
should be voluntary. Data harmonisation and standardisation were viewed as a fundamental 
precondition  for  providing  increased  benefits  for  trade  before  considering  the  mandatory 
application of this option. In addition, the meeting participants expressed strong agreement on 
the extension of the economic operator registration and identification (EORI) number to the 
formalities required by partner competent authorities for the international trade in goods.   

EDPS 

To  ensure  the  protection  of  personal  data  and  privacy,  the  Commission  consulted  the 
European Data Protection Supervisor on the processing of personal data within the EU Single 
Window environment for customs.  

Taking account of feedback received  

A concerted effort was made, particularly through discussions in the project group and High-
Level  Seminar  to  feed  back  on  the  ongoing  consultation  activities  and  to  ensure  that  the 
views and concerns of affected stakeholders were carefully considered throughout the impact 
assessment  exercise.  This  was  particularly  the  case  for  the  analysis  of  the  problem  and  the 
development and analysis of the policy options, where the arguments presented in the impact 
assessment are broadly in line with stakeholder views.  

Page 89 / 237 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

Practical implications of the initiative 

The practical implications are given by stakeholder group.  

Member States customs administrations 

Option 1 

This  option  would  lead  to  important  process  changes  that  would  save  significant 
time in the customs clearance. In broad terms, instead of needing to  ask economic 
operators  to  provide  physical  documents  to  support  customs  declarations,  the 
necessary documents would be delivered to customs IT systems (in the correct data 
format)  electronically  and  securely  from  the  respective  EU  electronic  system.  For 
the regulatory  requirements  covered by this  option, this would obviate the need to 
consult  paper documents  or external  systems,  introduce possibilities for automated 
verification and reduce reliance on manual documentary checks. The change would 
be especially pronounced for regulatory requirements where quantities of authorised 
goods can be split across multiple customs declarations. Verifying that ‘write-offs’ 
were  correct  currently  requires  time-consuming  checks  of  paper  documents  and 
interactions  with  partner  competent  authorities,  often  based  in  other  locations  or 
Member States. With the introduction of automated quantity management under this 
option,  the  verification  would  be  instantaneous  and  secure,  preventing  any  goods 
over the authorised quantity from being cleared. Moreover, having all information in 
electronic  form  makes  it  easier,  where  relevant,  to  coordinate  checks  with  partner 
competent authorities.  

Significant  human  resource  savings  are  expected  for  the  national  customs 
administrations.  The  automated  verification  of  supporting  documents  will  require 
less  human  resources  and  ultimately  expand  the  control  capacities  of  customs 
authorities. For standard cases (e.g. where the decision of the competent authority is 
favourable and there are no inconsistencies between the customs declaration and the 
supporting document) the documentary check can be fully automated, thus requiring 
no human intervention. As regards non-standard cases, the  initial  automated check 
will identify those to subsequently revert them to a customs officer, thus facilitating 
the  intelligent  allocation  of  human  resources.  Additionally,  given  the  24/7 
availability  of  the  automated  supporting  documents  verification  service,  the 
clearance of standard cases may happen even outside the working hours.  

Reduced  risk  of  receiving  falsified  supporting  documents,  as  customs  authorities 
would  receive  the  data  directly  from  the  partner  competent  authority  certification 
system.  

Option 6 

Data  simplification  and  harmonisation  between  customs  and  non-customs 
formalities and better alignment of procedures.   

The risk of fraud and the number of errors  could  be reduced because the data and 
documentation required would be sent just once to all the authorities involved.  

Improved  risk  management  steaming  from  increased  amount  of  electronic  data 
obtained from economic operators as part of the customs declaration and the easier 
data sharing among authorities. It could enable joint risk analysis if necessary.  

Option 8(ii)  This  would  allow  customs  and  partner  competent  authorities  to  exchange,  collect 
and  receive  information  about  economic  operators  more  easily,  facilitating  the 

Page 90 / 237 

 
 
implementation of option 1 and 6.   

Partner competent authorities 

Option 1 

Better enforcement and control of their policies. Quantity management at EU level 
would  in  particular  avoid  fraudulent  use  of  supporting  documents  over  the 
authorised  quantities.  The  automated  exchange  of  information  between  authorities 
would in addition eliminate to the risk of clearing goods under a falsified supporting 
document.  Moreover,  standardising  the  exchange  of  information  between  EU 
partner  competent  authorities  systems  and  national  customs  systems,  would  also 
bring  the  opportunity  to  harmonize  the  implementation  of  non-customs  legislation 
by national customs administrations across the EU.   

Processes would also be simplified and made more efficient for partner competent 
authorities.  Instead  of  needing  to  provide  validated  supporting  documents  to 
economic  operators  (who  then  take  them  onwards  to  customs  authorities),  this 
option  would  allow  electronic  versions  to  be  transferred  to  customs  authorities 
directly, in an automated way. This would reduce the time needed to document the 
results  of  checks,  as  well  as  making  it  easier  to  arrange  and  coordinate  controls 
efficiently.  

Option 6 

Data  simplification  and  harmonisation  between  customs  and  non-customs 
formalities and alignment of procedures.   

The risk of fraud and the number of errors  could  be reduced because the data and 
documentation required would be sent just once to all the authorities involved.  

Possibility  to  benefit  from  data  validation  performed  by  customs  according  to  the 
rules agreed in advance. 

Improved  risk  management  steaming  from  increased  amount  of  electronic  data 
obtained from economic operators as part of the customs declaration and the easier 
data sharing among authorities. It could enable joint risk analysis if necessary. 

Option 8(ii)  This  would  allow  customs  and  partner  competent  authorities  to  exchange,  collect 
and  receive  information  about  economic  operators  more  easily,  facilitating  the 
implementation of option 1 and 6.   

Economic Operators  

Option 1 

The  option  is  expected  to  generate  major  efficiency  gains  and  time  savings  in  the 
clearance  of  goods.  Instead  of  presenting  supporting  documents  in  paper  form  for 
the  customs  clearance,  transferring  them  physically  between  authorities,  economic 
operators  would  benefit  from  the  direct  automated  exchange  between  authorities 
through  this  G2G  connection.  This  also  means  that  application  for  supporting 
documents  and  customs  declarations  could  be  lodged  in  parallel,  simplifying 
business processes and reducing delays, while speeding up processing. In addition, 
customs  authorities  would,  in  the  majority  of  the  cases,  be  able  to  verify  the 
supporting  documents  in  an  automated  way,  thus  reducing  time  and  resources 
needed  by  economic  operators  to  attend  documentary  controls.  Given  the  24/7 

Page 91 / 237 

 
 
 
 
availability  of  the  automated  supporting  documents  verification  service,  the 
clearance of standard cases may happen even outside the working hours.  

Moreover,  the  G2G  information  exchange  could  also  led  to  coordinated  checks 
between  customs  and  partner  competent  authorities,  avoiding  the  movement  of 
containers at cost to the economic operators that previously took place. 

Finally,  this  option  would  enable  a  harmonised  implementation  of  non-customs 
legislation  by  national  customs  administrations  by  standardizing  the  exchange  of 
information between authorities. It would play a role in furthering the single market, 
eliminating possibilities for distorted competition.  

This  is  essentially  a  trade  facilitation  tool  that  would  provide  economic  operators 
with  a  single  point  of  entry  for  the  submission  of  customs  and  non-customs 
information.  This  solution  would  simplify  clearance  procedures  and  address  key 
problems such as the need to submit similar information to multiple authorities for 
the  same  movements.  Instead  of  needing  to  submit  data  to  different  authorities  at 
different  times,  and  in  different  formats,  this  option  would  rationalise  the  process, 
allowing  customs  and  non-customs  data  to  be  submitted  together.  This  would 
eliminate  data  redundancies  and  enable  easier  monitoring  of  the  status  of  requests 
and  automated  verification  of  documents  related  to  a  number  of  regulatory 
requirements.  

Option 6 

Option 8(ii)  This  would  allow  customs  and  partner  competent  authorities  to  exchange,  collect 
and receive information about economic operators more easily, with the purpose of 
reducing  the  administrative  burden  on  economic  operators  and  facilitating  the 
implementation of option 1 and 6. 

Citizens  

Option 1 

The envisaged social  and environmental impacts of this option are very important. 
These  would  be  felt  first  by  customs  and  partner  competent  authorities,  whose 
ability to work effectively would be improved. Ultimately, citizens will benefit from 
a  better  compliance  and  enforcement  of  non-customs  EU  regulatory  requirements. 
An efficient exchange of information and integration of procedures would allow for 
the  early  detection  of  fraudulent  activities  This  would  have  positive  impacts  on 
protecting  public  health  and  safety;  enhancing  security;  preserving  the  cultural 
heritage and protecting animal welfare and the environment.  

Option 6 

The  simplification  of  regulatory  requirements,  the  decrease  of  clearance  time  and 
the  resources  needed  to  deal  with  them,  may  ultimately  benefit  citizens  as  lower 
costs may be transferred to them in the form of lower prices.  

The  improved  cooperation  and  coordination  between  authorities,  better  risk 
management,  reduced  fraud  and  errors  and  better  compliance  and  enforcement  of 
EU policies in the scope of this initiative would indirectly lead to a better protection 
of the citizens and the environment.   

Option 8(ii)  N/A 

Page 92 / 237 

 
 
 
 
64.73  
64.38  
127.73  
129.11  
192.46  
212.87  
336.89  
25.91  
64.77  
494.10  
688.41  
732.88  
1 090.08  
540.42  
960.97  
3.81  
8.40  
6.35  
5.91  
11.75  
12.26  
18.10  
60.82  
96.25  
7.40  
18.51  
141.17  
196.69  
209.39  
311.45  
191.29  
299.19  
11.57  
25.40  

Summary of costs and benefits for the preferred option package 

Preferred option: package of options 1+6+8(ii)  
Total 
gradual 
for 
implementation years 1-
7 

Costs  
(-€m, 
except for EC costs) 

low  and  high  ranges 

European Commission 
Member 
authorities 
Total 

State 

Benefits  (€m,  low  and  high 
ranges) 

Member State customs  

Member  State  Partner 
Competent authorities 
Economic operators  

Total 

Net impact (€m, low and high ranges) 

EUR benefits per EUR spent, low and high ranges 

Annual  total  once  fully 
operational, from year 8 
onwards 

Costs  
(-€m, 
except for EC costs) 

low  and  high  ranges 

EC 
MS authorities 

Total 

Benefits  (€m,  low  and  high 
ranges) 

Member State customs  

Member  State  Partner 
Competent authorities 
Economic operators  

Total 

Net impact (€m) 

EUR benefits per EUR spent, low and high ranges 

Page 93 / 237 

 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

The impact assessment is based on the triangulation of evidence from a wide range of sources 
which  has  been  analysed  using  the  usual  methods  for  social  and  economic  research.  While 
more  advanced  methods,  such  as  econometric  modelling,  were  considered,  these  were 
deemed unsuitable due to the expected limited scale of second-order effects on international 
trade. 

The methods used are described in detail in various parts of this document as follows: 

  Standard  cost  model:  this  was  used  to  analyse  the  direct  economic  impacts  of  the 

policy options, as described in section 6 of the main report.  

  Stakeholder  consultation:  extensive  public  and  targeted  consultation  activities  were 
carried  out,  with  the  data  analysed  in  different  ways  and  fed  into  the  impact 
assessment.  The  activities  and  analytical  methods  are  described  in  Annex  2: 
Stakeholder consultation.  

 

  Evaluation of EU SW-CVED and EU CSW-CERTEX: as described in Annex 14, the 
evaluation  was  based  on  the  triangulation  of  evidence  from  several  desk  research 
sources and stakeholder consultation.  
ICT assessment: the extensive stakeholder consultation showed that the impact of this 
initiative  must  be  also  assessed  from  an  IT  perspective  within  the  G2G  and  B2G 
areas. For this reason, DG TAXUD commissioned an external contractor to assess the 
relevant  ICT  impacts  derived  from  the  implementation  of  the  viable  policy  options. 
As  described  in  Annex  15,  the  report  analyses  in  detail  the  IT  requirements  and 
implications  for  each  viable  policy  option,  focusing  on  three  main  IT  project 
management  domains:  project  timeline  and  integration,  governance  and  operations 
and system architecture. 

Page 94 / 237 

 
 
 
 
ANNEX 5: ACRONYMS  

Acronym 

Explanation 

AGREX 

AGRIM 

AACE 

ACE 

APEC 

ASEAN 

B2G 

CBP 

CBSA 

CCFV 

CED 

CEFIC 

CHED 

CHED-A 

CHED-D 

CHED-P 

CHED-PP 

CITES 

CLECAT 

COI 

CVED 

CVED-A 

CVED-P 

DG 

DG AGRI 

DG CLIMA 

DG ENV 

DG GROW 

DG HOME 

DG MARE 

DG MOVE 

DG SANTE 

DG TAXUD 

DG TRADE 

EC 

ECHA 

ECOFIN 

EDI 

EDIFACT 

eDUES 

Agriculture Export Licence 

Agriculture Import Licence 

African Alliance for e-Commerce 

Automated Commercial Environment (U.S.)   

Asia-Pacific Economic Cooperation 

Association of Southeast Asian Nations 

Business-to-Government cooperation 

U.S. Customs and Border Protection 

Canada Border Services Agency 

Certificate of conformity for fruits and vegetables 

Common Entry Document for Feed and Food of non-Animal Origin  

European Chemical Industry Council 

Common Health Entry Document for Plants, Plant Products and Plant Propagation 
Material, Products of Animal Origin and Live Animals 

Common Health Entry Document for Animals  

Common Health Entry Document for Feed and Food of Non-Animal Origin 

Common Health Entry Document for Animal Products 

Common Health Entry Document for Plants and Plant Products 

Convention on International Trade in Endangered Species of Wild Fauna and Flora 

European Association for Forwarding, Transport, Logistics and Customs Services 

Certificate  of Inspection (for import of products from organic production into the 
European Union) 

Common Veterinary Entry Document 

Common Veterinary Entry Document for Animals 

Common Veterinary Entry Document for Products of Animal Origin 

Directorate-General 

Directorate-General for Agriculture and Rural Development  

Directorate-General for Climate Action 

Directorate-General for Environment  

Directorate-General for Internal Market, Industry, Entrepreneurship and Small and 
Medium-sized Enterprises  

Directorate-General for Migration and Home Affairs 

Directorate-General Maritime Affairs and Fisheries 

Directorate-General for Mobility and Transport 

Directorate-General for Health and Food Safety 

Directorate-General for Taxation and Customs Union 

Directorate-General for Trade 

European Commission 

European Chemicals Agency 

Economic and Financial Affairs Council, responsible for EU policy in three main 
areas: economic policy, taxation  issues and the regulation of financial services 

Electronic data interchange 

Electronic Data Interchange For Administration, Commerce and Transport 

Electronic Dual Use Export Authorisation System 

Page 95 / 237 

 
 
eIDAS 

ePIC 

EU 

Electronic Identification, Authentication and trust Services 

IT system for Prior Informed Consent (PIC) 

European Union 

EU-CSW 

EU Customs Single Window 

EU CSW-CERTEX 

EU Customs Single Window CERTificates EXchange 

EU CSW-CVED 

EU Customs Single Window – Common Veterinary Entry Document 

EORI 

FGAS 

FLEGT 

FTE 

G2G 

HFCs 

IAS 

Economic Operator Registration and Identification  

Fluorinated greenhouse gases  

Forest Law Enforcement, Governance and Trade 

Full-time employee 

Government-to-Government cooperation 

Hydrofluorocarbons 

Invasive Alien Species 

ICEGATE 

Indian Customs Electronic Commerce Gateway 

ICS 

ICS2 

ICSMS 

ICT 

IID 

Import Control System  

Import Control System 2 

Information and Communication System for Market Surveillance 

Information and Communication Technology 

Integrated Import Declaration 

IUU Catch 

Illegal, Unreported and Unregulated fishing regulation, Catch certificate 

IPCSA 

IT 

ITDS 

KPCS 

MASP-C 

MRN 

MS 

MSME  

NGO 

NCTS 

NMSWs 

ODS 

PCA 

PCS 

PGA 

PDF 

 PD-NEA 

PIC 

RAMMAP 

REACH 

REX 

RIN 

SME 

SPEED 

SWIFT 

SWIM 

International Port Community System Association 

Information Technology 

International Trade Data System (U.S.) 

Kimberley Process Certification Scheme 

Multi-Annual Strategic Plan for Customs 

Movement Reference Number 

Member State 

Micro, Small, or Medium Enterprises  

Non-Governmental Organisation 

New Computerised Transit System 

National Maritime Single Window(s) 

Ozone-Depleting Substances 

Partner Competent Authority  

Port Community System 

Partner Government Agency (U.S.) 

Portable Document Format 

Portal Dashboard for National Enforcement Authorities 

Prior Informed Consent 

Reform and Modernization-Monitoring Activities and Projects 

Registration, Evaluation, Authorisation and Restriction of Chemicals 

Registered Exporters System 

Reference Identification Number 

Small and Medium Enterprises 

Single Portal for Entry or Exit of Data 

Indian Single Window Interface for Facilitation of Trade 

Single Window Interactive Map 

Page 96 / 237 

 
 
TARIC 

TFA 

TFEU 

TRACES 

TRACES NT 

UCC 

UN 

TARif  Intégré  Communautaire,  Integrated  Tariff  of  the  European  Union, 
multilingual  database  integrating  all  measures  relating  to  EU  customs  tariff, 
commercial and agricultural legislation 

Trade Facilitation Agreement 

Treaty on the Functioning of the European Union  

TRAde Control and Expert System 

TRAde Control and Expert System New Technology 

The Union Customs Code 

United Nations 

UN/CEFACT 

United Nations Centre for Trade Facilitation and Electronic Business 

UNECE 

UUM&DS 

VAT 

WCO 

WTO 

XML 

United Nations Economic Commission for Europe 

Uniform User Management & Digital Signatures 

Value Added Tax 

World Customs Organisation 

World Trade Organisation 

Extensible Markup Language 

Page 97 / 237 

 
 
 
 
 
ANNEX 6: GLOSSARY 

Term  

APEC 

ASEAN 

Business to 
Government (B2G) 
Centralised Clearance 

Certificate of origin 

Definition 
Asia-Pacific Economic Cooperation. A forum established as a vehicle 
for  multilateral  cooperation  among  the  market-oriented  economies  of 
the region to better manage their growing interdependence and sustain 
economic growth. Begun in 1989 as an informal grouping of 12 Asia-
Pacific economies (Australia, Brunei, Canada, Indonesia, Japan, South 
Korea,  Malaysia,  New  Zealand,  Philippines,  Singapore,  Thailand  and 
the  United  States),  APEC  admitted  the  People's  Republic  of  China, 
Chinese  Taipei  and  Hong  Kong  in  1991,  Mexico  and  Papua  New 
Guinea in 1993, Chile in 1994, and Peru, Russia and Vietnam in 1998.  
Association  of  Southeast Asian  Nations.  A  geopolitical and  economic 
organisation  of  ten  Southeast  Asian  Countries.  Formed  in  1967  by 
Indonesia,  Malaysia,  the  Philippines,  Singapore  and  Thailand  and 
include  Brunei,  Burma  (Myanmar), 
subsequently  expanded 
Cambodia, Laos and Vietnam.   
The  electronic  sharing  of  data  and/or  information  systems  between 
businesses and government agencies, departments or organizations. 
Simplification that allows economic operators to declare goods in one 
Member  State  (Supervising  Customs  Office)  and  present  them  in  a 
different  Member  State  (Presentation  Customs  Office).  This  allows 
economic  operators  to  centralise  the  accounting  and  payment  of 
customs  duties  for  all  their  customs  transactions  in  the  Supervising 
Customs Office. 
A  specific  document  identifying  the  goods,  in  which  the  authority  or 
body empowered to issue it certifies expressly that the goods to which 
the certificate relates originate in a specific country.  

to 

Competitive advantage  An attribute that allows a company to outperform its competitors.  
Consortium 

Cost-benefit analysis 

Customs authorities 

Customs controls 

Customs declaration 

An  agreement  or  individuals  or  companies  who  join  together  for  a 
common purpose. 
A  systematic  approach  to  estimating  the  strengths  and  weaknesses  of 
alternatives used to determine options which provide the best approach 
to achieving benefits while preserving savings. 
Customs administrations of the Member States responsible for applying 
the  customs  legislation  and  any  other  authorities  empowered  under 
national law to apply certain customs legislation (as defined in Article 
5(1) of Regulation (EU) 952/2013).  
Specific  acts  performed  by  the  customs  authorities  in  order  to  ensure 
compliance with the customs legislation and other legislation governing 
the entry, exit, transit, movement, storage and end-use of goods moved 
between the customs territory of the Union and countries or territories 
outside  that  territory,  and  the  presence  and  movement  within  the 
customs  territory  of  the  Union  of  non-Union  goods  and  goods  placed 
under the end-use procedure (as defined in Article 5(3) of Regulation 
(EU) 952/2013). 
The  act  whereby  a  person  indicates,  in  the  prescribed  form  and 
manner, a wish to place goods under a given customs procedure, with 

Page 98 / 237 

 
 
Customs formalities 

Customs fraud 

Customs legislation 

Customs procedure 

Customs Union 

an  indication,  where  appropriate,  of  any  specific  arrangements  to  be 
applied (as defined in Article 5(12) of Regulation (EU) 952/2013). 
All  operations  carried  out  by  an  economic  operator  or  customs 
authorities to comply with customs legislation. 
Any act, which a person deceives, or attempts to deceive, the customs 
and thus evades, or attempts to evade, wholly or partly, the payment of 
import or export duties and taxes or the application of prohibitions or 
restrictions  laid  down  by  the  regulatory  provisions  enforced  or 
administered by the customs administrations. 
The body of legislation made up of all of the following:  
(a)  the  Code  and  the  provisions  supplementing  or  implementing  it 
adopted at Union or national level;  
(b) the Common Customs Tariff;  
(c)  the  legislation  setting  up  a  Union  system  of  reliefs  from  customs 
duty;  
(d)  international  agreements  containing  customs  provisions, insofar  as 
they  are  applicable  in  the  Union  (as  defined  in  Article  5(2)  of 
Regulation (EU) 952/2013). 
Any of the procedures (release for free circulation, special procedures, 
export)  under  which  goods  may  be  placed  in  accordance  with  the 
Union Customs Code. 
The merger of two or more customs territories with the effect that (Art. 
XXIV GATT and Art. 23 EC Treaty) 
 

customs duties and non-tariff barriers are eliminated between the 
members of the union for substantially all trade, and 
a common customs tariff and common rules for non-tariff barriers 
are introduced for substantially all trade with non-member 
countries. 

 

Data model 

Data transformation 

Digitalisation 

ECOFIN 

Economic operator 

Economies of scale 

Export 

Exclusive competence 

The  process  of  defining  how  the  logical  structure  of  a  database  is 
modelled,  using  text  and  symbols  to  represent  the  way data needs  to 
flow. 
The process of converting the format of non-customs data into customs 
declaration  compatible  data  and  vice  versa  without  changing  their 
content. 
The  method,  practice,  or  process  of  converting  (usually  analog) 
information into a digital form, which is computer-readable. 
The  Council  configuration  on  Economic  and  Financial  Affairs 
composed of the Ministers (or State Secretaries) of Economic Affairs 
of the Member States of the EU. 
A  person  who,  in  the  course  of  his  or  her  business,  is  involved  in 
activities  covered  by  the  customs  legislation  (as  defined  in  Article 
5(5) of Regulation (EU) 952/2013). 
A  proportionate  saving  in  costs  gained  by  an  increased  level  of 
production. 
The  customs  procedure  for  taking  Union  goods  out  of  the  customs 
territory of the Union (as defined in Article 269 of Regulation (EU) 
952/2013).  
Areas in which the EU alone is able to legislate and adopt binding acts 

Page 99 / 237 

 
 
Government to 
government (G2G) 

Impact assessment 

Import 

Improved compliance 

Kigali  Amendment  to 
the Montreal Protocol 

Labour costs 

Level playing field 

Multi-Annual  Strategic 
Plan 
Customs 
for 
(MASP-C) 
One-off cost 
One-stop shop 

Partner competent 
authority  

(Article  3  of  the  Treaty  on  the  Functioning  of  the  European  Union  - 
TFEU). 
The  electronic  sharing  of  data  and/or  information  systems  between 
government  agencies,  departments  or  organizations  to  facilitate 
increased efficiency. 
The  formal,  evidence-based  procedures  that  assess  the  economic, 
social, and environmental effects of public policy. 
The act of bringing or causing any goods to be brought into a Customs 
territory. 
The principle of seeking to continually improve the level of voluntary 
compliance with customs legislation. 
An  international  agreement  to  gradually  reduce  the  consumption  and 
production of hydrofluorocarbons (HFCs). The amendment was agreed 
upon  at  the  twenty-eighth  Meeting  of  the  Parties  to  the  Montreal 
Protocol held on October 15, 2016, in Kigali. 
Sum of all wages paid to employees, as well as the cost of employee 
benefits and payroll taxes paid by an employer. 
A  set  of  common  rules  and  standards  that  prevent  businesses  in  one 
Member  State  undercutting  their  rivals  and  gaining  a  competitive 
advantage over those operating in other Member States. 
Overall  project  management tool  prepared  by  the  EU  Commission in 
partnership  with  Member  States  to  ensure  operational  planning  and 
implementation of all e-Customs IT projects. 
A cost that is paid once and not repeated. 
Set  of  services  provided  by  customs  authorities  in  close  cooperation 
with  partner  competent  authorities  whereby  in  respect  of  the  same 
goods,  customs  and  non-customs  controls  are  performed  at  the  same 
time  and  place,  as  referred  to  in  Article  47  of  Regulation  (EU) 
952/2013. 
Any  Member  State  authority  or  Commission  services  that  have  the 
legally delegated power to perform a designated function in relation to 
the fulfilment of the relevant Union non-customs formalities. 

Phased implementation  A process of transition from an existing system to a new one that takes 

Phytosanitary 

Port shopping 

Prohibitions and 
restrictions 

Proportionality 
principle 

place in stages. 
Relating  to  the  health  of  plants,  especially  with  respect  to  the 
requirements of international trade. 
The  practice  of  exporters  and  importers  choosing  a  particular  port 
based  on  their  assessment  of  customs'  treatment,  rather  than  on  the 
quality of physical facilities and efficiency. 
A limited range of goods prohibited or restricted at import and export, 
including live or dead animals or plants, foodstuff, illegal or dangerous 
goods, products of endangered species, protected items of international 
heritage, firearms, weapons or explosives, medicines, etc. 
Principle that regulates the exercise of powers by the EU and seeks to 
set actions taken by EU institutions within specified bounds to what is 
necessary to achieve the objectives of the Treaties (Article 5(4) of the 
Treaty on European Union). 

Page 100 / 237 

 
 
Risk 

Quota 

Recurrent costs 

Release of goods 

Risk management 

Sectorial legislation 

Quantity management 

The  activity  of  monitoring  and  managing  the  quantity  of  goods 
authorised by partner competent authorities in accordance with Union 
non-customs legislation based on the information provided by customs 
authorities on the clearance of related consignments. 
Any  pre-set  quantity,  authorised  for  importation  or  exportation  of 
given  goods,  during  a  specified  period,  beyond  which  no  additional 
quantity of these goods can be imported or exported. (WCO) 
The  costs  of  maintaining  and  operating  a  given  programme  once  the 
initial, one-off investment has been completed. 
Act  whereby  the  customs  authorities  make  goods  available  for  the 
purposes  specified  for  the  customs  procedure  under  which  they  are 
placed (as defined in Article 5(26) of Regulation (EU) 952/2013).  
The  chance  of  something  happening  that  will  have  an  impact  on 
customs  objectives,  including  potential  non-compliance  with customs 
laws and failure to facilitate trade. 
Systematic  identification  of  risk,  including  through  random  checks, 
and  the  implementation  of  all  measures  necessary  for  limiting 
exposure  to  risk  (as  defined  in  Article  5(25)  of  Regulation  (EU) 
952/2013). 
Body of legislation aiming at the protection of health, safety, security, 
environment, cultural goods or imposing sanctions in the framework of 
the  Common  Foreign  and  Security  Policy  (CFSP)  affecting  the 
international movement of goods. 
A  facility  that  allows  parties  involved  in trade  and transport to lodge 
standardized  information  and  documents  with  a  single-entry  point  to 
fulfill  all  import,  export,  and  transit-related  regulatory  requirements 
(UNECE Recommendation No 33).  
A  method  for  assessing  administrative  costs  imposed  by  a  regulation 
on,  among  other  things,  businesses  and  public  administrations.  It  is 
based on the identification of information obligations whose costs for 
the regulatory addressees can be measured and quantified. Impact can 
be calculated by comparing the total costs under the baseline scenario 
with costs under a new intervention.  
In  areas  in  which  the  European  Union  does  not  have  exclusive 
competence,  the  principle  of  subsidiarity  means  that  the  Union  is 
justified  in  exercising  its  powers  when  Member  States  are  unable  to 
achieve  the  objectives  of  a  proposed  action  satisfactorily  and  added 
value  can  be  provided  if  the  action  is  carried  out  at  Union  level 
(Article 5(3) of the Treaty on European Union).  
A  logistical  management  system  that  integrates  the  sequence  of 
activities  from  delivery  of  raw  materials  to  delivery  of  the  finished 
product into measurable components.  
Certificates,  attestations,  licences  and  permits  issued  by  partner 
competent  authorities  to  certify  the  fulfilment  of  Union  non-customs 
formalities. 
A comprehensive list of EU customs key terms is available at:  
https://ec.europa.eu/taxation_customs/glossary_en#heading_1 

Principle of 
subsidiarity 

Supporting documents 

Standard cost model 

Single window 

Supply chain 

Page 101 / 237 

 
 
 
 
ANNEX 7: OVERALL VOLUMES OF EU SUPPORTING DOCUMENTS 

Overall volumes of EU supporting documents where data were available  

EU supporting document   

Common Entry Document (CED) 

Overall  volumes  and,  where  available,  trends  in 
last few years based on partner DG estimates 

The  number  of  CED  increased  by  over  20%,  from 
around 180 000 in 2015 and 2016 to over 220 000 in 
2017133.  Spain  alone  was  the  destination  of  over 
40%  of  all  CEDs  and  experienced  a  nearly  50% 
increase between 2015 and 2017.  

Common 
Document: 
(CVED-P) 

Veterinary 
Animal 

Entry 
Products 

Common 
Entry 
Document: Live Animals (CVED-A) 

Veterinary 

Import Catch Certificates (CC) 

The  number  of  CVED-P  issued  increased  by  10% 
between  2015  and  2017,  from  about  340 000  to 
nearly 380 000 per year134. There is a high degree of 
concentration  in  terms  of  destination  countries, 
which  remained  stable  over  the  three  years  under 
consideration. Cumulatively, the three top  countries 
are the destination of more than half of all CVED-P 
in  all  three  years  (Germany,  Spain  and  Italy),  and 
the  share 
the 
Netherlands and France. 

to  around  80%  with 

increases 

An  average  47 000  CVED-A  were  issued  per  year, 
with  a  4%  increase  between  2015  and  2017. 
Cumulatively,  the  top  three  Member  States  include 
over  half  of  all  CVED-A  (UK,  Germany,  and 
France).  Once  Italy,  the  Netherlands,  and  Spain  are 
added, the share increases to 75%. While the overall 
share  did  not  change  significantly  over  the  three 
years,  some  of  the  "smallest"  destination  countries 
did  experience  changes,  with  Finland  tripling  the 
number of CVED-A between 2015 and 2017, while 
Latvia halved it for example.135 

The  28136  Member  States  registered  nearly  580 000 
import  Catch  Certificates  (CCs)  in  2014-2015,  or 
about  290 000  per  year  (no 
trend  data  were 
available).  Spain  alone  accounted  for  nearly  one 
fifth  of  all  import CCs. Cumulatively,  the  three  top 
countries represented nearly 50% of all import CCs 
over  the  period  considered  (Spain,  Germany  and 

133   It should be noted that these figures underestimate the true total to a certain extent, since not all Member States have 

used the EU system TRACES to process and store CEDs.  

134   Bulgaria and the UK not included. 
135   Croatia, Estonia and Sweden not included. 
136   These findings are based on 28 Member States.  

Page 102 / 237 

 
 
                                                 
France). 

2 433 ODS licences had been issued to companies as 
of 2018. Since 660 annual licences could be used for 
multiple  shipments,  however, 
the  number  of 
shipments  per  year  was  estimated  to  be  around 
16 000. 809 companies were registered. 

1 699  companies  had  reported  on  their  fluorinated 
greenhouse  gases  or  F-gas  activity  (production, 
import,  export  and  destruction  of  F-gases)  during 
2017  (33%  more  than  in  the  previous  year). 
Companies  are  distributed  across  all  EU  Member 
States,  the  largest  numbers  are  located  in  Poland, 
Italy,  Germany,  France,  the  United  Kingdom  and 
Spain. 

8 787 export notifications have been issued in 2019. 
This  represents  a  55%  increase  since  2015.  The 
largest  number  of  export  notifications  come  from 
Germany,  France,  Spain,  Italy,  Belgium  and  the 
United Kingdom.  

More  than  22 000  substances  are  registered  under 
REACH.  Registration  requirements  for  chemical 
substances produced or imported in  volumes  higher 
than  one  tonne  per  year  were  finalised  in  2018. 
Nearly  97 000  registration  files  were  submitted  to 
European  Chemicals  Agency  by  more  than  15 000 
companies. 

Ozone-Depleting 
licences (ODS) 

Substances 

Reporting on F-gas activity137 

Export  notifications  of  hazardous 
chemicals138 

REACH 

Source: Extrapolations based on partner DGs 

137   Data reported by companies on the production, import, export and destruction of fluorinated greenhouse gases (F-gases) 
in the European Union is published by the European Environment Agency. The latest report evaluates and presents the 
data reported by companies in 2018 about their activities involving F-gases in 2017. Available here.  

138   Data on annual export notifications is published by the European Chemicals Agency (ECHA). 

Page 103 / 237 

 
 
 
 
 
                                                 
ANNEX 8: CATEGORISATION OF REGULATORY FORMALITIES  

The non-customs regulatory formalities can be grouped into several categories, depending on 
whether  they  relate  to  EU  or  national  legislation  and  whether  the  information  required  is 
available nationally or at EU level. In some cases, where a third-country authority issues the 
supporting  documents,  the  information  is  unavailable  at  both  EU  and  national  levels.  The 
existing regulatory formalities can therefore be categorised in four groups: 

a)  Category 1: EU regulatory requirements set out in EU legislation for which the customs-
relevant information is available or planned to be made available for all Member States at 
EU level.  

Regulatory 
requirement(s)  

Description 

Owner 
legislation 

of 

EU Systems 

CHED-A 

CHED-P 

CHED-D 

CHED-PP 

COI 

FLEGT 

ODS 

FGAS 

Common  Health  Entry  Document 
Animals 

for 

DG SANTE 

TRACES NT 

Common  Health  Entry  Document 
animal Products 

for 

Formerly, CED certificate 

Common  Health  Entry  Document  module 
for Plant Protection 

Certificate of Organic Inspection 

Forest  Law  Enforcement,  Governance  and 
Trade 

DG AGRI 

DG ENV 

Ozone-Depleting Substances Licence 

DG CLIMA 

Fluorinated Greenhouse Gases: Registration 
(“Kigali License”); Authorisation/Quota  

ODS2 
system 

Licensing 

EU IUU Catch 

Illegal, Unreported and Unregulated fishing 
regulation, Catch certificate 

DG MARE 

Not yet specified 

PIC 

Prior Informed Consent 

REACH 

Registration,  Evaluation,  Authorisation  and 
Restriction of Chemicals 

DG ENV/ DG 
GROW 

ePIC (ECHA) 

DG GROW 

PD-NEA tool139 

Import licence 
cultural goods 

Import statement 
cultural goods  

Export licence 
cultural goods 

Import licence cultural goods 

DG TAXUD 

Not yet specified 

Import statement cultural goods  

DG TAXUD 

Not yet specified 

Export licence cultural goods 

Not yet specified 

Products 
and Compliance 

Safety 

Products  Safety  and  Compliance  (non-food 
products) 

DG GROW 

ICSMS 

Waste 

Waste Shipment Regulation documentation  DG ENV 

Not yet specified 

139   Portal Dashboard for National Enforcement Authorities 

Page 104 / 237 

 
 
 
                                                 
non-
mandatory 
EU  Systems 

TRACES NT 

b)  Category  2:  EU  regulatory  requirements  set  out  in  EU  legislation  for  which  the 
information  is  available  either  only  nationally,  namely  in  the  individual  Member  State 
system where compliance data is submitted and verified or in a combination of national 
and  non-mandatory  EU  systems  that  do  not  gather  customs-relevant  information  for  all 
Member States at central level. E.g. for some regulatory requirements like dual use goods 
licences  the  competent  DG  at  EU  level  is  developing  or  considering  developing  a  non-
mandatory  system  for  those  Member  States  willing  to  join  and  that  would  eventually 
coexist  with  national  ones.  These  future  EU  systems  and  the  corresponding  formalities 
are not considered under category 1 because, in principle, they would not make available 
information from all Member States at EU level, but only from the participating ones.  

Regulatory 
requirement(s)  

Description 

Owner 
legislation 

of 

the 

National  
Systems 

AGRIM  

AGREX 

CCFV 

EU Dual-Use 

Export of firearms 

EU surveillance 
document  

Drug precursors 

CITES 

IAS 

Source: DG TAXUD 

Agriculture 
Licence 

Import 

DG AGRI 

Agriculture  Export 
Licence 

DG AGRI  

DG AGRI 

Yes 

Yes 

Yes 

Certificate 
of 
conformity fruits and 
vegetables 

Goods,  software  and 
technology  that  can 
be  used 
for  both 
civilian  and  military 
applications. 

Export  of  firearms, 
and 
their 
parts 
and 
components 
ammunition 
Regulation 258/2012 

EU prior surveillance 
for  certain 
regime 
iron, 
and 
steel 
aluminium products 

Precursors 

Drug 
provisions  
Regulation 111/2005 

Convention 
on 
International Trade in 
Endangered Species 

Invasive 
Species 

Alien 

DG ENV 

DG TAXUD 

Yes 

eDUES 

DG HOME 

Yes 

eDUES 

DG TRADE 

Yes 

eDUES 

DG TAXUD 

Yes 

DG ENV 

Yes 

In  June  2019,  DG  AGRI  in  collaboration  with  DG  TAXUD  conducted  a  survey  on  the 
digitalisation  of  AGRIM/AGREX  licences  in  the  Member  States.  This  survey  showed  that 

Page 105 / 237 

 
 
 
 
 
 
 
 
out of 18 respondents, 15 Member States have an electronic licensing system in place for the 
application process; in  12 of them, licences are issued electronically.  In 11 Member States, 
the electronic licensing system is interconnected to customs systems allowing the electronic 
verification  of  licenses;  in  just  9  cases  does  the  interconnection  foresee  real  time  quantity 
management based on the quantities imported or exported in the Member State. 

In  addition,  a  study140  evaluating  the  implementation  of  Regulation  258/2012  against  illicit 
manufacturing  and  trafficking  of  firearms  found  that  among  Member  States  for  which 
information  is  available,  five  Member  States  (AT,  CZ,  DE,  EE,  UK)  have  fully  electronic 
licensing systems. The application is only paper-based in seven Member States (DK, FI, HU, 
LU, PL, PT, SI), the Belgian Capital Region and the Belgian Walloon Region. Nine Member 
States (ES, FR, IE, IT, LT, LV, NL, RO, SE, SK) and the Belgian Flemish Region allow for 
submitting applications in both electronic and written forms.  

c)  Category  3:  National  regulatory  formalities  introduced  by  national  legislation  in 
accordance with Article 36 of the TFEU141. There is no comprehensive list of the existing 
national  regulatory  requirements,  but  they  are  multiple  and  disparate.  The  national 
regulatory formalities provided by some Member States are listed below as an example: 

Licence code 

France 

Description 

Owner of the legislation 

2413 

Seeds importation document  

2044/2045 

Radionuclides import/export document 

0030 

Registration certificate required for exports of second-hand 
vehicles   

2409/2403 

Explosives and powder authorisations 

2043 

2041 

Authorisations for narcotics - psychotropics 

Importation autorisation for medicines 

2405 
Source: French customs  

Export authorisations for war materials 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

Licence code 

1311 

1310 

1313 

1306/1403/ 
1404/1407 

1406 

Spain 
Description 

Pesca ilegal exportacion         

Soivre seguridad importacion       

Farmacia exportacion         

Farmacia importacion         

Muestras biologicas  

1405/1413          

Sanidad exterior importacion       

1412 

1106 

Sanidad animal importacion       

R.E.A importacion               

Owner of the legislation 

National regulation 

National regulation 

National regulation 

National regulation 

National 
(RD 65/2006)         

regulation  

National regulation 

National regulation 

National regulation 

140   Source: EY, SIPRI and RAND (2017), Study in view of a report evaluating the implementation of Regulation 258/2012 

- Final Report. Information from the Final Report was double-checked during the field visits. 

141   https://ec.europa.eu/taxation_customs/business/customs-procedures/general-overview/single-administrative-document-

sad/national-sad-data-coding_en 

Page 106 / 237 

 
 
                                                 
1104 

1117 

1118 

MDDU. Material defensa           

MDDU.  Otro material de defensa         

MDDU.  Armas de fuego           

1408 
Source: Spanish customs 

CEXGAN exporta 

Italy 

National regulation 

National regulation 

National regulation 

National regulation 

Licence code 

Description 

Owner of the legislation 

01AO 

02AO 

03AO 

04AO 

05AO 

06AO 

02CC 

03CC 

04CC 

01CH 

01CR 

02CR 

03CR 

04CR 

05CR 

06CR 

02CS 

05CS 

06CS 

07CS 

09CS 

10CS 

11CS 

12CS 

13CS 

13RS 

01IT 

Autorizzazione Ministero dello Sviluppo Economico   National regulation 

Comunicazione di cui all'art.12 del DPR 187/2001 

National regulation 

Certificato di conformità. 

National regulation 

Attestazione dell'avvenuta sorveglianza radiometrica  National regulation 

Documento di trasporto unico 

EU Reg. 2446/2015 

Attestazione dell'origine estera del prodotto 

National regulation 

Nulla osta sanitario. 

National regulation 

Certificato di esenzione dal controllo del rispett.... 

National regulation 

Certificato di controllo  

EU 
1333/2008 (Art 6) 

regulation  

Identificativo registrazione presso l'ECHA  

ECHA 

Modiche quantita 

National regulation 

Dichiarazione di merce sana, leale, mercantile (ar....  National regulation 

Dichiarazione dell'origine della merce  

National regulation 

Dichiarazione dell'origine dei prodotti composti e....  National regulation 

Dichiarazione di non trasbordo in caso di esportaz....  National regulation 

Dichiarazione di trasbordo in caso di esportazione....  National regulation 

Autorizzazioni/Nulla Osta per l'importazione di pr....  National regulation 

Autorizzazioni/Nulla Osta per l'importazione di pr....  National regulation 

Autorizzazioni/Nulla Osta per l'importazione di f.... 

National regulation 

Autorizzazioni/Nulla Osta per l'importazione di pr....  National regulation 

Nulla Osta sanitario per l'importazione di indumen 

National regulation 

Nulla Osta per l'importazione di indumenti usati, ....  National regulation 

Nulla osta per introduzione di parti di cadavere,o.... 

National regulation 

Nulla Osta sostanze gas tossici e sostanze pericol....  National regulation 

Autorizzazione/Nulla  osta  sanitario  U.S.M.A.F. 
all.... 

National regulation 

Richiesta di autorizzazione/Nulla osta Sanitario U....  National regulation 

ITDER 

National regulation 

Source: Italian Customs  

Page 107 / 237 

 
 
Licence code 

Description 

Owner of the legislation 

The Netherlands 

0005 

0006 

0010 

0011 

0015 

0022 

0023 

0027 

0029 

0030 

0040 

0061 

0084 

0097 

0099 

1119 

1500 

1600 

1700 

1800 

1900 

1998 

Vervoersdocument Uitvoeringsbesluit accijns art. 3a 

National regulation 

Ontheffing  verdrag  chemische  wapens  Art.  3  (4) 
Uitvoeringswet verdrag chemische wapens 

Vergunning  kolenbelasting  Art.  36  Wet  belastingen  op 
milieugrondslag en Mededeling 18 nr. DGB/2010-630 

Vergunning  voor  het  binnenbrengen;  afgeg.  Door  min. 
Vrom  Kernenergiewet,  Handboek  VGEM,  onderdeel 
40.02.00 

Invoervergunning  productschap  Art.  3  (2)  Algemeen 
douanebesluit 

Verklaring  bewijs  van  typegoedkeuring  blustoestellen 
Verklaring dat belanghebbende in bezit is van een bewijs 
van typegoedkeuring besluit blustoestellen 

Consent  als  bedoeld  in  de  Wet  wapens  en  munitie 
Consent als bedoeld in artikel 14 Wet wapens en munitie 

Invoerverg. (overige prod.) Afgegeven door het min. Van 
vrom Art. 6 en 8 Opiumwet 

Kwaliteitscertificaat / PD-begeleidings-formulier. 

Inventaris  als  bedoeld  in  waarborgwet  Inventaris  als 
bedoeld in art. 50, 1e lid, waarborgwet 1986 

DO040-Verklaring  vernietiging  goederen  onder  toezicht 
Douane Art. 5 lid 37 letter c, DWU 

Geleidebiljet  ondermaatse  vis  Geleidebiljet  voor  het 
vervoer  van  ondermaatse  vis  in  de  gesloten  tijd  als 
voorzien in art. 12 

Factuurverklaring  voor  textielproducten  Art.  2  regeling 
aanwijzing  bewijsstukken,  inzake  de  oorsprong  van 
textielproducten 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

Wegvoeringsexemplaar 
douaneregeling 

Zuiveringsexemplaar 

Bijlage 

VI 

Algemene 

National regulation 

National regulation 

Voorfixatiecertificaat landbouw in depot bij productschap   Regulation 

376/2008/EC, 

Fytosanitaire  controle  De  aangegeven  goederen  vallen 
niet  onder  het  toepassingsgebied  van  EU  Richtlijn 
2000/29 van de Raad. (fytosanitaire eisen). 

Kwaliteit  controle  De  aangegeven  goederen  vallen  niet 
onder  het  toepassingsgebied  van  Uitvoeringsverordening 
(EU) Nr. 543/2011 van de Commissie. (kwaliteitsnormen 
G&F). 

Art 24 

Regulation 2000/29/EC 

Regulation EU 543/2011 

bescheidcode 
Fictieve 
landbouwregimes taric-NL toepassing 

inzake 

economische- 

en 

National regulation 

Fictieve  bescheidcode  inzake  gezondheid  en  kwaliteit 
TARIC-NL toepassing 

Fictieve  bescheidcode  inzake  overige  regelingen  bij 
invoer TARIC-NL toepassing 

Fictief 

National regulation 

National regulation 

National regulation 

Page 108 / 237 

 
 
1999 

2010 

2095 

8002 

8003 

8004 

8005 

8006 

8007 

8009 

8010 

8011 

8016 

8022 

8025 

8030 

9003 

9004 

Fictieve  bescheidcode  bij  uitvoer  (zwaar  bescheid) 
TARIC-NL toepassing 

National regulation 

Formulier l ter bestemming (F) Formulier landbouw L(F)  National regulation 

Formulier zekerheid rvo(invoer)  

National regulation 

Verklaring nederlands stamboek Art. 9 Fokkerijbesluit 

National regulation 

Geleidebiljet/Ontheffing vervoer vis 

Uitvoercertificaat preferentiele regeling kaas 

Oorsprongs-  en  geldigheidscertificaat  voor  uitvoer  van 
bepaalde kaas 

Uitvoeringswet  verdrag  Chemische  wapens,  Strategische 
goederen, Handboek VGEM, onderdeel 30.06.00 

Uitvoeringswet  verdrag  Chemische  wapens,  Strategische 
goederen, Handboek VGEM, onderdeel 30.06.00 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

Gezondheidscertificaat 
dieren  Art. 
gezondheids- en welzijnswet voor dieren 

77 

van 

de 

National regulation 

FORMULIER  L(F)  TER  verzending/uitvoer  L(F) 
formulier. Restitutie (Nationaal) 

Uitvoervergunning/ontheffing cdiu handelspolitiek In- en 
uitvoerwet 

Uitvoervergunning/verlof  opiumwet  Art.  6  en  8 
Opiumwet 

Uitvoervergunning  militaire  goederen  CDIU  Art.  6 
Besluit strategische goederen 

Uitv.Verg.Reg.Goed.Tweeerlei  Gebr.  Egypte,  Syrie, 
Oekraine  Vergunning  inzake  Regeling  goederen  voor 
tweeerlei  gebruik  voor  uitvoer  naar  Egypte,  Syrie  en  de 
Oekraine 

VERGUNNING  VERZAMELZENDING  UITVOER 
Beleidsbesluit nr. 2009/2057 

FORMA 

een 
PRO 
waardeverklaring  Commentaar  7  punt  9  en  10  van  het 
Comite Douanewetboek, afdeling douanewaarde 

voorlopige 

factuur 

of 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

National regulation 

UNECE  Recommendation 
01 code 325 

Vergunning in het kader van vo. (EG) Nr. 1186/2009 Art. 
7:2 Algemene douaneregeling 

Regulation EU 1186/2009 

9999 
Source: Dutch Customs 

Overige Bescheiden  

National regulation 

d)  Category  4:  Regulatory  formalities  certified  by  a  third-country  authority  where  the 
compliance  information  is  presented  directly  to  customs  authorities  in  the  EU  as  a 
supporting  document  to  the  customs  declaration.  These  include  Certificates  of  Origin 
issued  by  third  countries  with  which  the  EU  has  agreements  in  place,  and  other 
certificates such as the VI 1 certificates for wine or the Kimberley Process Certificates.  

Page 109 / 237 

 
 
 
 
ANNEX 9: SINGLE WINDOW INITIATIVES AT NATIONAL LEVEL 

Single window developments/initiatives at national level 

Member 
State 
Austria 

National Custom Single Windows: Current state of play 

  The Customs Single Window scheme is fully operational. 
  The  Customs  Single  Window  facility  is  managed  by  both  customs 
administration  and  involved  regulatory  agencies,  such  as  Ministry  of 
Trade/Ministry of Agriculture/Agency for Agricultural Products. 

  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

  The issuing authority sends license data  automatically  at  the moment  of 
their issuing to the customs system via web service using XML. Customs 
sends back the relevant data for customs declarations. 

  EORI  number  is  used  by  the  regulatory  agencies  participating  in  the 

Customs Single Window scheme.  

Belgium 

  A final scheme has been selected, and a study phase has been carried out 

based on which a Proof of Concept will be performed. 

  Customs  administration  is  the  leading  authority  for  the  Customs  Single 

Window scheme, although its role is not formalised. 

  The  majority  of  certificates  requested  by  the  economic  operators  are 

currently paper-based. 

Bulgaria 

  Customs administration manages the SW facility and the Bulgarian Food 

Safety Agency is the involved regulatory agency. 

  Customs provides a Single Access Point to all its electronic services. 
  8 customs competent customs offices are designated for the introduction 

of goods subject to veterinary controls. 

  Paper CVEDs are also used. 
 

Import  declarations  and  T1  (transit  declarations)  are  affected  within  the 
Customs Single Window scheme. TIR and ATA carnets are excluded. 

  ЕО submits the required information to the issuing authority.  
  Links  between  customs  information  systems,  EU  CSW-CVED  and 
Bulgarian Food Safety Agency IT system are based on a web services and 
asynchronous exchange massages. 

  The  connection  between  the  systems  is  established  by  the  protected 

government network. 

Czechia 

  Customs  administration  is  the  leading  authority  for  the  Customs  Single 

Window scheme, although its role is not formalised. 

  Economic  operator  submits  the  required  information  to  the  issuing 

authority.  

  Data  harmonization  is  carried  out  for  cross  border  regulatory  agencies 

participating in the Customs Single Window. 

  Data transformation for CVED documents is performed by DG TAXUD 

and by the customs administration for CITES documents. 

  Web services and XML are used for data exchange. 

Page 110 / 237 

 
 
Member 
State 

National Custom Single Windows: Current state of play 

Estonia 

  Automatic validation is based on type of TARIC certificate (e.g. C400) in 
box  44  of  customs  declaration.  Box  44  of  the  customs  declaration  was 
expanded to include “certificate item and item quantity.” 
  Preparatory phase for the quantity management functionality. 
  The quantity management functionality is based on the actual “write-off” 
of  the  available  quantity  (rather  than  the  “reservation  of  quantity”) 
because  the  reservation  system  is  too  complicated  for  single  use 
transactions, like CITES permits and FLEGT licenses. 

  The Customs Single Window is not yet operational. No central database 
will  be  created.  Each  authority  runs  its  own  database  that  will  be 
connected to the customs system.  

  Expressed interest in joining the EU CSW-CERTEX project starting from 

Release 1.4.0 of the EU CSW-CVED project. 

  The  Customs  Single  Window  scheme  is  anticipated  to  expand  in  the 
following areas: feed, cultural goods, CAP goods, strategical goods (dual-
use and export control), medicines and explosives. 

  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

  One-stop shop in road transport. 
  All  authorities  are  obliged  to  exchange  information  by  using  Data 
Exchange  Layer  X-Road  pursuant  to  national  legislation.  The  exchange 
of information with TRACES will be resolved via SPEED. 

  Customs declaration system and IT systems of regulatory agencies will be 
amended  in  order  to  harmonise  data  for  all  systems  and  avoid 
transformation  of  data.  If  this  harmonisation  will  not  be  possible,  data 
transformation will be decided on a case by case basis. 

  The  MobiCarnet  private  sector 

initiative  will  allow 

to 

lodge 

electronically: 

      TIR-carnet  data  (transmit  XML  via  X-road  to  NCTS),  invoice,  CMR, 

packing list and certificates. 

France 

  Customs Single Window scheme has been operational since December 7, 

2015 (“Guichet Unique National” initiative). 

  The customs administration is the leader of the Customs Single Window 

facility. Its role is formalised by national legislation. 

  All  authorities  issuing  permits  and  certificates  required  for  imports  and 
exports are progressively to be involved in the Customs Single Window 
mechanism.  The  current  scope  includes  CITES,  AGREX,  seed  import 
declaration and the radionuclide export and import certificates. 

  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

  Economic  operator  provides  the  type  code  and  the  reference  of  the 
document  submitted  in  box  44.  For  each  document  added  in  box  44, 
to  provide  extra 
customs  authorities  request  economic  operators 
(imputation 
information 
to 
the  quantity 
segment/boxes)  which  allow 

reference 
implementation  of 

the  document 

specific 

the 

Page 111 / 237 

 
 
Member 
State 

National Custom Single Windows: Current state of play 

management functionality.  

  Automation  of  both  customs  cross-checks  and  quantity  management  is 

available. 

  The PDF of the supporting document is made available to customs agents 

when they consult the electronic declaration.  

  Exchanges are carried out by web service (http) SOAP calls, whereas data 

is sent in XML. 

Germany 

  The  customs  information  system  (ATLAS  system)  mirrors  the  national 

Greece 

Italy 

Customs Single Window. 

  Bi-directional interfaces for export licences through which the certificates 
are received by customs from the competent authorities. In case of single 
licences,  quantity 
licences  and  maximum  value  export 
export 
management is carried out by the customs clearance system.  

  Single-directional interfaces for AGREX and AGRIM through which the 
certificate  and  licence  datasets  are  received  by  customs  from  the 
competent  authorities.  No  quantity  management  is  implemented  in  the 
customs clearance system for AGREX and AGRIM. 

  Option  to  join  EU  Customs  Single  Window:  Certificates  exchange  has 
been discussed in January 2017 with various business/technical experts. 
  Currently,  the  Customs  Single  Window  project  is  undergoing  the 

inception phase. 

  Customs is the leading authority in the Customs Single Window initiative 
but  the  relationship  with  the  regulatory  agencies  is  established  through 
the  National  Committee  on  Trade  Facilitation  whose  role  is  legally 
formalised. 

  Both legal and regulatory national amendments have been introduced for 

the Customs Single Window initiative. 

  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

  An  economic  operator  is  legally  obliged  to  send  certificates  to  customs 
electronically through ICISnet (National Integrated Customs System). All 
supporting  documents  for  export  procedure  are  uploaded  to  this  system 
since 2014. 

  Customs  administration  is  the  leading  authority,  formalised  by  national 
legislation. The role of the competent authorities involved in the national 
Customs  Single  Window  is  formalised  by  Presidential  Decree  n. 
242/2010. 

  The organisational setup for Customs Single Window activities includes a 
for 
central  monitoring  and  control  committee,  a  subcommittee 
interoperability  between  customs  administration  and  other  government 
agencies,  a  technical  working  group  and  several  procedural  working 
groups for each agency.  

  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

Page 112 / 237 

 
 
Member 
State 

National Custom Single Windows: Current state of play 

  Data integration and harmonization is performed only once at the start of 
each project by means of an IT system alignment process. As such, data 
transformation is no longer needed, and the information is exchanged via 
the  XML  message.  The  coordination  of  controls  is  integrated  in  this 
process.  

  Only  import  declarations  are  affected  by  the  Customs  Single  Window 

scheme. Only AGREX licenses are affected at export.  

  The  quantity  management  functionality  is  implemented  for  AGRIM  / 
AGREX licenses and is under development for certificates issued by the 
Ministry  of  Health.  A  database  replication  is  established  from  the  EU 
database  to  the  Ministry  of  Health  which  sends  the  information  to 
customs.  Requests  from  economic  operators  are  replicated  after  passing 
through TRACES. The database replication approach enables the customs 
administration to perform quantity management and send feedback to the 
competent authority. Economic operators can monitor the lifecycle of the 
customs  declaration/  supporting  documents  by  using  the  portal  of  the 
Italian Customs Agency. 

  Web services and XML are used for data exchange. 
  A  new  Customs  Single  Window  facility  that  will  allow  economic 
operators  to  send  information  only  once  is  anticipated  to  be  developed 
pursuant to Decree n. 169/2016 Art. 20. 

Ireland 

  National  Customs  Single  Window  is  run  and  managed  by  both  the 

 

customs administration and other regulatory bodies involved. 
In  2014,  Irish  customs  implemented  an  Electronic  Manifest  System 
(EMS). All Manifest data (for both Air and Sea) is received in the EMS. 
Data from the EMS is shared with the Department of Transport, Tourism 
and  Sport  and  the  Department  of  Agriculture  and  Health.  Plans  are  in 
place to share the data with other government agencies. 

  Customs  have an in-house Arrivals  System  which stores  information  on 
the  Arrival  of  all  flights  and  ships  into  Ireland.  This  system  interfaces 
with  all  customs  electronic  systems  (Clearance,  ICS,  Manifest,  etc.)  to 
update the status of declarations. The information on the Arrival of Ships 
is  received  from  SafeSeasIreland,  while  the  information  on  flights  is 
received  from  the  Airport  Authorities.  With  this  facility  in  place,  the 
requirement  for  the  operators  of  the  flights  or  ships  to  send  customs 
Arrival Notifications is waived. 

  The  manifest  and  arrival  notifications  are  deemed  to  be  the  temporary 
storage  declaration.  Customs  declarations  that  are  lodged  or  written  off 
are  matched  against  the  temporary  storage  declaration.  As  such,  the 
system indicates goods under the temporary storage procedure and those 
that are released. 
ICS  receives  pre-arrival  information  in  advance  and  interfaces  with  the 
arrival system. The status of the ENS is updated to “arrived” at the time 
of arrival, at which point the system performs a check on the declarant. If 
the declarant allows for the re-use of data by customs, the data is moved 
from  ICS  to  the  manifest  system  to  be  reused  as  presentation  and 

 

Page 113 / 237 

 
 
Member 
State 

National Custom Single Windows: Current state of play 

Latvia 

Lithuania 

temporary storage. 

  The current system does not allow different information to be lodged by 
different parties, but Ireland intends to update the system pursuant to the 
UCC requirements, particularly as it pertains to temporary storage. 

  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

  The certificate data is sent directly to the customs clearance system from 
the  issuing  authority  via  the  EU  database.  Only  the  status  of  the 
certificate is relevant to the clearance of the customs declaration. 

  Web services and XML are used for data exchange. 
  The EU CSW-CVED is in production since 20.09.2015. 
  Economic  operator  submits  the  required  information  to  the  issuing 

authority. 

  The  exchange  of  certificates  data  is  performed  via  the  Rural  Support 
Service  (AGRIM/AGREX)  and  Food  and  Veterinary  Service  (through 
TRACES).  Data  exchange  between  customs  and  Rural  Support  Service 
systems  is  established  via  a  special  channel.  Customs  receives  the  data 
regarding issued certificates (AGRIM/AGREX) which is validated during 
processing (submitting) the corresponding customs declarations. After the 
declaration  is  released,  the  information  (endorsement  of  certificate)  is 
sent back to the Rural Support Service. 

  Quantity management for AGREX/AGRIM is managed automatically in 
the  customs  system.  No  quantity  management 
is  available  for 
CED/CVED certificates as such, but customs system provides a summary 
of the affected declarations to customs officers for manual verification. 
  SOAP web services are used with the Rural Support Service. REST Web 

services are used for data exchange with TRACES. 
  Trader obligations are governed by national regulations. 
  LV  Customs  Single  Window  solution  for  railway  uses  the  SMGS 
consignment  note  (the  SMGS  system  railway  manifest)  presented  in 
every transit declaration as a transport document. LV railway companies 
use NCTS for transit procedures declaring both national and international 
movements.  

  Customs has implemented a project in 2015 for the implementation of the 
Customs  Single  Window  system  with  partners,  such  as  the  State  Food 
and  Veterinary  Service,  the  Department  of  Cultural  Heritage  under  the 
Ministry  of  Culture,  the  National  Paying  Agency  under  the  Ministry  of 
Agriculture and the State Enterprise Centre of Registers. 

  Conformance  testing  for  the  Customs  Single  Window  interface  was 

completed in 2016. 

  Legislation has come into force for issuing AGRIM and AGREX licenses 

which are issued only electronically. 

  The  Customs  Department  under  the  Ministry  of  Finance  has  been 
nominated as a lead authority to implement the Customs Single Window. 

Page 114 / 237 

 
 
Member 
State 

National Custom Single Windows: Current state of play 

  The Economic operator submits the required license information directly 

to the issuing authority. 

  An  interface  has  been  developed  in  Customs  Single  Window  whereby 
customs  authorities  and  anyone  can  search  for  any  certificate/licence 
issued by project partners. 

  Quantity  management  for  AGREX/AGRIM  is  managed  automatically 
and  takes  place  in  the  information  system  of  the  National  Payment 
Agency under the Ministry of Agriculture.  

Luxembourg    Currently, the national  Customs  Single Window called “Single Window 
for  Logistics/SWL”  project  is  undergoing  the  inception  phase.  The 
Customs Single Window for Logistics is not yet operational. 

  The Customs Single Window initiative is coordinated by the Ministry of 
the  Economy  in  close  collaboration  with  all  engaged  governmental 
services, particularly with the Luxembourg Custom’s Administration. 
  A  multiannual  project  portfolio  has  been  implemented  since  September 
2015 (2015-2020). A Customs Single Window programme management 
team (Single Window for Logistics team) is in place. 

  The Economic operator can apply for most certificates electronically but 
the  licence  is  issued  on  paper  if  an  original  copy  is  required  by  the 
country of destination. 

  The relationship with the regulatory agencies participating in the Customs 

Single Window is formalised. 

  A  data  harmonisation  project  has  been  set  up  in  order  to  build  a  LU 
Customs  Single  Window  data  model.  GEFEG.FX  tool  to  build  our 
national  Customs  Single  Window  for  Logistics  data  model.  The 
certificate data will be mapped against one common data set based on the 
EU CDM to achieve the objective of data reuse. 
  No Customs Single Window facility is yet in place. 
  Plans to join the EU CSW-CERTEX project in the future. 
  The  Customs  Single  Window  facility  will  be  managed  by  customs 

authorities in collaboration with various involved stakeholders. 

  All  certificates  are  paper-based.  Export  licences  will  soon  be  issued 

electronically by the Commerce Department. 

  Currently,  economic  operators  submit  the  required  information  to  the 

issuing authority. 

Malta 

Netherlands 

  The Maritime Single Window (MSW) is being enhanced to all modes of 

transport into Single Window for Trade and Transport (SWTT). 

  A  EU  CSW-CVED-like  Single  Window  has  been  established  where 
information from phytosanitary certificates is combined with declarations 
for  free  circulation.  The  Customs  Single  Window  Phyto  is  managed  by 
the Phytosanitary authority. 

  Customs  is  the  lead  authority  and  its  role  is  formalised  in  the  Logistics 
Policy  of  the  Netherlands  Government,  in  a  multi  departmental  steering 
group and other national agreements.  

Page 115 / 237 

 
 
Member 
State 

National Custom Single Windows: Current state of play 

  Veterinary  and  phytosanitary  certificates  are  issued  only  electronically. 
AGRIM  and  AGREX  certificates  are  currently  on  paper,  but  will  be 
available electronically in the near future. 

  The  required  information  for  the  Maritime  Single  Window  (SWTT)  is 
sent  to  the  Customs  Single  Window  and  distributed  to  the  competent 
authorities.  The  phytosanitary  information  is  directly  sent  to  the 
competent authority, which shares it with other authorities. 

  Economic  operators  can  access  TRACES  directly,  or  use  the  FFPS 
platform, which will automatically transfer the information to TRACES. 
The information delivered to TRACES is also stored at the national Food 
Feed and Product Safety Organisation. 

  XML and EDIFACT messages are used to receive data. 
  With  regard  to  Data  Integration  and  Harmonisation,  a  governmental 
forum on standardisation has chosen the WCO data model as the basis for 
all governmental authorities.  

  Data  fields  for  the  bills  of  lading,  airway  bills,  container  type 

identification and container number have been harmonised. 

  The use of EORI-numbers is harmonised between different authorities. 
  Customs  performs  integrated risk assessments  on goods and execute the 

coordination on controls and inspections. 

  Currently,  the  national  Customs  Single  Window  project  is  in  the 
elaboration phase. The relevant documentation (functional specifications, 
etc.) is being finalised. 

  AGRIM-AGREX  pilot  project  has  been  developed.  The  deadline  for 
implementation  depends  on  the  progress  of  deployment  of  the  new  IT 
environment of the National Revenue Administration.  

  No legal amendments have been implemented with regard to the national 

Customs Single Window. 

  The National Revenue Administration is the national coordinator for the 
Customs Single Window project, but it does not  have a formalised role. 
Cooperation agreements  on the Customs Single  Window are  anticipated 
with other system stakeholders (government agencies). 

  EU CSW-CVED for transit is fully operational. Communication between 
NCTS2  and  EU  CSW-CVED  takes  place  automatically  after  receipt  of 
IE015  message  containing  veterinary  document:  C640  /CVED-A/  or 
N853 /CVED-P. 
Initial  steps  toward  the  process  of  developing  and  implementing  a 
national  Customs  Single  Window  which  is  anticipated  to  be  run  by  the 
customs administration. 

 

  The automatic exchange of information between customs declaration and 

other certificates started with AGREX. 

  The  electronic  AGREX  licence  allows  the  cross  check  and  exchange  of 
data  between  the  SLE  -  External  Licensing  Service  and  customs  export 
declaration  (STADA  –  EXPORT).  This  connection  includes  quantity 
management. 

Page 116 / 237 

Poland 

Portugal 

 
 
Member 
State 

Spain 

National Custom Single Windows: Current state of play 

  An  integrated  IT  customs  system  for  the  fulfilment  and  treatment  of 
declarative formalities associated with the arrival and departure of vessels 
and  aircrafts  to  and  from  PT  ports  and  airports,  SDS  (System  for  the 
Integrated  Treatment  of  the  Means  of  Transport  and  Goods)  has  been 
developed to incorporate data related to the entry and exit manifests.  
  Fully operational system for exchanging certificate data. A one-stop shop 
to coordinate physical controls on goods is currently completing the pilot 
phase.  

  A common repository is available to all parties involved for the required 

documentation. 

  Two  national  regulations  were  modified,  and  seven  agreements  were 

signed to implement the Customs Single Window facility. 

  Customs  administration  is  the  lead  authority  for  the  national  Customs 

Single Window. 

  Two  alternatives  are  available.  Traditional  approach:  traders  could 
declare  certificates  in  box  44  of  the  SAD.  In  this  case,  the  certificate's 
data  are  retrieved  from  the  issuing  authority  and  automatically  cross-
checked with the customs declaration. Pre-SAD approach: the economic 
operator lodges a pre-customs declaration which is assigned a file number 
(MRN) 
involved 
authorities.  The  MRN  is  used  to  request  certificates  from  the  relevant 
competent authorities which issue the corresponding certificate and send 
it automatically to customs. The MRN is the key to match the SAD with 
the certificate. The advantage is that the certificate is directly applied to 
SAD upon receipt. Hence, the economic operator does not need to declare 
it in box 44. 

information  exchange  with 

to  enable 

in  order 

Sweden 

  The  pre-SAD  approach  allows  the  coordination  of  controls.  The  main 
advantage is that customs can apply risk analysis tools prior to the arrival 
of the goods, thus providing involved authorities with better information 
in  advance.  If  any  of  the  competent  authorities  involved  needs  to  check 
the  goods  before  issuing  the  certificate,  they  communicate  it  to  the 
Customs  Single  Window  to  coordinate  all  necessary  controls.  MRN  is 
again the key for the information exchange.  

  A minimum data set has been established for the pre-SAD. The complete 

customs declaration is lodged according to Article 171 UCC. 

  The Customs Single Window scheme is fully operational and is managed 
by  the  customs  administration.  Legal/regulatory  amendments  were 
applied to existing legislation. 

  The economic operator submits the declaration to customs which passes 
through from Customs Single Window facility to the competent authority. 

  Customs receives licenses from the competent authority via EDI. 
  Veterinary checks are performed separately. 
  Confidentiality  and  data  protection  are  ensured  by  applying  strong 

authentication measures. 

Source: Data provided by the Member States participating in the Customs 2020 Project Group 

Page 117 / 237 

 
 
 
ANNEX 10: SINGLE WINDOW INITIATIVES AT INTERNATIONAL LEVEL  

In recent years, the concept of the ‘single window’ has gained momentum at the international 
level.  Various  standardisation  bodies  and  international  organisations  such  as  the  United 
Nations  Economic  Commission  for  Europe  (UNECE),  its  subsidiary,  the  United  Nations 
Centre  for  Trade  Facilitation  and  Electronic  Business  (UN/CEFACT),  the  World  Customs 
Organisation (WCO) and the World Trade Organisation (WTO) have promoted this concept 
and supported capacity-building efforts for its implementation through international standards 
and  guidance  documents.  Over  the  past  few  decades,  UNECE  has  developed  a  series  of 
interlinked  recommendations  that  represent  best  practices  on  trade  facilitation,  including  a 
number of formal recommendations applicable to the implementation of the single window. 
As  an  example,  the  graph  below  references  the  UN’s  approach  for  the  creation  of  a  single 
window.  

Figure 16: Key steps in the creation of a single window 

Source: UNECE/UN/CEFACT 

In its most widely  acknowledged international  definition142, the single window is  “a facility 
that  allows  parties  involved  in  trade  and  transport  to  lodge  standardised  information  and 
documents with a single-entry point to fulfil all import, export, and transit-related regulatory 
requirements” whereby trade data is only required to be reported once. With its emphasis on 
collaboration  between  authorities  and  better  sharing  of  information,  the  single  window 
concept  offers  a  vision  for  most  countries  to  support  both  trade  facilitation  and  the 
enforcement  of  regulatory  requirements.  The  elimination  of  procedural  redundancies  and 
reduction  of  clearance  times  in  the  fulfilment  of  regulatory  formalities  is  viewed  as  a 
competitive advantage in global trade that contributes to well-positioned economies and ease 
of doing business.   

142   UNECE Recommendation 33, July 2015. 

(https://www.unece.org/fileadmin/DAM/cefact/recommendations/rec33/rec33_trd352e.pdf)  

Page 118 / 237 

 
 
 
                                                 
 
The establishment of a single window has been proposed by the World Trade Organization 
(WTO)  as  one  of  the  key  elements  to  develop  within  the  context  of  its  Trade  Facilitation 
Agreement (TFA). The WTO TFA that entered into force in 2017 includes a ‘best endeavour 
clause’143 committing the signatory parties to establish single windows. Countries around the 
world  are  now  actively  involved  in  digitalising  their  customs  and  other  related  procedures 
required  for  international  trade  to  simplify  and  streamline  processes  for  dealing  with 
regulatory requirements. Some have implemented national single windows or have embarked 
on initiatives to develop single windows, while others are building on existing developments 
to  provide  key  features  of  the  single  window  or  studying  future  implementation.  Some 
initiatives to realise the single window concept pursued by EU’s international trading partners 
are summarised below.  

The single window initiative in the United States dates back to the mid-1990s when a number 
of  recommendations  were  formulated  to  harmonise  data  for  an  integrated  government 
oversight  of  international  trade.  The  initiative  remained  in  the  pipeline  until  2014  when 
President  Obama  signed  Executive  Order  13659144,  mandating  completion  of  an  electronic 
single window by December 2016. The Customs and Border Protection (CBP) agency fully 
implemented 
2017.  The  Automated  Commercial 
Environment/International  Trade  Data  System  (ACE/ITDS)  systems  provide  one  electronic 
interface through which the trade submits the required information for customs and different 
government  agencies,  known  as  partner  government  agencies  (PGA).  ACE  is  the  primary 
electronic filing environment that connects the trade community with the U.S. Customs and 
Border Protection (CBP) and 47 PGAs of the federal government shown below.  

initiative 

January 

the 

in 

Figure 17: U.S. Partner Government Agencies  

Source: U.S. Customs and Border Protection  

143   Article 10.4 of the WTO TFA 
144   https://obamawhitehouse.archives.gov/the-press-office/2014/02/19/executive-order-streamlining-exportimport-process-

america-s-businesses 

Page 119 / 237 

 
 
 
                                                 
This  interface  ensures  compliance  with  U.S.  laws  and  regulations,  while  enhancing 
transparency and increasing predictability in the movement of goods. Efficiency for the trade 
results  from  the  sharing  of  common  data  across  PGAs.  The  U.S.  single  window  aims  to 
improve  the  competitiveness  of  the  United  States  in  the  global  economy  through  trade 
facilitation, and enhance PGA enforcement.  

Similar  developments  were  observed  in  Singapore  where  the  Single  Window  for  Trade 
(TradeNet) became operational in 1989, bringing together more than 35 border agencies. The 
TradeNet  system  began  as  an  electronic  data  interchange  (EDI)  system  that  links  multiple 
parties involved in external trade transactions to a single point of transaction for most trade 
formalities.  TradeNet  integrates  import,  export  and  transhipment  documentation  processing 
procedures,  enabling  customs  and  other  competent  authorities  to  monitor  the  movement  of 
goods and enforce regulatory requirements across policy areas. 

In  China,  some  degree  of  single  window  has  been  in  place  since  2012,  although  each 
province has its own local version of the single window system with different functionalities 
and levels of maturity. Various pilots were launched in Shanghai and several coastal ports on 
a  “single  declaration,  single  inspection  and  single  release”  model  but  it  was  not  until  late 
2017  that  a  standard  single  window  platform  became  operational,  centralising  data  for  all 
ports of 31 provinces under the direction of the central government. The integrated platform 
is currently running in parallel with the local single window systems, allowing enterprises to 
submit  data  only  once,  which  is  then  automatically  passed  to  the  relevant  government 
authorities. This will rationalise the former ‘linear’ process of customs clearance and lead to a 
shift  towards  a  more  integrated  and  synchronised  approach  with  ‘parallel’  enforcement  of 
regulatory  formalities,  reducing  administrative  costs  and  the  time  needed  for  customs 
clearance.  

The  single  window  initiative  of  the  Canada  Border  Services  Agency  (CBSA)  streamlines 
processes  for  the  exchange  of  commercial  import  data  between  the  Government  of  Canada 
and  the  import  community  to  eliminate  duplicate  and  redundant  data  requirements  and 
simplify  border  processes.  Besides  the  CBSA,  nine  government  departments  and  agencies 
(PGA)  representing  38  government  programs  participate  in  the  single  window  initiative.  A 
critical part of the CBSA Single Window Initiative is the Integrated Import Declaration (IID), 
an electronic message that  the CBSA has  developed to  allow traders to  submit  both  CBSA 
and applicable PGAs import data requirements. This means that the CBSA and PGAs collect 
required import data from a single declaration, instead of multiple submissions. Transmitted 
electronic  data  is  shared  among  CBSA  and  regulating  agencies  for  easy  access,  processing 
and monitoring. The use of the IID became mandatory for all applicable import transactions 
in  Canada  as  of  April  1,  2019.  PGA  licenses,  permits,  certificates  and  other  data  can  be 
provided on an IID and validated by PGAs before the arrival of the goods. Related data that 
cannot  be  populated  into  the  IID  fields  may  be  submitted  as  digital  image  through  a 
Document Image Functionality.  

Similarly,  the  Indian  Single  Window  Interface  for  Facilitation  of  Trade  (SWIFT)  allows 
importers  and  exporters  to  lodge  their  clearance  documents  online  at  a  single  point.  The 
necessary  permits  from  non-customs  regulatory  agencies  are  obtained  online  without  the 
trader having to approach participating government agencies (PGA) separately. Some of the 
main  features  of  the  SWIFT  project  are  the  integrated  declaration,  the  integrated  risk 
assessment  and  the  online  clearance  platform.  Starting  in  April  2016,  traders  electronically 
submit  customs  clearance  information  required  by  relevant  PGAs  through  an  integrated 
declaration  at  a  single-entry  point,  i.e.  the  Customs  Gateway  (ICEGATE).  The  integrated 
declaration  replaces  the  separate  submissions  of  application  forms  required  by  different 

Page 120 / 237 

 
 
PGAs involved in the clearance process. When filing the integrated declaration, an automated 
routing feature enables the customs IT system to identify consignments that require clearance 
by  the  PGAs.  SWIFT’s  Integrated  Risk  Management  feature  allows  all  PGAs  to  integrate 
their  risk  criteria  in  the  system  and  carry  out  risk-based  inspection  and  testing  based  on 
selective targeting of consignments. These risk-based targeted controls would enable PGAs to 
focus  on  high-risk  consignments,  while  generating  a  faster  and  more  efficient  customs 
clearance  and  control  procedures.  Finally,  the  system  records  and  gathers  clearance  related 
decisions and approvals from relevant PGAs and delivers the results to the trader at a single 
point through an online clearance platform. 

It should be noted that it is challenging to estimate the exact number of currently operating 
single window systems around the world due to the different models adopted, national laws 
and  the  extent  of  operations  and  functions  performed.  However,  following  the  entry  into 
force of the WTO TFA, 72 countries have provided transparency notifications145 with regard 
to the operation of the single window. Moreover, China, Chinese Taipei, El Salvador, Brazil, 
Mexico  and  Saudi  Arabia  have  shared  their  experience  concerning  the  partial  or  full 
implementation of single window platforms in the WTO context. Other countries, like India, 
have  indicated  willingness  to  present  their  single  window  developments  at  the  WTO  TFA 
Committee  meeting  in  February  2020.  Likewise,  Singapore  and  New  Zealand  have  started 
bilateral negotiations to apply the once only submission principle in their custom procedures.   

At  the  regional  level,  the  single  window  is  comprised  of  several  national  single  windows, 
allowing countries to integrate relevant data into a single regional portal. The Association of 
Southeast  Asian Nations (ASEAN) Single Window initiative in  the Asia-Pacific  region  has 
played an important role in building the necessary political support and policy environment 
for  single  windows  at  the  national  level.  This  association  is  currently  in  the  process  of 
implementing  a  Government-to-Government  (G2G)  exchange  of  information  between  the 
national  single windows of its member countries (some of which have been operational  for 
many  years)  so  that  a  single  submission  of  information  can  be  sufficient  for  all  ASEAN 
members. 

Figure 18: Single Window system development status in Asia and the Pacific  

Source: United Nations Economic and Social Commission for Asia and the Pacific (UNESCAP) 

145   Publication of information for governments and traders on Article 10.4.3 of the WTO TFA related to the operation of 

the single window: https://tfadatabase.org/notifications/transparency  

Page 121 / 237 

 
 
 
                                                 
Similarly,  the  African  Alliance  for  e-Commerce  (AACE)  has  steadily  progressed  on  the 
strategy  of  implementing  single  window  environments  for  efficient  trading  regimes  in  the 
African nations. Beneficial projects and initiatives have been evaluated over the recent years 
through continuous workshops in this field.  

The  Asia-Pacific  Economic  Cooperation  (APEC)  countries  are  discussing  the  path  forward 
for the implementation of the single window in the context of regional economic integration 
and  the  need  for  further  facilitation  of  international  trade.  CBSA  has  also  been  eager  to 
explore a Regional Single Window with the U.S. and Mexico. 

In  an  effort  to  inform  on  the  progress  to  date  on  Single  Window  environments  and  trade 
facilitation  measures,  the  World  Customs  Organization  (WCO)  has  created  an  online 
interactive  map146  for  its  members,  known  as  the  Reform  and  Modernization-Monitoring 
Activities and Projects  (RAMMAP) and Single Window Interactive Map (SWIM). Devised 
as a structured database, this platform integrates several sources of information ranging from 
WCO  surveys  and  websites  of  member  administrations  to  publicly  available  information 
from  international  stakeholders,  while  acting  as  a  hub  for  further  performance  monitoring 
activities. 

146   https://rammap-swim.wcoomd.org/ 

Page 122 / 237 

 
 
                                                 
ANNEX 11: NUMBER OF DECLARATIONS COVERED BY OPTIONS 1, 2 AND 6 

Estimated number of declarations per year subject to regulatory requirements covered 
by option 1   

Estimated no of declarations / year (thousands) 

Regulatory 
requirements covered 
Import requirements 

CHED-PP  

CHED-P*  

CHED-D** 

Catch import 

Waste import 

COI 

CHED-A***  

FLEGT 

ODS import 

estimates 

Combined 
FGAS,  Cultural 
import, Product safety 

for 
goods 

Total imports 

Export requirements 

Waste export  

PIC 

ODS export 

Export 
goods 

licence 

cultural 

Catch export 

Total exports 

Overall total 
Annotation: *Based on figures for predecessor CVED-P;  

**Figures based on predecessor CED; 
***Figures based on predecessor CVED-A.  

972  

655  

641  

417  

231  

135  

96  

57  

13  

482  

3 699  

188  

126 

72  

20  

23  

429 

4 128 

Source: Declarations and supporting documents data from Member State customs authorities; Extrapolations 

based on Eurostat trade data.  

Page 123 / 237 

 
 
 
  
 
 
 
Estimated number of declarations per year subject to regulatory requirements covered 
by option 2     

Regulatory  requirements 
covered 

Import requirements 

CCFV import  

AGRIM 

CITES import 

Precursors 
authorisation 

Additional 
declarations† 

Total imports 

import 

import 

Export requirements 

CCFV export 

Dual use export 

CITES export 

AGREX  

Drugs precursors export  

Total exports 

Overall total 

Estimated no of declarations / year (thousands) 

625  

244  

134  

1  

50  

1 054  

814  

595  

141  

72  

19  

1 641  

2 695 

Annotation: †Combined estimated total of regulatory requirements for which data was unavailable, namely the 

Trade Surveillance Document.  

Source: Declarations and supporting documents data from Member State customs authorities;  Extrapolations 

based on Eurostat trade data 

Page 124 / 237 

 
 
 
 
 
Estimated number of declarations per year subject to regulatory requirements covered 
by option 6     

Regulatory  requirements 
covered 

Import requirements 

Estimated no of declarations / year (thousands) 

CHED-PP 

CHED-P* 

CHED-D** 

CCFV import 

Catch import  

COI 

CHED-A*** 

FLEGT 

ODS import 

estimates 

Combined 
cultural  goods 
trade surveillance document 

for 
import  and 

Total imports 

Export requirements 

CCFV export 

ODS export 

Catch export 

Cultural goods export 

Total exports 

Overall total 

972  

655  

641  

625  

417  

135  

96  

57  

13  

361 

3 971 

814  

72  

23  

20  

928  

4 899  

Annotation: *Based on figures for predecessor CVED-P;  

**Figures based on predecessor CED;  
***Figures based on predecessor CVED-A;  
†Combined estimated total of regulatory requirements for which data was unavailable, namely cultural goods 
import and the trade surveillance document. 

Source:  Declarations  and  supporting  documents  data  from  Member  State  customs  authorities;  Extrapolations  based  on 

Eurostat trade data.  

Page 125 / 237 

 
 
 
 
 
  
 
 
ANNEX 12: ANALYSIS OF THE DISCARDED POLICY OPTIONS 

Analysis of the impacts of policy options 3, 4, 5, 7 and 8(i) 

Overview  

Stakeholder 
views 

Economic impacts  Social and 

environmental 
impacts 

Category I: G2G options 

Option 3 

Option 4 

This option is similar to 
option 2, but it concerns 
national  rather  than  EU 
regulatory 
Data 
requirements. 
from  a  limited  number 
States 
of  Member 
these  could 
suggests 
of 
dozens 
cover 
regulations 
each 
in 
country  across  a  wide 
range of policy areas.  

and 

customs 
National 
have 
authorities 
expressed 
largely 
negative  views  towards 
this  policy  option.  This 
is  due  to  its  uncertain 
the 
scope 
(or 
unfeasibility 
huge 
potentially 
expense)  of  making  the 
necessary 
connections 
between a large number 
of  electronic  systems 
and 
CSW-
CERTEX.  

EU 

option  would 
This 
regulatory 
cover  EU 
requirements  for  which 
third-country 
documents are required, 
such  as  the  Certificate 
1 
of  Origin,  VI 
for  wine 
document 
the 
imports 
and 
Process 
Kimberley 
for 
Certification 
diamond imports. While 
a  number  of  examples 
were 
the 
identified, 
volume  of  electronic 
systems 
customs 
or 
declarations  that  would 
be affected is unclear. 

Given 
the  uncertain 
scope and difficulties of 
technical 
implementation, 
customs 
national 
authorities 
have 
considered this option  a 
low  priority.  There  are 
about 
doubts 
also 
legally 
it 
whether 
is 
is 
it 
since 
feasible, 
third-
unlikely 
that 
authorities 
country 
could  be  obliged 
to 
necessary 
the 
make 
connections.  

While  the  nature  of  the 
benefits  would  be  similar 
to 
those  described  for 
option  1,  these  would  be 
limited,  since  only  goods 
national 
subject 
to 
one 
requirements 
Member 
but 
dealing  with  customs  in 
another, 
be 
affected.  The  likely  costs 
would  be  very  high  in 
the  many 
of 
light 
connections needed.  

in 
State, 

would 

the 

For 
customs 
declarations subject to the 
requirements 
regulatory 
covered, 
benefits 
the 
would  be  of  a  similar 
nature  to  those  described 
for  option  1.  Since  this  is 
uncertain, the scale of the 
benefits  is  unknown.  The 
costs  are  also  hard  to 
a 
define, 
proportion 
considerable 
would  be 
incurred  by 
third-country authorities.  

though 

Category II: B2G options 

Option 5 

an  EU 

This  option  would  set 
trader 
up 
for  dealing 
platform 
regulatory 
with 
requirements 
covered 
under option 1.  

the 

Customs authorities and 
operators 
economic 
expressed 
negative 
this 
towards 
views 
option.  This  is  mainly 
since 
because, 
economic 
operators 
would  still  need  to  deal 
and 
with 
customs 
competent 
partner 
separately, 
authorities 
processes 
clearance 
were seen as unlikely to 
significantly 
be 

for 

costs 

This  option  would  entail 
considerable 
to 
develop  and  implement, 
the 
mainly 
Commission  but  also  for 
partner 
national 
and 
competent 
authorities. 
There  would  also  be 
potential 
for 
economic 
operators 
needing  to  adjust  to  the 
Some 
system. 
new 
economic  benefits  could 
be  realised,  mainly  for 
economic  operators  who 

costs 

Page 126 / 237 

to 

nature 

If 
the 
implemented, 
social  and  environmental 
benefits  would be similar 
in 
those 
described  for  option  1. 
However, 
scale 
would be limited because 
only  a  relatively  small 
customs 
of 
number 
declarations  is  likely  to 
be affected.  

their 

to 

nature 

If 
the 
implemented, 
social  and  environmental 
benefits  would be similar 
in 
those 
described  for  option  1. 
However,  their  scale  is 
impossible  to  gauge  due 
to  the  unknown  scope  of 
regulatory 
the 
requirements 
be 
covered.  

to 

to 

and 
errors 

To  a  limited  extent,  this 
option  could  be  expected 
improve  authorities’ 
to 
share 
ability 
thus 
information 
and 
reduce 
improve  enforcement 
/ 
compliance.  However, 
expectations 
such 
among 
benefits 
stakeholders 
were 
limited.  

of 

 
 
 
Overview  

Stakeholder 
views 

improved.  

Economic impacts  Social and 

environmental 
impacts 

could  deal  with  multiple 
non-customs requirements 
using  a  single  platform. 
However,  it  did  not  seem 
likely  that  these  benefits 
would  be  large  enough  to 
justify 
investment 
required.  

the 

Category III: Cross-cutting option 

Option 
8(i) 

This 
option  would 
extend  EORI  to  partner 
authorities 
competent 
registration, 
for 
and 
identification 
validation 
purposes. 
This  would  imply  the 
registration 
of 
additional 
businesses 
who  are  not  registered 
customs 
the 
with 
EORI 
authorities. 
would 
a 
registration 
common 
identification 
and 
number for customs and 
partner 
competent 
authorities  involved  in 
international trade. 

become 

presented 

Customs authorities and 
operators 
economic 
largely 
expressed 
favourable 
views 
towards opening the use 
to  partner 
of  EORI 
authorities. 
competent 
the  partner 
However, 
DGs 
a 
diversity of cases where 
of 
replacement 
the 
current 
registration 
systems by EORI would 
be  extremely  complex. 
In addition, some of the 
registration 
so 
requirements 
that 
domain 
customs 
authorities 
would  not  be  equipped 
to 
administer 
efficiently.   

are 
specific 

a 

option 

would 
This 
benefit 
particularly 
economic  operators  by 
providing 
single 
registration  mechanism 
for  customs  and  non-
formalities.  
customs 
the  EORI 
Extending 
system 
to  non-customs 
domains  for  registration 
identification 
and 
purposes  would  require 
additional 
businesses 
(including  those  based  in 
or 
third 
intra-
involved 
community 
to 
register  for  the  system. 
This might come at a cost 
of  increased  complexity 
the 
and 
limit 
thus 
economic  benefits 
that 
could be generated. 

countries 
in 
trade) 

option 

would 
This 
incremental 
provide 
social  and  environmental 
benefits  for  any  other 
would 
option 
it 
supplement. 
It  would 
information 
facilitate 
sharing  between  customs 
and  partner  competent 
authorities  and  simplify 
the procedures to enforce 
regulatory 
requirements 
across policy domains. 

Page 127 / 237 

 
 
 
 
 
 
 
 
 
ANNEX 13: COMPARISON OF ECONOMIC IMPACTS FOR ALL OPTION PACKAGES 

The following three tables summarise the comparison of the direct economic impacts for the 
different packages of options. These contain the information needed to compare the options in 
terms  of  their  likely  direct  economic  impacts  compared  to  the  continuation  of  the  baseline 
scenario. More precisely:  

  Packaging:  the  options  are  packaged  as  described  in  section  7,  meaning  that  the 
impacts shown represent the sum of those for the options included in each package.  

  Three timeframes are shown in the tables: 

o  Total  costs  and  benefits  for  years  1-7:  presents  the  sum  of  impacts  to  be 
expected  for  years  1-7,  during  which  one-off  implementation  costs  would  be 
incurred and economic benefits would be phased in for all packages comprised 
of combinations of options 1, 2, 6 and 8(ii). Since packages containing option 
7 will not realise any benefits during years 1-7, only costs are shown for these. 

o  Total costs and benefits for years 8-12: presents the sum of the impacts to be 
expected  for  years  8-12.  During  this  time,  the  packages  comprised  of 
combinations  of  options  1,  2,  6  and  8(ii)  would  be  fully  operational.  The 
figures thus show the total impacts for the first 5 years of full operation. The 
packages containing option 7 would be phased in during this time, meaning the 
total of costs incurred and gradually increasing benefits are shown. 

o  Annual costs and benefits during full operation: for all packages of options, the 
table shows the recurrent costs and full direct economic benefit that would be 
expected each year. This would be year 8 onwards for the packages comprised 
combinations of options 1, 2, 6 and 8(ii), and year 13 onwards for the packages 
containing option 7. 

  Net impact: for all three timeframes, the ‘net impact’ rows show the sum of the costs 
and benefits. The degree of uncertainty in expected impacts is taken into account by 
using  high  and  low  ranges  for  each  package  of  options.  As  shown,  the  net  impact 
varies  significantly  but  is  positive for  all packages except  those containing option 7. 
These  packages  show  negative  net  impacts  due  to  the  large  implementation  and 
recurrent costs  

  EUR  benefit  per  EUR  spent:  to  help  illustrate  differences  in  the  expected  value  for 
money  of  the  option  packages,  the  last  rows  show  the  benefit  of  each  EUR  spent. 
Values  greater  than  one  depict  net  benefits,  while  values  less  than  one  depict  net 
negative impacts (since EUR 1 achieves less than EUR 1 in benefit).  

Page 128 / 237 

 
Table 20: Comparison of the total benefits and costs for years 1-7147 

Total costs and benefits for 
years 1-7 

Costs 
(€m, low and 
high ranges 
except for 
EC costs) 

EC 
MS authorities 

EOs 

Total 

Benefits 
(€m, low and 
high ranges) 

MS customs  

MS PCAs 

EOs 

Total 

Net impact (€m, low and high 
ranges) 

EUR benefit per EUR spent 

Packages of options for G2G collaboration only 

Packages of options for G2G and B2G cooperation 

1 

1+2 

1+8(ii) 

1+2+8(ii) 

1+6 

1+2+6 

1+6+8(ii) 

1+2+6+8(ii) 

1+7 

1+2(i)+7 

1+7+8(ii) 

28.7  
14.4  
28.7  
0.0  
0.0  
43.1  
57.4  
173.4  
260.1  
11.6  
28.9  
173.4  
260.1  
358.3  
549.1  
300.9  
506.0  
6.2  
12.8  

63.7  
56.4  
112.7  
0.0  
0.0  
120.1  
176.4  
230.0  
335.5  
19.1  
47.8  
230.0  
335.5  
479.1  
718.9  
302.7  
598.8  
2.7  
6.0  

29.7  
15.4  
29.7  
0.0  
0.0  
45.1  
59.5  
177.7  
266.6  
11.8  
29.6  
177.7  
266.6  
367.3  
562.8  
307.8  
517.7  
6.2  
12.5  

64.7  
57.4  
113.7  
0.0  
0.0  
122.1  
178.5  
235.7  
343.9  
19.6  
49.0  
235.7  
343.9  
491.1  
736.8  
312.6  
614.7  
2.8  
6.0  

63.7  
63.4  
126.7  
0.0  
0.0  
127.1  
190.4  
207.7  
328.7  
25.3  
63.2  
482.0  
671.6  
715.0  
1 063.5  
524.6  
936.4  
3.8  
8.4  

98.7  
105.4  
210.7  
0.0  
0.0  
204.1  
309.4  
264.3  
404.1  
32.8  
82.1  
538.6  
747.1  
835.7  
1 233.3  
526.3  
1 029.2  
2.7  
6.0  

64.7  
64.4  
127.7  
0.0  
0.0  
129.1  
192.5  
212.9  
336.9  
25.9  
64.8  
494.1  
688.4  
732.9  
1 090.1  
540.4  
961.0  
3.8  
8.4  

99.7  
106.4  
211.7  
0.0  
0.0  
206.1  
311.5  
270.9  
414.2  
33.6  
84.1  
552.1  
765.8  
856.6  
1 264.1  
545.2  
1 058.0  
2.8  
6.1  

4 028.7  
4 000.0  
9 333.3  
0.0  
0.0  
8 028.7  
13 362.0  
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
-13 362.0  
-8 028.7  
0.0  
0.0  

4 063.7  
4 084.0  
9 417.3  
0.0  
0.0  
8 147.7  
13 481.0  
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
-8 147.7  
-8 147.7  
0.0  
0.0  

4 029.7  
4 001.0  
9 334.4  
0.0  
0.0  
8 030.8  
13 364.1  
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
-13 364.1  
-8 030.8  
0.0  
0.0  

Table 21: Comparison of the total benefits and costs for years 8-12 

Total costs and benefits years 
8-12 

Costs 
(€m, low and 
high ranges 
except for 
EC costs) 

EC 
MS authorities 

EOs 

Total 

Packages of options for G2G collaboration only 

Packages of options for G2G and B2G cooperation 

1 

1+2 

1+8(ii) 

1+2+8(ii) 

1+6 

1+2+6 

1+6+8(ii) 

1+2+6+8(ii) 

1+7 

1+2(i)+7 

1+7+8(ii) 

16.4  
8.2  
16.4  
0.0  
0.0  
24.6  
32.8  

36.4  
32.2  
64.4  
0.0  
0.0  
68.6  
100.8  

16.8  
8.6  
16.8  
0.0  
0.0  
25.3  
33.5  

36.8  
32.6  
64.8  
0.0  
0.0  
69.3  
101.5  

31.4  
29.2  
58.4  
0.0  
0.0  
60.6  
89.8  

51.4  
53.2  
106.4  
0.0  
0.0  
104.6  
157.8  

31.8  
29.6  
58.8  
0.0  
0.0  
61.3  
90.5  

51.8  
53.6  
106.8  
0.0  
0.0  
105.3  
158.5  

2 302.1  
2 285.7  
5 333.3  
700.0  
1 400.0  
5 287.8  
9 035.4  

2 322.1  
2 333.7  
5 381.3  
700.0  
1 400.0  
5 355.8  
9 103.4  

2 302.5  
2 286.1  
5 333.7  
700.0  
1 400.0  
5 288.5  
9 036.1  

1+2(i)+7+8(ii) 
4 064.7  
4 085.0  
9 418.4  
0.0  
0.0  
8 149.8  
13 483.1  
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
-13 483.1  
-8 149.8  
0.0  
0.0  

1+2(i)+7+8(ii) 
2 322.5  
2 334.1  
5 381.7  
700.0  
1 400.0  
5 356.5  
9 104.1  

 147  Given that option 7 would replace existing EU customs systems with a single centralised system, this would be combined with a simplified version of option 1 that entails a single connection of EU 

CSW-CERTEX to the option 7 system. Similarly, it would only be feasible to implement option 7 alongside the direct connection version of option 2 (i.e. 2(i)).   

Page 129 / 237 

 
  
 
                                                 
Benefits 
(€m, low and 
high ranges) 

MS customs  

MS PCAs 

EOs 

Total 

Net impact (€m, low and high 
ranges) 

EUR benefit per EUR spent 

247.7  
371.5  
16.5  
41.3  
247.7  
371.5  
511.9  
784.4  
479.1  
759.8  
15.6  
31.9  

328.6  
479.4  
27.3  
68.2  
328.6  
479.4  
684.4  
1 026.9  
583.6  
958.3  
6.8  
15.0  

253.9  
380.8  
16.9  
42.3  
253.9  
380.8  
524.7  
804.0  
491.2  
787.2  
15.7  
31.8  

336.8  
491.3  
28.0  
69.9  
336.8  
491.3  
701.5  
1 052.6  
600.0  
987.9  
6.9  
15.2  

296.7  
469.5  
36.1  
90.3  
688.6  
959.5  
1 021.4  
1 519.3  
931.6  
1 458.7  
11.4  
25.1  

377.5  
577.3  
46.9  
117.2  
769.5  
1 067.3  
1 193.9  
1 761.8  
1 036.1  
1 657.2  
7.6  
16.8  

304.1  
481.3  
37.0  
92.5  
705.9  
983.4  
1 047.0  
1 557.3  
956.5  
1 496.0  
11.6  
25.4  

387.0  
591.8  
48.1  
120.2  
788.7  
1 093.9  
1 223.8  
1 805.9  
1 065.3  
1 700.6  
7.7  
17.1  

148.3  
234.8  
18.1  
45.1  
344.3  
479.7  
510.7  
759.6  
-8 524.7  
-4 528.2  
0.1  
0.1  

188.8  
288.7  
23.4  
58.6  
384.7  
533.6  
597.0  
880.9  
-8 506.5  
-4 474.9  
0.1  
0.2  

152.1  
240.6  
18.5  
46.3  
352.9  
491.7  
523.5  
778.6  
-8 512.7  
-4 509.9  
0.1  
0.1  

193.5  
295.9  
24.0  
60.1  
394.4  
547.0  
611.9  
902.9  
-8 492.3  
-4 453.6  
0.1  
0.2  

Table 22: Comparison of the annual benefits and costs during full operation 

Annual costs and benefits 
during full implementation 

Costs 
(€m, low and 
high ranges 
except for 
EC costs) 

EC 
MS authorities 

EOs 

Total 

Benefits 
(€m, low and 
high ranges) 

MS customs  

MS PCAs 

EOs 

Total 

Net impact (€m, low and high 
ranges) 

EUR benefit per EUR spent 

Packages of options for G2G collaboration only 

Packages of options for G2G and B2G cooperation 

1 

1+2 

1+8(ii) 

1+2+8(ii) 

1+6 

1+2+6 

1+6+8(ii) 

1+2+6+8(ii) 

1+7 

1+2(i)+7 

1+7+8(ii) 

3.3  
1.6  
3.3  
0.0  
0.0  
4.9  
6.6  
49.5  
74.3  
3.3  
8.3  
49.5  
74.3  
102.4  
156.9  
95.8  
152.0  
15.6  
31.9  

7.3  
6.4  
12.9  
0.0  
0.0  
13.7  
20.2  
65.7  
95.9  
5.5  
13.6  
65.7  
95.9  
136.9  
205.4  
116.7  
191.7  
6.8  
15.0  

3.4  
1.7  
3.4  
0.0  
0.0  
5.1  
6.7  
50.8  
76.2  
3.4  
8.5  
50.8  
76.2  
104.9  
160.8  
98.2  
157.4  
15.7  
31.8  

7.4  
6.5  
13.0  
0.0  
0.0  
13.9  
20.3  
67.4  
98.3  
5.6  
14.0  
67.4  
98.3  
140.3  
210.5  
120.0  
197.6  
6.9  
15.2  

6.3  
5.8  
11.7  
0.0  
0.0  
12.1  
18.0  
59.3  
93.9  
7.2  
18.1  
137.7  
191.9  
204.3  
303.9  
186.3  
291.7  
11.4  
25.1  

10.3  
10.6  
21.3  
0.0  
0.0  
20.9  
31.6  
75.5  
115.5  
9.4  
23.4  
153.9  
213.5  
238.8  
352.4  
207.2  
331.4  
7.6  
16.8  

6.4  
5.9  
11.8  
0.0  
0.0  
12.3  
18.1  
60.8  
96.3  
7.4  
18.5  
141.2  
196.7  
209.4  
311.5  
191.3  
299.2  
11.6  
25.4  

10.4  
10.7  
21.4  
0.0  
0.0  
21.1  
31.7  
77.4  
118.4  
9.6  
24.0  
157.7  
218.8  
244.8  
361.2  
213.1  
340.1  
7.7  
17.1  

460.4  
457.1  
1 066.7  
0.0  
0.0  
917.6  
1 527.1  
59.3  
93.9  
7.2  
18.1  
137.7  
191.9  
204.3  
303.9  
-1 322.8  
-613.7  
0.1  
0.3  

464.4  
466.7  
1 076.3  
0.0  
0.0  
931.2  
1 540.7  
75.5  
115.5  
9.4  
23.4  
153.9  
213.5  
238.8  
352.4  
-1 300.3  
-574.0  
0.2  
0.4  

460.5  
457.2  
1 066.7  
0.0  
0.0  
917.7  
1 527.2  
60.8  
96.3  
7.4  
18.5  
141.2  
196.7  
209.4  
311.5  
-1 316.2  
-606.3  
0.1  
0.34  

1+2(i)+7+8(ii) 
464.5  
466.8  
1 076.3  
0.0  
0.0  
931.3  
1 540.8  
77.4  
118.4  
9.6  
24.0  
157.7  
218.8  
244.8  
361.2  
-1 294.4  
-565.3  
0.2  
0.39  

Page 130 / 237 

 
 
 
  
ANNEX 14: EVALUATION OF THE EU CSW-CVED PILOT AND EU CSW-CERTEX PROJECT 

Introduction 

This section presents the evaluation of the “EU Customs Single Window CVED pilot” since 
its  launch  in  2015.  Its  successor,  the  EU  Customs  Single  Window-CERTificate  Exchange 
project  (EU  CSW-CERTEX)  project  is  in  an  early  stage  of  implementation.  To  the  extent 
possible, the EU CSW-CERTEX has also been considered in the evaluation.  

The  state  of  play  in  term  of  coverage  and  participation  in  the  pilot  and  its  successor  are 
presented in the box below.  

Box 9: Subject of the evaluation 

The scope and state of play of the initiative evaluated is as follows. 

e)  The EU Customs Single Window CVED pilot (EU CSW-CVED pilot) which 
allows customs authorities to automatically verify three supporting documents 
was launched in 2015 and covered: 

  CED  (Common  Entry  Document)  for  imports  of  feed  and  food  of  non-

animal origin 

  CVED-A  (Common  Veterinary  Entry  Document  Animals)  for  imports  of 

animals 

  CVED-P  (Common  Veterinary  Entry  Document  Products)  for  imports  of 

products with animal origin 

f)  Its successor, known as the EU CSW-CERTEX project (CERTificate EXchange 
project), expanded the scope of regulatory requirements to include (as at 2019):   

  CHED-PP  (Common  Health  Entry  Document  for  Plant  Protection)  for 

plants, plant products and plant propagating material  

  FLEGT  (Forest  Law  Enforcement,  Government  and  Trade)  for  imports  of 

timber 

  COI (Certificate of Organic Inspection) for imports of organic products 

Further  expansion  is  foreseen  encompassing  the  following  regulatory  requirements: 
ODS  (Ozone-Depleting  Substance);  F-GAS  licences;  dual  use  export  licenses  of  the 
Directorate-General  for  Trade  (DG TRADE), while more (including non-food product 
safety  and  compliance,  market  surveillance148)  are  under  discussion.  In  addition, 
Regulation  (EU) 2019/1020 of the European Parliament and of the Council on market 
surveillance  and  compliance  of  products,  which  aims  to  upgrade  compliance  and 
enforcement  rules  for  products  covered  by  EU  legislation,  provides  for  linkages  and 
data  transfer  between  national  customs  systems  and  the  EU  information  database  for 
market surveillance (ICSMS) through the EU Single Window environment for customs. 
The electronic interface should be in place within four years following the adoption of 
the required implementing legislation. It will initially be developed in the context of the 
EU CSW-CERTEX project. 

148   Regulation (EU) 2019/1020 of the European Parliament and of the Council on market surveillance and compliance of 
products, which intends to upgrade compliance and enforcement rules for products covered by EU legislation, provides 
for  linkages  and  data  transfer  between  national  customs  systems  and  the  EU  information  database  for  market 
surveillance  (ICSMS)  through  the  EU  Single  Window  environment  for  customs  The  electronic  interface  should be  in 
place within four years following the adoption of the required implementing legislation. It will initially be developed in 
the context of the EU CSW-CERTEX project. 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2019.169.01.0001.01.ENG&toc=OJ:L:2019:169:TOC) 

Page 131 / 237 

 
 
 
                                                 
 
The geographical coverage of the pilot and its successor is as follows:  

1.  Bulgaria (2015) 
2.  Latvia (2015) 
3.  Slovenia (2015) 
Ireland (2015) 
4. 
5.  Czechia (2015) 
6.  Cyprus (2016) 
7.  Poland (2016) 
8.  Estonia (2017) 
9.  Portugal (2019) 

France  is  planning  to  join  EU  CSW-CERTEX  and  is  making  the  necessary  technical 
arrangements. Belgium has also decided to join the EU CSW-CERTEX project and has 
started taking steps in terms of IT developments. Other Member States have signalled a 
desire to join.  

The purpose of this evaluation is to provide evidence for the study for the impact assessment. 
More specifically, by investigating the pilot’s relevance, effectiveness (insofar as is relevant 
given  the  pilot  nature  of  the  initiative),  efficiency,  coherence  and  EU  added  value,  the 
evaluation  helps  understand  the  nature  and  scale  of  the  existing  problems  and  how  the 
situation  would  likely  evolve  without  further  intervention  (i.e.  the  baseline  scenario).  By 
providing  insight  into  such  areas  as  reasons  for  participating  or  not  participating,  costs 
incurred and experiences so far, the evaluation also provides useful insight for the analysis of 
the likely impacts of the policy options.  
When reading the evaluation findings, it should be borne in mind that EU CSW-CVED was a 
pilot,  with  a  scope  of  just  three  reporting  obligations  (CVED-A,  CVED-P  and  CED)  and 
voluntary participation (of five Member States in  2015, rising to  eight  by  the  end of 2017). 
This allowed it to play a valuable role in testing the viability of the concept and allowing for 
some experimentation before expanding its scope and rolling it out to all Member States. At 
the  same  time,  the  pilot  nature  of  EU  CSW-CVED  has  also  limited  its  potential  to  address 
existing problems and generate benefits for customs authorities, partner competent authorities 
and economic operators. This was expected and is reflected in the terms in which EU CSW-
CVED is judged in the ensuing sub-sections.  

As a reference point for the analysis, we have developed a summary of the intervention logic 
of  the  pilot  (and  its  successor).  This  is  a  high-level  summary  connecting  the  needs,  inputs, 
activities  to  the  initial  results,  specific  purpose  and  overall  objective.  Where  relevant  we 
distinguish between the functional results / objective and the pilot results / objective. 

Page 132 / 237 

 
 
 
 
Table 23: Simplified intervention logic of the pilot initiative 

Needs 

Inputs 

Activities 

Initial results 

Specific 
purpose 

Overall 
objective 

Development  and 
implementation of 
links  between  DG 
TAXUD 
middleware 
and 
(1)  DG  SANTE’s 
database 
(TRACES) 
(2) 
customs 
systems  

and 
national 
IT 

improve 

To 
coordination 
between  customs 
and  non-customs 
authorities  

and 
Financial 
resources 
human 
from 
the 
Commission  and 
Member States  

More 
integrated, 
faster  and  simpler 
paperless 
processes 
goods clearance   

for 

More 
effective 
implementation of 
key  non-customs 
EU regulations  

Initial results:  

for 

and 

System 
electronic 
exchange 
of 
CVED-A,  CVED-
CED 
P 
documents   
between  customs, 
partner  competent 
authorities 
and 
DG  SANTE  via 
DG 
TAXUD 
middleware. 

Pilot results: 

from 

Learning 
implementation 
experience  (needs 
of 
and 
users 
practical 
implementation 
challenges) 

of 

digital 
to 

Use 
technologies 
coordinate 
government 
processes 
to 
ensure  a  secure 
sustainable 
and 
for 
environment 
parties 
all 
involved 
in 
international 
trade. 

Functional 
objective:  

a)  more 

effective and 
efficient 
implementati
on of EU 
rules and 
regulations 

improved 
coordinatio
n between 
customs and 
non-
customs 
authorities 

b) 

c)  moving 
from the 
paper flow 
to digital 
environmen
t 

Pilot objective: 

develop 
an 
understanding  of 
the viability of the 
to 
approach 
automated 
exchange between 
customs  and  non-
customs 
authorities 

The  intervention  logic  for  the  EU  CSW-CERTEX  project  is  the  same,  but  has  an  expanded  scope  of  more 
regulatory requirements and additional functionalities, such as EU-wide quantity management. 

Source: DG TAXUD  

Sources of evidence 

The evaluation relies on essentially the same sources of evidence as the rest of the study for 
the impact assessment. As a starting point, it used existing sources, such as the legal text for 
the paperless environment for customs and trade149, the Evaluation of the electronic customs 
implementation in the EU150 and the EU CSW-CERTEX project business case151. These were 
based on extensive consultation about the pre-existing situation, and thereby provide evidence 
of the project’s underlying rationale (i.e. relevance). Additional evidence was gathered from: 

a)  Field visits to eight Member States, which facilitated the collection of first-hand views 
and experiences of national authorities in participating and non-participating countries. 

149   Decision No70/2008/EC of the European Parliament and of the Council of 15 January 2008 on a paperless environment 

for customs and trade, OJ L 23, 26/01/2008, p. 21-26. 

150   Evaluation  of 

the  electronic  customs 

implementation 

in 

the  EU  Final 

report 

(21 

January  2015), 

https://ec.europa.eu/taxation_customs/sites/taxation/files/docs/body/ecust_evaluation_final_en.pdf  

151   Business Case – EU Customs Single Window: Certificates exchange (December 2016). 

Page 133 / 237 

 
 
 
 
 
                                                 
b)  A  questionnaire  sent  to  project  group  members  for  feedback  on  the  rationale  for 
joining  or  not  joining,  as  well  as  experiences  so  far,  especially  costs  of  joining  (i.e. 
one-off  implementation  and  maintenance  costs)  and  benefits  (i.e.  savings  from 
reduced amounts of labour needed to deal with goods clearance). 

c)  Interviews  carried  out  with  different  Commission  officials  working  with  various 
regulatory requirements, which provided an up-to-date understanding of the utility of 
the project for different reporting requirements. 

d)  The views gathered from economic operators through targeted interviews and the open 

public consultation are included. 

e)  Available data on the volumes of declarations requiring CED, CVED-A and CVED-P 
for four participating countries (Czechia, Estonia, Ireland and Latvia) were combined 
with  qualitative  information  to  make  estimations  on  time  saved  for  different 
stakeholders in our assessment of the efficiency of the EU CSW CVED pilot. 

f)  Relevant  data  from  the  EU  Customs  Single  Window  Architecture  Evolution  and 
Change  Management  Policy  project  provides  insights  from  stakeholder  consultation 
with Member State custom authorities focused on the technicalities of implementation. 

Relevance 

To what extent do the EU CSW-CVED pilot and EU CSW-CERTEX project correspond to the 
needs of stakeholders, namely (different types of) economic operators and public authorities? 

Coverage of question 

This question assesses the EU CSW-CVED pilot and EU CSW-CERTEX project’s capacity 
to  address  needs  of  different  stakeholders.  The  two  initiatives  aim  to  address  the  need  for 
synchronisation of digitalisation efforts of the Member States and the European Commission 
in the customs area. As clarified in the introduction, as a pilot, EU CSW-CVED entails testing 
the  concept  of  digital  verification  of  the  supporting  documents  issued  by  the  partner 
competent  authorities  other  than  customs,  which  are  required  to  support  the  customs 
declaration  of  certain  goods.  This  technical  solution  aims  to  address  a  need  to  improve 
coordination  between  customs  and  non-customs  authorities  for  greater  efficiency  and 
effectiveness in the implementation of EU regulation. The needs of economic operators are, 
likewise, related to  faster, simpler and more integrated processes for the clearance of goods 
affected  by  non-customs  regulatory  requirements.  The  relevance  question  is  focused  on 
assessing how appropriate the technical solution is, in terms of its functionalities and scope. A 
separate question (see question 3) deals specifically with an assessment of the effectiveness of 
the EU CSW-CVED pilot and EU CSW-CERTEX project in achieving the objectives. 

Evidence base 

This question draws on the existing documentary sources mentioned in the introduction, and 
consultation with stakeholders in both participating and non-participating Member States. The 
assessment  of  relevance  is  based  mainly  on  qualitative  data  relating  to  the  problems 
experienced  by  Member  States  and  the  extent  to  which  the  EU  CSW-CVED  pilot  and  EU 
CSW-CERTEX project are designed in  a way that can address these problems. Quantitative 
data on declaration volumes is used to assess the scale of the EU CSW-CVED pilot and EU 
CSW-CERTEX project in relation to other reporting obligations facing economic operators. It 
is important to remember that the EU CSW-CVED pilot and EU-CSW-CERTEX project aim 
to test an approach as this provides context for how far they can meet stakeholders’ needs.  

Answer to evaluation question 

Page 134 / 237 

 
 
The problem consistently experienced by those involved in the import and export of goods is 
that  of  insufficiently  coordinated  and  inefficient  goods  clearance  processes.  While  the 
specificities  and  scale  of  the  problem  vary  by  Member  State  and  regulatory  requirement, 
customs authorities, partner competent authorities and economic operators trading in Member 
States are affected. The implications of these inefficiencies include duplication of information 
and procedural redundancies as systems do not “speak to” one another, paper is passed from 
one authority to another, different authorities request the same information, and so on. 

Participating countries were asked about the relevance of the EU CSW-CVED pilot to address 
their needs. They confirmed that from a functional point of view, the pilot addressed the basic 
need  for  more  efficient  goods  clearance  and  coordinated  automated  checks  between 
supporting documents and customs declarations. For the reporting formalities covered in the 
pilot, there is now the possibility for automated checks. According to stakeholders, the need 
for  automated  checks  was  particularly  important  for  goods  being  traded  in  higher  volume 
when the time for manual exchange of data and checks was cumulatively more onerous (with 
the  opposite  true  in  the  case  of  smaller  import/export  volumes)152.  Participating  Member 
States  also  confirmed  that  through  the  new  approach,  the  competent  authorities  were 
coordinated in a way that was previously not possible (i.e. when they used systems that were 
not  designed  to  share  information  between  each  other).  This  addresses  the  need  for  greater 
coordination between authorities.  

The  perceived  relevance  of  the  EU  CSW-CERTEX  project,  is  in  part  demonstrated  by  the 
desire and willingness to join among Member States. In addition to the nine Member States 
already  engaged,  others,  such  as  France,  Belgium,  Malta,  Lithuania,  and  Luxembourg  are 
actively  planning  to  join,  some  of  whom  have  been  enticed  by  technical  improvements 
introduced  over  time153.  Some  other  Member  States  (such  as  the  Netherlands,  Spain  and 
Germany)  foresee  joining  once  certain  functionalities  are  available,  or  participation  has 
reached a sufficient threshold. 

Similarly, at the EU level, an increasing number of DGs are also investigating the possibility 
to join the EU CSW-CERTEX project154. The increasing number of Member States and DGs 
interested  in  joining  the  project  further  serves  as  evidence  of  the  ability  of  the  approach  to 
meet the needs of stakeholders. 

In line with the pilot nature and limited scope of the EU CSW-CVED pilot and the EU CSW-
CERTEX project  there are limitations to the extent  to  which (with their current  scope) they 
can fully satisfy stakeholders’ needs. More concretely, the number of regulatory requirements 
covered  corresponds  to  only  about  a  third  of  the  import  declarations  requiring  supporting 
documents from non-customs EU legislation each year.  

Beyond  the  scope,  the  experience  from  the  pilot  and  successor  project  provide  information 
about  what  unfilled needs remain and what  needs should be considered for future planning. 
Both participating and non-participating Member States cited the following (unmet) needs: 

  The  connection  currently  only  allows  national  authorities  to  “poll”  available 
information  from  TRACES  (i.e.  authorities  need  to  electronically  and  periodically 

152   This was the case for “FLEGT” (Council Regulation (EC) No 2173/2005 of 20 December 2005 on the establishment of 
a FLEGT licensing scheme for imports of timber into the European Community) in Ireland, where the volume of timber 
imports is not high enough to justify the inclusion of this reporting requirement. 

153   For  instance,  while  the  EU  CSW-CVED  pilot  did  not  initially  correspond  to  national  authorities’  need  to  be  able  to 
retrieve  the  full  supporting  document  in  a  universally  readable  format,  this  functionality  has  been  added  for  the  EU 
CSW-CERTEX  project.  The  introduction  of  this  function  in  2018  was  one  of  the  determining  factors  in  France’s 
decision to join for example. 

154   DG  SANTE  (CVED-A,  CVED-P  and  CED),  DG  ENV  (FLEGT),  DG  AGRI  (COI)  are  already  involved,  while  DG 

MARE (IUU), DG CLIMA (ODS and F GASES) are preparing to join. 

Page 135 / 237 

 
 
                                                 
send  a  request  to  TRACES  for  updated  information).  This  means  that  authorities  do 
not  have  continuously  updated  information  from  TRACES.  It  would  be  similar  to 
having  to  input  your  inbox  every  few  hours  and  not  simply  getting  an  alert  when  a 
new  email  comes  in.  Member  States  would  be  interested  in  the  possibility  to 
automatically exchange information with TRACES, enabling updates in real time. 

  EU-level quantity management is not possible in the current system (it would require 
for  all  Member  States  to  be  using  the  system  and  for  the  system  to  be  updated 
continuously  in  real  time),  meaning  that  authorities  must  manually  check  whether  a 
supporting  document  has  already  been  depleted.  Having  manual  checks  makes 
fraudulent  reuse  of  documents  possible,  as  there  is  no  strict  one-to-one  relationship 
between a supporting document and a customs declaration. 

The lack of quantity management was also cited as a problem by EU authorities as well. For 
instance, for DG CLIMA, the value of the EU  CSW-CERTEX project  is  limited if it is  not 
mandatory  for  all  Member  States,  as  quantity  management  would  be  less  useful  since  the 
quota system applies EU-wide and not at national level. Phasing down of F-gas via quotas as 
part of the EU’s commitment to contribute to global reductions in Fgases which are extremely 
harmful  to  the  environment  have  led  to  large  price  increases,  which  on  one  hand  promote 
innovation,  but  on  the  other  provide  an  incentive  for  illegal  activities  and  (potential  fraud), 
according  to  an  NGO  study.155  A  European  Commission  study  on  the  same  issue  found 
similarly that custom controls are relevant and need to be intensified, because any amount of 
HFCs  coming  into  the  EU  outside  the  HFC  quota  system  has  the  potential  of  reducing 
environmental benefits and leads to unfair competition.156 

For economic operators in particular, the digital connection between government authorities is 
a step in the right direction to meet their needs157. However, these connections do not allow 
processes  to  be  simplified  fully.  For  instance,  economic  operators  continue  to  face  the 
requirement  for  paper  documents  to  be  filed  (alongside  the  digital  processes).  According  to 
stakeholders  consulted,  a  legislative  framework  to  give  digital  signatures  legal  value  would 
mean  that  electronic  supporting  documents  could  be  used  at  the  EU  level,  avoiding  the 
duplication with paper documents. 

Conclusion  

The evaluation confirms that the EU CSW-CVED pilot and EU CSW-CERTEX project are in 
line with the needs of stakeholders in terms of more efficient goods clearance and coordinated 
automated checks  between supporting documents and customs declarations. While there are 
limitations to  the relevance which relate to  the pilot  nature of the solutions to  date. As new 
functionalities  are  introduced,  and  coverage  of  regulatory  requirements  is  projected  to 
increase  so  too  does  the  relevance.  Nevertheless,  understanding  what  needs  remain  unmet 
these are gives insight into the continued problems facing different stakeholders: 

a)  EU quantity management is needed to close enforcement gaps and remains impossible 

without full mandatory participation of all Member States.  

155   Door wide open, Environment  
156   https://ec.europa.eu/clima/sites/clima/files/f-gas/legislation/docs/report_illegal_trade_hcf_en.pdf 
157   Indeed, five trade associations, whose members represent economic operators dealing with border formalities on a daily 
basis,  were  consulted  regarding  the  relevance  of  EU  CSW-CVED  pilot  and  confirmed  that  broadly  the  developments 
were  in  line  with  their  needs  for  more  efficient  goods  clearance  processes.  The  organisations  interviewed  were:  Easy 
Frontier, International Port Community System Association (IPCSA), Dow Benelux B.V. (in representation of European 
Chemical Industry Council - CEFIC), World Shipping Council, and European Liaison Committee of Common Market 
Forwarders (CLECAT). 

Page 136 / 237 

 
 
                                                 
b)  Upgrades to the connections between systems would be required to allow for real time 

continuous updates (rather than periodic polling).  

c)  The  continued  need  for  economic  operators  to  provide  paper  documents  alongside 
digital ones limits the benefits economic operators can realise but resolving the issue 
would require a legislative framework giving digital signatures legal value.  

Effectiveness 

To what extent has the EU CSW-CVED pilot project been implemented as planned? 

Coverage of the question 

This  question  assesses  the  implementation  process  of  delivering  the  EU  CSW-CVED  pilot, 
and experiences of this process from participating Member States.  

Evidence base 

This  question  draws  on  the  experiences  of  the  nine  Member  States  participating  in  the  EU 
CSW-CERTEX  project  to  date158.  Specifically,  Member  States  were  asked  to  answer 
questions about their experiences of implementation in a written questionnaire shared with the 
project group. 

Answer to evaluation question 

For the most part, the EU CSW-CVED pilot was implemented as planned, with no significant 
issues  identified.  Certain  participating  Member  States  reported  the  process  to  have  been 
smooth  and  without  incidence.  This  was  the  case  for  Czechia  and  Ireland  who  were  early 
joiners (2015), and two later joiners: Estonia and Portugal. 

Notwithstanding  the  overall  positive  experience,  feedback  from  customs  authorities 
participating  in  the  project  group  also  shows  some  lessons  could  be  learned  from  the 
implementation process itself. Experiences of this process were not uniformly seamless. The 
reasons  for  this  varied  but  can  be  summarised  as  teething  problems.  For  instance,  the  key 
issues reported were: 

a)  delays  in  providing  details  for  conformance  testing  for  necessary  IT  developments 

(cited to have been an issue in Poland) and/or  

b)  incomplete  technical  specifications,  which  created  issues  for  IT  resource  planning 

within Member States (as was the case in Ireland and Cyprus).  

Both  Cyprus  and  Poland  commented  on  the  additional  costs  incurred  for  countries  piloting 
systems, as adjustments are made, which are not necessarily “backward compatible”159. The 
precise figures for additional costs were not available.  

Similarly,  the  lack  of  robust  technical  release  plans  was  reported  to  have  slowed  down 
implementation  in some cases and made it difficult  for benefits  to  be realised initially. This 
was reported to be the case in  Ireland, Latvia and Cyprus. For instance, Latvian authorities, 
while positive about the introduction of the PDF functionality found mismatches between this 
and electronic versions of CED/CVED documents.  

158   Bulgaria, Latvia, Slovenia, Ireland, Czechia, Cyprus, Poland, Estonia, France and Portugal. 
159   Backward compatible refers to the need for developments to consider the requirements of existing systems – i.e. not to 
require  a  complete  overhaul  of  existing  systems  but  to  consider  how  to  develop  systems  which  are  compatible  with 
previous systems. 

Page 137 / 237 

 
 
                                                 
These experiences show that – in line with its purpose - the pilot was a learning experience for 
Member  States,  and  the  Commission.  But  it  also  provides  ideas  and  insights  into  how  to 
manage  future  developments,  as  follows:  the  importance  of  maintaining  parallel  systems 
alongside  new  solutions,  as  well  as  planning  in  backward  compatibility,  was  stressed  as 
crucial for future upgrades or developments. Member States also emphasised the importance 
of  sharing  the  integration  guidance  document  prepared  by  the  Commission  ahead  of 
conformance  testing  to  help  them  with  smooth  implementation160.  Teething  problems  can  – 
and  in  some  case  did  –  have  a  detrimental  impact  on  economic  operators  who  experienced 
delays and a lack of predictability in clearance processes. 

Conclusion 

Implementation  proceeded  with  varying  degrees  of  ease  for  the  different  Member  States 
involved to date, but for the most part proceeded as planned.  

In line with the pilot nature of the project, some customs authorities reported facing specific 
issues which can be summarised as “teething problems”. These are actually useful as lessons 
that can be learned for future participants and confirm the importance of having a pilot.  

The main take-away lessons learnt related to:  

a)  ensuring backward compatibility to minimise costs of additional functionalities; 

b)  maintenance of parallel back-up systems to minimise disruption; and  

c)  sharing  integration  guidance  ahead  of  conformance  testing  to  facilitate  smooth 

implementation. 

160   Survey result from “EU Customs Single Window Architecture Evolution and Change Management Policy project”. 

Page 138 / 237 

 
 
 
 
                                                 
To what extent have the EU CSW-CVED pilot and the EU CSW-CERTEX project delivered on 
their objectives and expected outcomes in line with their scope? 

Coverage of question 

This question looks at whether the EU CSW-CVED pilot and EU CSW-CERTEX project are 
delivering on their objectives and expected outcomes. The objective  of the EU CSW-CVED 
pilot  and  the  EU  CSW-CERTEX  project  was  to  test  the  viability  of  the  idea  to  have 
automated checks  of supporting documents  by customs for a limited number of  certificates. 
The EU CSW-CVED pilot and EU CSW-CERTEX project have not (yet) fully replaced the 
previous systems. Building on the simplified intervention logic provided in the introduction, 
the  expected  outcomes  for  different  stakeholders  are  as  presented  in  Figure  19  below.  This 
question looks at the outcomes that relate to functionality of the solution (i.e. harmonisation 
of  technical  requirements)  for  the  limited  number  of  certificates  covered  and  the  indirect 
benefits  (i.e.  coordination  between  competent  authorities  and  increased  safety  through 
reduced possibility for fraud). A separate question (see question 4) deals specifically with an 
assessment of costs and time-saving benefits.  

Figure 19: Expected outcomes from the EU CSW-CERTEX project 

EU LEVEL 

•  More  efficient  and  less  burdensome  cargo  border  control  formalities  as  a  result  of  breaking 
down silos across the sectors, thus meeting the demands and expectations of stakeholders. 

•  Optimised  procedures  for  verification  of  supporting  documents  in  the  EU,  making  use  of 
electronic data processing techniques. 

•  Facilitated application and interpretation of the EU legislation in an effort to integrate business 
processes uniformly at a national level. 

• Reduced  potential  for  fraud  through  enforcement  of  presentation  and  control  of  an  electronic 
supporting document in an EU database rather than only on paper. 

•  Reduced potential for fraud through the quantity management functionality, which records the 
already used slots of the quota allowed by a supporting document. 

•   Reputation  gains  –  the  European  Commission  acts  as  one  fully  integrated  and  centrally 
managed system for the Member States, which is helpful for the national authorities and could 
create a positive perception for trade. 

NATIONAL LEVEL 

•  Automated  verification  of  supporting  documents  directly  from  the  data  source,  allowing 
automatic cross-checks and decreasing the need for human interaction. This can lead to gains in 
quality improvement and cost reduction. 

•  Greater  effectiveness  and  better  working  practices  between  the  competent  border  control 
authorities,  positively  impacting  the  speed  of  service  provided  to  the  stakeholders  and 
facilitating the reputation gains for the national border control authorities. 

•  Reduced  risk  of  human  error  or  misconduct  through  the  automatisation  of  supporting 
documents' checks. 

ECONOMIC OPERATORS 

•  Elimination of the need to submit the supporting document issued by a competent authority to a  
national customs authority; hence, gains in time and human resources. 
•  Faster customs controls. 
•  Improved time-to-market. 
•  Reduced risk of human errors for the economic operator. 

Source: EU CSW-CERTEX business case 

Page 139 / 237 

 
 
 
Evidence base 

Again, the evidence to date is limited to the scope of the EU CSW-CVED pilot and EU CSW-
CERTEX  project,  both  in  terms  of  those  Member  States  participating  and  the  regulatory 
requirements covered. While there is qualitative evidence that the overall objective has been 
achieved  with  the  pilot  nature  in  mind,  the  evidence  on  expected  outcomes  is  limited  to 
showing that within the scope of the initiatives successful harmonisation and cooperation has 
been  achieved,  while  there  is  very  limited,  mostly  anecdotal,  evidence  of  how  the  initiative 
has contributed to tackling fraud.  

Regarding  improved  time  to  market  specifically,  data  on  processing  times  for  different 
regulatory requirements before and after the introduction of the pilot was requested from the 
project  group.  The  information  provided  by  Member  States  was  neither  complete  nor 
comparable.  Authorities  expressed  difficulties  in  calculating  times  due  to  the  importance  of 
different factors, variability and lack of systematic tracking of clearance times.  

Answer to evaluation question 

With  the  EU  CSW-CVED  pilot,  automated  verification  checks  of  the  CVED  and  CED 
submitted  with  customs  declarations  are  possible  (as  shown  in  the  right-hand  side  of  the 
figure below). To date, nine participating Member States have established a connection with 
their customs systems to perform automated certificates checks against an EU level database 
dealing  with  partner  competent  authority  reporting  formalities  for  CED  and  CVED-A  and 
CVED-P.  

Figure 20: The concept of the "EU Customs Single Window: Certificates Exchange" 

Source: EU CSW-CERTEX business case 

The  automation  of  checks  is  possible  because  of  efforts  to  develop  harmonised  data  sets 
between DGs at the EU level, and between national and EU authorities (dealing with relevant 
reporting  formalities).  As  such,  the  project  has  successfully  delivered  the  outcome  of  EU-
level  harmonisation  regarding  the  implementation  of  customs  and  non-customs  regulatory 
requirements implemented within the current scope (i.e. between customs and EU databases 
covering  certain  non-customs  regulatory  requirements)161.  Data  harmonisation  in  a  more 

161   Looking ahead, part of the process for expanding the EU CSW-CERTEX project to cover new regulatory requirements 
will  necessarily  include  a  data  harmonisation  phase  for  the  non-customs  formalities  covered,  as  stipulated  in  the 
documentation  for  the  development  of  new  connections.  It  will  also  include  a  process  for  the  transformation  of  data 
from customs to non-customs authorities to enable the realisation of automated exchange of the required information. 

Page 140 / 237 

 
 
 
                                                 
general sense (between customs and non-customs authorities) has not been in the scope of the 
pilot. 

Data harmonisation was possible through a process of exchange and collaboration at both EU 
and  national  levels,  which  was  another  expected  outcome.  For  example,  meetings  were 
organised  to  understand  the  legal  requirements  and  data  needs  of  both  sides  (customs  and 
non-customs).  Although  not  yet  a  full  member  of  the  EU  CSW-CERTEX  project,  France 
provides  a  concrete  evidence  of  the  process  undertaken  to  establish  harmonised  data  (see 
overview in the box below).  

Box  10:  Evidence  of  process  for  establishing  a  connection  between  customs  and  non-
customs authority systems 

First contact 
(Informal) meeting with partner 
competent authority, incluing 
presentation of the GUN 

Agreement-in-principle 
from both authorities 

Framework 
Perimeter, 
organisation
, planning, 
etc. 

General 
Functional 
Specificatio
ns (GFS) 
Regulatory 
basis 

Validation of 
the GFS 
Executive 
Committee 
between the 
two 
authorities 

Realisation 
Contracts 
for 
interfaces 
Technical 
developme
nt 

End-to-end 
testing 

Testing 1 
Fictional 
operations 
Monitorin
g and 
Evaluatio
n 

Testing 2 
Real 
operations 
Monitorin
g and 
Evaluatio
n 

Generalisation 
Diffusion of 
instructions to 
services 
Information to 
operators 

The agreement-in-principle is a roadmap used until full implementation of the connection. 
It  is  an  important  political  commitment  signed  by  the  Director  General  and  sent  to  the 
partner  competent  authority.  Given  that  customs  do  not  financially  support  the  partner 
competent authority’s necessary adaptation, this commitment must come from a sufficiently 
high  level.162  Communication  is  important  throughout,  as  authorities  must  have  the  same 
understanding and definition of the different components so that systems are interoperable. 
Economic operators are systematically involved once the testing phase begins. 

This has reportedly led to an improved understanding between the authorities involved as an 
indirect  benefit,  in  the  case  of  France,  and  with  the  EU  CSW-CVED  pilot  and  EU  CSW-
CERTEX  project.  In  the  framework  of  the  EU  CSW-CVED  pilot,  DG  TAXUD  interacted 
with  other  stakeholders  involved,  through  its  IT  services.  The  pilot  served  as  an  interface 
between national customs authorities and TRACES, which is managed by DG SANTE. This 
required  improved  coordination  between  customs  and  the  other  authorities  (in  this  case  DG 
SANTE and typically sanitary / veterinary departments) involved. 

Already there are indications that the EU CSW-CVED pilot and EU CSW-CERTEX project 
are  leading  to  benefits  such  as  reduced  fraud  and  mistakes.  Unfortunately,  most  of  this 
evidence  is  anecdotal  due  to  the  sensitivity  of  the  information  and  /  or  an  absence  of 
systematic  recording  of  the  improvements  made  leading  to  mainly  qualitative  data. 
Nevertheless, this finding was consistently reported; four Member States participating in the 
project group indicated this as a benefit. Portugal indicated that the approach reduces errors, 
because all the conditions attached to the enforceability of the supporting documents, and the 
exceptions also provided for in the legislation, are all previously established in the electronic 
system. Malta provided a detailed answer on the matter, making it an argument for joining the 
EU CSW-CERTEX project (see box below). 

162   The role of the sponsor is indeed essential, as (s)he “is accountable for ensuring that the work is governed effectively 
and delivers the objectives that meet identified needs”. Novare Consulting Ltd., Association for Project Management. 

Page 141 / 237 

 
 
 
 
 
 
 
                                                 
 
Box 11: Expected reduced risk of fraud and mistakes as explained by Maltese customs 

From both a customs and business perspective, the EU CSW-CVED is expected to reduce 
the risk of fraud and eliminates the potential for errors. The possibility to consult the source 
of  supporting  documents  data  eliminates  the  need  to  check  the  supporting  document  as 
provided by the economic operator, this automated check eliminates the risk of receiving a 
falsified supporting document (in electronic form). Further, the obligation for the economic 
operator  to  provide  a  reference  to  an  electronic  supporting  document  in  an  EU  database 
eliminates the risk of receiving a falsified paper document. The transformation of data from 
the  supporting  documents  into  customs  declaration  compatible  data  ensures  synchronised 
application of legislation among the EU Member States and reduction of human errors. 

Source: Response to questionnaire sent to customs administrations (December 2018) 

Envisaged  future  benefits  as  the  project  continues  to  improve  and  expand  its  scope  were 
viewed  positively.  As  previously  mentioned,  there  are  still  some  limitations  in  terms  of  the 
outcomes  of  the  initiatives,  which  relate  to  the  scope  to  date.  While  national  quantity 
management is now possible, EU level quantity management is not. 

Conclusion 

The EU CSW-CVED pilot and EU CSW-CERTEX project have delivered on their objective 
to allow for automated checks of supporting documents by customs authorities. While caveats 
apply in line with the scope of the project to date, the EU CSW-CVED pilot and its successor, 
the  EU  CSW-CERTEX  project,  have  already  led  to  harmonisation  and  exchange  of  data 
related  to  the  regulatory  requirements  covered.  Indeed,  the  automation  of  the  process  for 
verifying  documents  was  possible  due  to  harmonisation  of  relevant  data.  In  turn,  this  has 
meant  improved  cooperation  between  competent  authorities.  There  is  also  some  limited 
evidence  of  reduced  fraud  and  human  error,  particularly  through  the  reduced  human 
intervention, and through the possibility for national quantity management.  

While certain needs remain unmet, expected outcomes are likewise not achievable within the 
current  scope  providing  evidence  of  the  remaining  issues  facing  stakeholders.  The  most 
obvious  example  of  this  is  the  feasibility  of  EU  level  quantity  management  (necessary  for 
fully effective enforcement of quotas, for example), which is not possible unless all Member 
States are involved, and the technology supports real-time information sharing. 

Efficiency 

To what extent have the benefits of the EU SW-CVED pilot and EU CSW-CERTEX project so 
far (in terms of costs, time and effort savings), outweighed the costs of implementation? 

Coverage of question 

This  evaluation  question  assesses  the  extent  to  which  the  resources  used  for  the 
implementation of the EU SW-CVED pilot and EU CSW-CERTEX project are proportionate 
to  the  benefits  generated.  It  addresses  administrative  and  regulatory  burden  and  looks  at 
aspects of simplification overall. To answer the question, costs and benefits for Member State 
authorities  were  compared  to  the  extent  possible.  Given  the  pilot  nature  of  the  EU  CSW-
CVED  pilot  and  EU  CSW-CERTEX  project,  it  is  important  to  stress  that  their  efficiency 
cannot  be  judged  in  a  complete  sense.  The  initiatives  have  not  (yet)  fully  replaced  the 
previous  processes  for  verification  of  documents,  and  this  means  some  of  the  expected 
benefits to different stakeholders cannot be fully realised yet. Nevertheless, it is important to 
show how benefits compare to costs already at this stage, with the various caveats made clear. 
This  provides  a  starting  point  to  see  the  direction  of  travel  for  how  costs  and  benefits  may 
compare  as  further  efforts  to  expand  the  scope  of  the  EU  CSW-CERTEX  project  over  the 

Page 142 / 237 

 
 
longer  term  take  shape.  At  the  same  time,  establishing  the  costs  already  incurred  provides 
information  regarding  the  sunk  costs  which  cannot  be  recuperated  if  the  initiative  is  not 
expanded. 

Evidence base 

The  evidence  to  date  is  limited  to  those  countries  that  have  been  involved  in  the  EU  SW-
CVED  pilot  and  EU  CSW-CERTEX  project.  Most  detailed  evidence  of  costs  and  benefits 
come from field visits to participating countries (namely Czechia and Ireland). We also rely 
on feedback shared in the form of a survey, to which only some participating Member States 
replied163. Obtaining robust quantitative data to use in the evaluation of costs and benefits was 
challenging, particularly since Member States joined with different baselines and at different 
points  in  time.  Member  States  also  have  different  administrative  set-ups  and  took  different 
approaches to developing connections with the EU databases (some using in-house providers 
and some using contractors), which also makes comparisons difficult. Given the importance 
of presenting quantitative data to provide a comparison of costs with time and effort saving, 
we  have  used  a  limited  sample  of  Member  States  with  the  most  complete  data  to  present 
estimates  of  the  order  of  magnitude  of  costs  and  benefits164.  To  put  these  estimations  into 
context,  they  are  complemented  with  qualitative  findings,  including  from  other  Member 
States which either have or have not yet begun the pilot.  

Approach to estimation of costs and benefits: 

Estimation of costs: As mentioned above, costs cannot be considered comparable for Member 
States,  given  their  different  approaches  and  starting  points.  Costs  can  include  one-off 
implementation  costs and recurring maintenance costs, which  are borne  by the Commission 
and Member States. Rather than attempt to estimate costs for the different Member States, we 
have based costs on reported data from Member State authorities. While there could in theory 
be  costs  for  economic  operators  to  align  with  new  systems,  interviews  with  operators 
suggested these would be negligible. Costs for the European Commission were provided by 
the DG TAXUD. 

Estimation  of  benefits: we  use  the  same  standard  cost  model  approach  taken  for  the  impact 
assessment (see section 7.2) which essentially multiplies the number of declarations affected, 
a reasoned estimate for the time saved per declaration and a standard hourly labour cost. 

Answer to evaluation question 

The  evidence  available  suggests  that  already  the  EU  CSW-CVED  pilot  and  the  EU  CSW-
CERTEX project have led to some, albeit limited, cost savings, through reductions in the time 
and effort needed for various stakeholders to deal with clearance processes. This finding was 
consistent across Member States and stakeholders consulted during the fieldwork as well as in 
the  feedback  in  the  survey  to  project  group  members.  The  automation  of  the  process  for 
verifying documents implies less human intervention, so  fewer resources and more efficient 
processes.  

Despite  the  consistent  reporting  of  meaningful  benefits,  the  caveat  that  applied  to  the 
relevance  of  the  EU  CSW-CVED  pilot  and  EU  CSW-CERTEX  project  also  limit  the  full 
realisation  of  cost  savings  for  all  stakeholders.  Namely,  the  functionalities,  scope  and 
voluntary  nature  of  the  project  mean  that  concurrent  submission  of  paper  documents 
continues, and thus authorities and economic operators are unable to shed the associated costs 
of having to deal with an automated and manual system concurrently. Indeed, the problem of 

163   Bulgaria, Cyprus, Czechia, Estonia, Ireland, Latvia, Poland and Portugal. 
164   Usable data was only available for Czechia, Estonia, Ireland and Latvia. 

Page 143 / 237 

 
 
                                                 
the  continued  need  for  paper  documents  featured  prominently  in  the  responses  to  the  open 
public consultation165 and economic operators from  participating countries were as likely as 
others to complain about the continued need for paper documents, showing that the EU CSW-
CERTEX project has not significantly changed that aspect. For the full savings to be realised, 
a  fully  paperless  environment  would  be  needed,  and  more  regulatory  requirements  would 
need to  be covered. As  stated by  Irish Customs:  “Further benefits  will  not  materialise until 
EU  CSW-CERTEX  is  mandatory  for  all  Member  States  and  expanded  to  other  certificates. 
For example, the onus on customs to manually check AGRIM licences on a declaration that 
also requires a CVED can often negate the benefit of EU CSW-CVED”.  

With  these  caveats  in  mind,  we  have  assumed  the  benefits  are  positive  but  modest.  More 
specifically, it seems  reasonable to  assume that  customs authorities and economic operators 
save  about  two  minutes  for  each  relevant  customs  declaration.  For  partner  competent 
authorities,  the  benefits  consist  mainly  of  improved  enforcement,  but  there  have  also  been 
minor  savings  estimated  at  about  one  minute  per  declaration.  The  table  below  summarises 
simplified estimations for the benefits accrued from time savings for the different stakeholder 
groups  for  the  three  reporting  obligations  covered  in  the  EU  SW-CVED  pilot  for  four 
Member States: Czechia, Ireland, Estonia, and Latvia.  

Table 24: Estimated benefits for sample of Member States  

Relevant declarations / 
year (avg 2015-17) 

Customs 
authorities 

Partner 
competent 
authorities 

Economic 
operators 

Total annual 
benefit (EUR) 

Time saved 

2 minutes 

1 minute 

2 minutes 

Czechia (hourly labour cost EUR 7.99) 

CVED-A  

CVED-P  

CED 

TOTAL 

1 655  

3 374 

1 059 

6 088 

Estonia166 (hourly labour cost EUR 10.36) 

CVED-A  

CVED-P  

CED 

TOTAL 

27 

1 034 

182 

1 243 

Ireland (hourly labour cost EUR 36.93) 

CVED-A  

CVED-P  

CED 

TOTAL 

348 

8 272 

908 

9 527 

Latvia (hourly labour cost EUR 8.20) 

CVED-A  

CVED-P  

66 

546 

441 

899 

282 

1 622 

9 

357 

63 

429 

428 

10 183 

1 117 

11 728 

18 

149 

220 

449 

141 

811 

5 

179 

31 

215 

214 

5 091 

559 

5 864 

9 

75 

441 

899 

282 

1 622 

9 

357 

63 

429 

428 

10 183 

1 117 

11 728 

18 

149 

1 102 

2 247 

705 

4 054 

23 

893 

157 

1 073 

1 070 

25 457 

2 793 

29 320 

45 

373 

165   78% of respondents reported this problem negatively affected them to some or a large extent. 
166   Declaration data only available for 2017. 

Page 144 / 237 

 
 
 
 
 
                                                 
CED 

TOTAL 

12 271 

12 882 

3 354 

3 521 

1 677 

1 761 

3 354 

3 521 

8 385 

8 803 

Source: Declarations data from the Member States participating in the project group, hourly  costs based on Eurostat and 

OECD data and time estimates based on stakeholder interviews.  

As shown, the benefits differ depending on the volumes of declarations concerned and are in 
line  with  the  varying  hourly  labour  costs  found  in  the  selected  Member  States.  The  highest 
benefits are accrued in Ireland, where the volume of relevant declarations and labour costs are 
highest; the total annual benefit from the EU SW-CVED pilot is estimated to be nearly EUR 
30 000. The next highest benefits are found in Latvia, where nearly EUR 9 000 is estimated to 
be saved. In Czechia the annual saving is estimated to be just over EUR 4 000 and in Latvia 
just over EUR 1 000.  In  every Member State except  Latvia, the relatively higher volume of 
declarations  requiring  CVED-P  meant  this  was  where  the  major  benefits  were  accrued  in 
terms of time and effort saved. For Latvia, the major benefits were realised for CED.  

Two Member States - which did not supply sufficiently robust data on declarations to produce 
estimates - suggested the benefits they had realised were significant for their authorities:  

a)  Portugal referred to “speedier” processes and provided an estimate of the actual time 
estimated  to  be  saved  through  the  EU  CSW-CERTEX  project:  “Regarding  the 
implementation  of  the  EU  CSW-CVED  pilot  in  Portugal,  the  time  needed  to  accept 
and  validate  the  declaration  with  certificates  that  are  hosted  in  TRACES  decreased 
three  hours,  concerning  declarations  that  needed  the  same  certificate  (C678).”  The 
expected  savings  to  be  made  would  be  “extraordinary”  as  the  average  time  for 
clearance decreases substantially. While this is clearly a significant benefit, it cannot 
be  simply  monetised  because  of  the  absence  of  robust  data  on  how  this  time  saved 
affects  different  actors.  Some  of  the  time  saved  may  simply  be  from  the  electronic 
exchange of data replacing a more time-consuming transfer of paper documents from 
place to place, meaning it is not as simple as to say three hours of labour time is saved. 

b)  Similarly, Malta, which is still only at planning stage, and aims to join the EU CSW-
CERTEX  project  in  the  coming  years,  provided  quantitative  evidence  of  time  and 
effort savings, citing the redeployment of resources leading to “a minimum reduction 
of  30%  in  releasing  times”  meaning  “Customs  will  be  able  to  utilise  resources 
currently  tasked  with  scrutinising…manual  certifications…in  other  areas.”  Again, 
while clearly a significant benefit, it is not simple to monetise.  

This  evidence  suggests  that,  while  it  is  appropriate  to  make  conservative  quantitative 
estimates,  the  view  of  different  Member  States  is  that  these  have  or  will  have  significant 
knock-on effects  to  the full  time taken to  clear goods at  the border (beyond the labour time 
saved).  

The question asks us to compare benefits with costs incurred. Turning our attention to costs; 
while  quantitative  evidence  of  the  implementation  costs  has  been  difficult  to  gather  for 
participating  Member  States,  the  scale  of  implementation  costs  is  summarised  below  as 
reported  directed  by  three  of  the  four  Member  States  which  were  focused  on  above. 
Evidently, these vary significantly by Member State which reflects their different approaches 
and starting points. 

Table 25: Estimated costs for selected Member States (in EUR) 

One-off costs 

Inclusion of new 
requirements 

Periodic systematic 
upgrades 

Czechia   

 63 000  

 50 000  

16 500  

Page 145 / 237 

 
 
 
Estonia   

Ireland  

 145 000  

Not provided 

Three  specialised  IT  staff 
working  full 
time  over 
two months 

0.5  FTE  for  one  year  for 
specialised IT staff 

None identified 

Latvia  

No quantitative estimates shared  

Source: Estimations provided by Member States   

Added  to  these  Member  State  costs  are  costs  to  the  Commission  for  the  EU  CSW-CVED 
pilot,  encompassing 
technical  specifications, 
development,  deployment,  operations  and  maintenance  costs  of  the  pilot.  Data  available  for 
past seven years show these costs add up to 3.25 million EUR. 

functional  specifications, 

the  design, 

Table 26: Estimated costs for European Commission (in EUR) 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

300 000 

700 000 

600 000 

500 000 

400 000 

400 000 

350 000 

European 
Commission 

Source: Estimations provided by DG TAXUD 

The costs, which have been steadily declining since their peak in 2013, are much higher than 
the costs to individual Member States and – as such - show the importance of developing a 
centralised solution. More specifically, the pilot approach which implies small fixed costs to 
Member  States  to  “plug  into”  a  centralised  solution  is  evidently  preferable  to  an  alternative 
scenario whereby the cost to Commission would be replicated in all Member States; meaning 
the overall cost would be much higher. 

Notwithstanding  this  argument,  taken  at  face  value  the  costs  may  seem  relatively  high 
compared to the (conservative) estimated benefits to Member States, but it is worth recalling a 
number  of  factors  before  concluding  on  how  they  compare.  Firstly,  the  benefits  are  annual 
(and thus  cumulatively add up to higher values over time), whereas costs to  Member States 
are one-off (and are now sunk costs, i.e. cannot be recuperated) and the Commission costs are 
also  largely  sunk  costs,  which  became  less  important  after  the  initial  start-up  phase  of  the 
pilot.  

But  even  more  important  is  the  wider  the  context.  The  benefits  to  Member  States  are 
discounted  to  account  for  the  fact  that  previous  systems  and  processes  are  still  in  place 
(meaning  the  full  savings  have  not  been  realised).  Meanwhile,  the  costs  and  benefits  also 
relate to a pilot initiative which aims to test an idea, which has the long-term potential to be 
expanded to cover more regulatory requirements. The expansion of the pilot (to more Member 
States and more requirements) means that provided this continues as anticipated, the marginal 
cost over time should diminish, while the benefits continue should grow. Indeed, although the 
figures  suggest  the  benefits  have  not  in  all  cases  yet  outweighed  the  costs  (for  example  in 
Czechia ), taking into account  the complementary  qualitative evidence  gathered, these costs 
were not judged to be huge in comparison to the potential benefits over time if the initiative 
expands  as  expected  and  once  parallel  systems  are  replaced.  Indeed,  this  was  the  case  in 
Ireland, and Czechia, where the costs reported above (Table 25) were deemed not to be huge 
given the potential time savings should the initiative be expanded to cover more requirements 
(these would depend on the volumes concerned, as presented in Table 24).  

Other  participating  Member  States,  such  as  Latvia  and  Cyprus,  and  France  (which  plans  to 
join)  and  Cyprus  (which  joined  in  2016)  reported  to  be  expecting  net  positive  calculations 
when taking a long-term perspective.  

Page 146 / 237 

 
 
 
a)  For  instance,  Latvia  explained  that  considering  that  “CVED/CED  will  have  to  be 
totally  rebuilt  in  2019-2020, for our administration costs of national  integration with 
EU  CSV-CVED/CED  are  higher  than  benefits.  Nevertheless,  we  believe  that 
development  of  EU  CSW-CERTEX  and  its  further  expanding  with  other  certificates 
will have positive impact on clearance process (long term).”  

b)  In  Cyprus,  the  view  was  that  the  benefits  are  worth  the  costs  incurred  because  they 
expect  to  have  additional  benefits  in  the  future  with  further  inclusion  of  new 
supporting documents and a more complete national Single Window system.  

c)  In  France,  which  is  working  on  establishing  a  connection  with  the  EU  database 
TRACES as part of the EU CSW-CERTEX project, the qualitative evidence gathered 
through the field visit was that the one-off costs of gradually expanding the scope of 
the  EU  CSW-CERTEX  project  would  not  be  significant  (compared  to  the  benefits 
over time). 

The same can be said for the Commission costs, which while appearing high, mostly relate to 
one-off  costs  invested  in  developing  a  new  system  from  scratch  and  should  continue  to 
diminish over time, which indeed is already clear from the yearly costs in 2016 onwards.    

A last point, made by several participating Member States and evidenced in  Table 24 above 
which is relevant to consider when projecting the cost-benefit calculus into long-term plans, 
was  that  depending  on  the  volume  of  supporting  documents  issued  or  processed  in  a  given 
Member State, it may or not be cost-efficient to invest in the EU CSW-CERTEX project. For 
example, where volumes are really small, like  for FLEGT in  Ireland, the investment  cost  is 
expected to outweigh the benefit in this instance. Precisely this calculus has led Ireland not to 
cover FLEGT in their Single Window environment. 

Conclusion 

The  EU  CSW-CVED  pilot  and  the  EU  CSW-CERTEX  project  have  led  to  some  benefits, 
mainly in the form of time and effort savings. This demonstrates the viability of the concept 
and  potential  to  general  larger  benefits  over  time  as  the  scope  in  terms  of  regulatory 
requirements and participation in terms of Member States continue to expand. The continued 
use of parallel systems and processes hampered the potential savings to a certain extent, but 
the costs were viewed as appropriate by stakeholders given the expected long-term prospects 
of  expansion  and  associated  increased  benefits.  The  model  is  based  on  the  Commission 
bearing the majority of development costs. Building in the assumption about future expansion 
is important because most of the costs incurred are now sunk costs and longer term efficiency 
will depend on the assumption of expansion holding true. The exception that was mentioned 
was  that  in  cases  where  volumes  are  really  low  (i.e.  less  than  ten  declarations  affected 
annually), costs are likely to still outweigh benefits even over the longer term.  

Coherence 

How  well  do  the  EU  CSW-CVED  pilot  and  EU  CSW-CERTEX  project  fit  with  other  EU 
initiatives? 

Coverage of question 

This  question  addresses  the  extent  to  which  the  EU  CSW-CVED  pilot  and  EU  CSW-
CERTEX project work with other relevant EU initiatives. It specifically covers the extent to 
which there are synergies to potentially improve overall performance. 

Evidence base 

This question draws on existing documentary sources, and on stakeholder consultation. 

Page 147 / 237 

 
 
Answer to evaluation question 

The  EU  CSW-CERTEX  project  and  its  predecessor  are  well  aligned  with  EU  political 
priorities. In December 2014, the Council adopted the Venice Declaration, which established 
a commitment to develop an action plan for an EU Single Window environment for customs 
and corresponding legal framework. This was reiterated in the 2016 Communication entitled 
"Developing the EU Customs Union and Governance”167, which outlined the Commission’s 
plan  to  explore  a  workable  solution  for  the  development  and  creation  of  an  EU  Single 
Window  environment  for  customs.  This  was  supported  by  the  European  Council  in  its 
conclusions of March 2017. 

Both the EU CSW-CVED pilot and its successor, the EU CSW-CERTEX project, contribute 
to  the  operationalisation  of  this  vision.  The  Commission  initiatives  have  seen  collaboration 
between  DG  TAXUD  and  several  other  DGs  (DG  SANTE,  DG  ENV,  DG  AGRI  and  DG 
DIGIT168). The expansion of the EU CSW-CERTEX project to new regulatory requirements 
(falling under the responsibility of DG CLIMA,  DG TRADE, DG GROW and DG MARE) 
demonstrates its ability to support other EU initiatives and policies and thereby contribute to a 
smoother implementation of EU legislation. 

Other  related  EU  initiatives  coexist  with  the  EU  CSW-CERTEX  project  and  show  how  the 
EU  CSW-CERTEX  project  is  in  line  with  wider  efforts  to  simplify  and  digitise  processes 
relating to reporting formalities for the movement of goods to reduce the burden stakeholders, 
as well as to streamline and improve the implementation of Union legislation: 

  A  maritime  national  Single  Window  was  initiated  by  the  Directorate-General  for 
Mobilty  and  Transport  (DG  MOVE)  and  entered  into  force  on  1  June  2015.169  It  is 
based on the Commission’s 2010 Reporting Formalities Directive (RFD) and requires 
Member States to accept the fulfilment of reporting formalities by ships in electronic 
format  and  their  collection  through  a  single  window170.  Feedback  from  the  trade 
community  revealed  that  the  exclusion  of  clearance  functions  from  the  maritime 
national  Single Window initiative was  considered a drawback. This  shows that even 
though the objectives of the EU CSW-CERTEX project are aligned with this initiative 
but there is scope for greater collaboration between DG MOVE and DG TAXUD. 

  The  eManifest  Pilot  Project  (which  the  new  maritime  Single  Window  regulatory 
proposal  considers)  explores  how  cargo  information  required  by  both  maritime  and 
customs  authorities  could  be  submitted  together  with  other  reporting  formalities 
required by the RFD in a harmonised manner. It will serve as a basis for developing a 
proper legal framework fully responsive to the needs of the industry. The project may 
be extended to cover customs formalities related to arrival and departure notifications, 
mapped in a unique set of data elements as per the reporting only once approach. This 
pilot  was  mentioned  during  several  interviews  with  trade  associations  members  as  a 
positive initiative. There is potential for synergies with the EU CSW-CERTEX project 
which both DG TAXUD and DG MOVE are conscious of. 

167   COM (2016) 813 final 
168   As stipulated in the EU CSW-ERTEX Business case  – “DG DIGIT is involved in horizontal support activities of the 

"EU Customs SW: Certificates Exchange project".” 

169   See more information here: https://ec.europa.eu/transport/modes/maritime/digital-services/e-maritime_en  
170   The exchange of information between Member States should be organised using existing systems, like e-Customs  for 
example. Port Community Systems (PCS) can be included if they comply with the relevant RFD requirements. Member 
States currently collect and distribute information through the Maritime National Single Windows (MNSWs) and/or the 
PCSs. Either MNSW perform both functions of interface and gateway, or the PCSs act as interfaces while sharing the 
gateway function with the MNSW. 

Page 148 / 237 

 
 
                                                 
  Market  surveillance  –The  new  EU  market  surveillance  framework  for  non-food 
products aims to strengthen and facilitate safety and compliance controls by national 
market surveillance and customs authorities. 171 It includes government-to-government 
exchange  of  information  for  the  purposes  of  risk  analysis  and  surveillance  and  is 
therefore closely linked with the objectives of the EU CSW-CERTEX project. 

An  important  limitation  of  the  coherence  of  the  EU  CSW-CVED  pilot  and  EU  CSW-
CERTEX  initiatives  is  the  continued  requirement  for  paper  documents.  The  broader 
digitisation  agenda  pursued  by  the  Commission  and  particularly  DG  TAXUD  means  a 
reduction in the use of paper. As per the 2008 e-Customs Decision, a commitment was made 
to a paperless environment172 and the Union Customs Code (UCC)173 which stipulates modern 
tools  and  technology  should  be  encouraged  to  further  promote  the  uniform  application  of 
customs legislation and modernised approaches to customs control.  
More generally, the European Commission, through the Digital Agenda for Europe,174 aims to 
have  a  digital  single market  based on interoperable applications. The Commission  therefore 
encourages  all  organisations,  businesses  and  government  bodies  to  commit  to  carrying  out 
actions to reduce the digital skills gap in Europe.175 The fact that paper continues to be used 
alongside  the  EU  CSW-CERTEX  project  limits  coherence  but  this  is  not  intrinsic  to  the 
project. It is related to the pilot nature of the project, where previous systems are still in use. 
Should  the  project  proceed  as  planned,  paper  will  not  continue  to  be  used.  Other 
developments  at  the  EU  level  show  potential  to  support  an  expansion  of  the  functionalities 
offered within EU CSW-CERTEX, and contribute to improved coherence: 

  The  eIDAS  Regulation176  established  a  new 

legal  structure  for  electronic 
identification, signatures, seals and documents throughout the EU. Its most important 
aspect  is  the  uniform  application  of  government-recognised  electronic  identification 
systems.  The  electronic  documents  it  supports  ensure  validity  and  legal  certainty  of 
cross-border electronic transactions. It hence strengthens the legal framework for the 
use  of  electronic  documents,  which  is  an  underlying  feature  of  a  potential  Single 
Window  solution.  As  EU  CSW-CERTEX  incorporates  documents  in  PDF  format,  it 
will be important that the eIDAS Regulation is complied with to maintain coherence.  

Two  other  EU  level  initiatives  are  outside  of  the  current  scope  of  EU  CSW-CERTEX  but 
show where there is under exploited potential to ensure coherence looking ahead.  

  The  “Once-Only”  Principle  project  aims  at  promoting  cross-border  cooperation 
among  authorities  with  a  commitment 
transparency 
opportunities  for  business  operations.  It  stipulates  that  collecting  the  same  data 
multiple  times  is  more  expensive  than  sharing  and  reusing  them.  This  principle 
constitutes  a  priority  for  several  stakeholders  consulted  but  is  currently  not  applied 
within the EU CSW-CERTEX project. 

to  provide  control  and 

171   Regulation (EU) 2019/1020 of the European Parliament  and of the Council on market surveillance and compliance of 

products, OJ L 169, 25.6.2019, p. 1–44. 

172   Decision No 70/2008/EC of the European Parliament and of the Council of 15 January 2008 on a paperless environment 

for customs and trade. 

173   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. 1–557. 

174   Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 

Committee and the Committee of the Regions, A Digital Agenda for Europe, 2010.  

175   https://ec.europa.eu/digital-single-market/en/pledges-action  
176   Regulation  (EU)  910/2014  on  electronic  identification  and  trust  services  for  electronic  transactions  in  the  internal 
market,  became  effective  on  1  July  2016,  repealing  the  existing  directive  on  e-signatures  and  prevailing  over  any 
inconsistent national laws. Full text at: https://ec.europa.eu/futurium/en/system/files/ged/eidas_regulation.pdf.  

Page 149 / 237 

 
 
                                                 
  The  Single  Digital  Gateway  Regulation  was  adopted  in  September  2018  and 
provides for a Single Entry Point for economic operators to be integrated in the “Your 
Europe”  portal,  creating  a  one-stop  shop  for  the  EU's  most  common  administration 
procedures  and  making  it  easier  for  citizens  and  economic  operators  to  interact  with 
public administrations.177 The EU CSW-CERTEX project does not include a SEP so 
far, and as such is not coherent with the Single Digital Gateway Regulation.  

Conclusion 

The EU CSW-CVED pilot and EU CSW-CERTEX project has to date been coherent with the 
European  Commission’s  and  DG  TAXUD’s  political  commitment  to  the  creation  of  an  EU 
Single Window environment for customs, and the Commission’s broader agenda to increase 
digitisation  and  simplify  processes  for  border  management.  Whether  this  holds  true  for  the 
next Commission (2019 onwards) remains to be seen. 

Both initiatives have been conceived and developed collaboratively between DG TAXUD and 
other DGs 

. As the number of DGs that DG TAXUD is collaborating with continues to grow, so does the 
coherence  of  the  project  and  its  ability  to  contribute  to  a  smoother  implementation  of  EU 
legislation. 

It  would,  however,  be  important  to  consider  how  the  project  can  support  the  Commission 
policy to develop a paperless environment for customs and trade, as the absence of a systemic 
reduction  of  paper  through  the  project  has  been  shown  to  be  a  limitation  of  the  internal 
coherence of the project and an unmet need.  

the  scope  of  EU  CSW-CERTEX 

While 
to  government-to-government 
collaboration,  its  coherence  with  EU  priorities  to  reduce  duplication  of  information  and 
procedural redundancies and to allow a single entry point for government services is limited. 
This provides further evidence of unmet needs.  

limited 

is 

EU Added Value 

To  what  extent  has  the  EU  CSW-CVED  pilot  project  complemented  the  activities  of  the 
Member States? 

Coverage of question 

The question considers the extent to which the EU CSW CVED pilot and EU CSW-CERTEX 
project have EU added value. EU added value refers to changes that are due to the initiative, 
added  benefits  of  the  presence  of  the  initiative  at  EU  level,  compared  to  what  could  be 
achieved by Member States alone.  

Evidence base 

The evaluation of EU added value brings together the findings of the other criteria, based on 
the evidence available regarding the performance of both initiatives to date. 

Answer to evaluation question 

The EU CSW-CVED pilot and EU CSW-CERTEX project have EU added value. Given the 
EU has the competence and is best placed to deliver harmonisation and provide solutions for 
EU level  regulations.  Indeed, competent  authorities consulted during field visits  argued that 

177   More  information  is  available  at  the  following  url:  http://www.europarl.europa.eu/legislative-train/theme-deeper-and-
fairer-internal-market-with-a-strengthened-industrial-base-services-including-transport/file-single-digital-gateway 

Page 150 / 237 

 
 
                                                 
the  EU  is  best  placed  to  provide  a  solution  for  exchange  of  documents  based  on  EU 
legislation. 

There is a legal basis for the EU to act to provide for customs cooperation between Member 
States and between the latter and the Commission in line with the objective the establishment 
and functioning of the internal market178. In addition to the legal basis for action, the EU is in 
a  unique  position  to  coordinate  action  and  stem  fragmentation  of  Member  State  action. 
Individual  Member  States  are  not  in  a  position  to  ensure  the  harmonisation  of  data 
requirements for supporting documents based on EU regulation. 

By providing a single solution, the EU CSW-CVED pilot and the EU CSW-CERTEX project 
were  expected  to  reduce  the  need  for  participating  Member  States  to  develop  their  own 
solutions  and thereby  generate economies of scale. This  was indeed found to  be the case in 
most  Member  States  participating  in  the  project.  The  cost  estimates  provided  by  Member 
States  show  that  the  European  Commission  has  borne  the  more  significant  costs.  During 
fieldwork visits in Ireland and Czechia for example, stakeholders explained that EU solutions 
were  preferred  since  smaller  volumes  of  trade,  and  the  lack  of  existing  national  systems, 
meant the one-off costs of technical solutions were hard to justify.  

However,  some  Member  States,  which  already  had  their  own  systems  in  place,  have  still 
opted  to  join  due  to  the  potential  benefits  from  having  an  EU  system  where  there  is  the 
possibility  to  share  information  between  countries,  such  as  better  risk  management  and 
controls  and  reduced  risks  of  fraud,  though  this  is  limited  by  the  small  number  of  Member 
States taking part so far. 

Respondents  to  the open public consultation  showed that the majority believed that without 
European  Commission  action  the  issues  experienced,  such  as  uncertainty  regarding  data 
sharing  and  data  protection,  time  for  goods  clearance,  etc.,  would  remain  unchanged.  Few 
believed the situation would improve a lot. This confirms the perception of EU added value – 
where the EU acts as a change driver, facilitator and initiator of improvements.  

Conclusion 

The EU added value of the EU CSW-CVED pilot and EU CSW-CERTEX project is judged to 
be high and was perceived to be strong by the different parties consulted. The creation of a 
single European solution for EU regulatory requirements was valuable, particularly where the 
one-off costs of solutions would be harder to justify for smaller Member States. The available 
cost data also show why a centralised EU solution makes more economic sense. Respondents 
to  the open public consultation  confirmed that European Commission  action is  perceived to 
be  an  important  means  to  improve  the  current  situation,  and  without  which  the  problems 
experienced would not be resolved. 

178   Treaty  on  European  Union  and  the  Treaty  on  the  Functioning  of  the  European  Union,  Official  Journal  C  326, 

26/10/2012 P. 0001 – 0390 (specifically articles 33 and 114). 

Page 151 / 237 

 
 
 
                                                 
ANNEX  15:  ASSESSMENT  OF  IMPACTS  RELATED  TO  INFORMATION  AND  COMMUNICATION 
TECHNOLOGIES AND SYSTEMS 

DG TAXUD commissioned an external contractor to assess the relevant  ICT impacts of the 
viable policy options. The report analyses in detail the IT requirements and implications for 
each  viable  policy  option,  focusing  on  three  main  IT  project  management  domains:  project 
timeline and integration, governance and operations and system architecture. The full report is 
available as a separate document and named “ICT assessment of policy changes of EU CSW-
CERTEX”. 

Page 152 / 237 

 
 
 
  
 
 
ANNEX 16: COUNTRY CASE STUDY REPORTS 

This  Annex  contains  the  reports  of  case  studies  that  were  carried  out  in  eight  EU  Member 
States. These contain much of the evidence used for the study, regarding such aspects as the 
existing situation, economic costs and benefits, and other likely impacts of the policy options, 
and  experiences  of  EU  SW-CVED  and  other  initiatives.  The  sample  covers  different 
experiences  of  EU  SW-CVED  and  national  single  window  initiatives  as  well  as  diverse 
trading  profiles.  The  sample  included  the  Czech  Republic,  France,  Germany,  Ireland,  Italy, 
the Netherlands, Romania and Spain. Each case study was comprised of 10-15 mainly face-to-
face  interviews  with  customs,  partner  competent  authorities  and  economic  operators,  and  a 
review  of  relevant  documentation.  The  field  visits  took  place  between  October  2018  and 
February 2019.  

information  on 

The reports for the Czech Republic, France, Ireland, the Netherlands and Spain are structured 
as  follows.  First,  a  background  section  provides 
trading  profiles, 
administrative  arrangements  for  border  coordination,  approaches  to  electronic  customs  and 
the current single window state of play. This is followed by current  experiences in terms of 
clearance  processes  and  problems  experienced.  A  section  on  likely  future  developments 
explores views and potential impacts of the continuation of the status quo and new EU action 
to  foster  G2G  and  B2G  collaboration.179  Each  report  ends  with  a  set  of  conclusions  with  a 
view to the nature and scale of current problems, and feasibility and desirability of the options 
for  future  action.  For  countries  participating  in  EU  SW-CVED,  an  assessment  of  the 
initiative’s implementation and achievements is also provided.  

Due to the scheduling for the study, the reports for Germany, Italy and Romania are shorter. 
After  a  brief  introduction,  these  focus  on  key  findings  and  conclusions  regarding 
administrative  arrangements,  progress  made  towards  a  single  window  (either  through 
participation in EU SW-CVED / EU CSW-CERTEX or similar national initiatives) and likely 
future developments  in  case of continuation of the status  quo or adoption of the options for 
EU action.  

CZECH REPUBLIC  

Introduction  

This  report  forms  one  of  the  eight  country  case  studies  that  were  carried  out  to  provide 
evidence  for  the  impact  assessment  on  a  potential  new  initiative,  namely  the  EU  Single 
Window environment for customs. By collecting and analysing data on the current situation 
and expected future developments, the case studies aim to generate insight on the nature and 
scale  of  any  existing  problems  and  likely  impacts  of  the  policy  options  defined  for  the 
potential  new  initiative.  These  include  an  option  for  no  additional  EU  action,  which  would 
consist of the continued existence and gradual expansion of the EU Customs Single Window-
CERTEX project (EU CSW-CERTEX).  

Each  case  study  used  a  common  methodology  based  on  a  document  review,  feedback  from 
national  administrations  provided  through  participation  in  the  project  group  and  interviews 
(mainly  face-to-face)  with  officials  from  customs  and  partner  competent  authorities  and 
economic operators. The sample of eight Member States was selected in discussion with DG 
TAXUD with a view to covering complementary areas of interest and achieving a degree of 
representativeness.  

179   The cross-cutting option on expanding EORI to additional regulatory requirements had not been defined at the time the 

case study fieldwork was carried out. 

Page 153 / 237 

 
 
                                                 
Within  this  broader  framework,  the  research  on  individual  case  studies  varied  according  to 
trading  profile,  administrative  set-up  and 
national  specificities  such  as  geography, 
participation  (or  not)  in  the  EU  Single  Window-CVED  pilot  project  (EU  SW-CVED,  the 
predecessor to EU CSW-CERTEX).  

For the Czech Republic, the case study mainly focused on:  

  Experiences with the EU SW-CVED pilot; 

  Experiences with their existing and still developing, national single window system; 

  Controls  related  to  import  of  agricultural  products  and  live  animals  (CVEDP  and 

CVEDA). 

The  evidence  for  the  case  study  is  comprised  of  desk  research  and  interviews  with  nine 
customs  authorities,  partner  competent  authorities  responsible  for  environmental  regulations 
and  economic  operators  dealing  including  freight  forwarders  and  customs  brokers.  These 
were conducted during a field visit took place in the week of 19 November 2018.  

Background  

Some  background  information  is  needed  to  understand  the  current  situation  in  the  Czech 
Republic  and  how  it  would  likely  evolve  for  the  policy  options  under  review.  This  section 
presents  an  overview  of  the  Czech  Republic’s  profile  for  international  trade,  administrative 
and IT set-up for customs and other relevant regulatory requirements. It also briefly presents 
progress towards a customs single window at national level in the Czech Republic.  

Trading profile   
The Czech Republic with its 10 million inhabitants180 is centrally located in Europe, bordering 
the EU Member States of Austria, Germany, Poland and Slovakia, but  with  no external  EU 
border or maritime border. Goods declared in the country therefore typically enter or exit by 
airplane (in Prague, Brno or Ostrava) or by road, with transit often involving Germany.  

The  country’s  share  of  the  total  EU  exports  and  imports  were  1,4%  respectively  1,7%  in 
2017.181  The  top  commodity  group  for  both  imports  and  exports  is  by  far  manufactures 
(89.7% for total exports and 84.1% for total imports during 2017), with  goods such as cars, 
vehicle  parts,  automatic  data-processing  machines  being  among  the  most  prominent  goods. 
Among agricultural products (accounting for 6.2% of total exports and 7.4% of total imports 
during 2017), the top imported product during 2017 was swine meat (which is a good subject 
for  non-customs  regulations).    The  third  largest  commodity  group  is  fuels  and  mining 
products (with 3.3% of total exports, and 8.0% of total imports).182 This is a commodity group 
relevant for regulatory requirements, since certain goods such as explosive materials or dual-
use goods require certain types of additional requirement documents.  

To  understand  the  Czech  Republic’s  degree  of  success  in  clearing  goods  efficiently,  we 
looked at the country’s logistics performance as assessed by the World Bank, and the Czech 
Republic ranks number 26 globally. Among the six components which are used to calculate 
the  ranking  by  the  World  Bank183,  the  component  of  customs  received  the  lowest  scoring. 
However, customs still rank highly with the Czech Republic being ranked as number 14 of the 

180   Source: The Czech Statistical Office, 2018. https://www.czso.cz/csu/czso/population (accessed 2018-12-18). 
181   Eurostat data on external trade.  
182   Source: WTO, the Czech Republic trade profile information (2017).  
183   Namely customs, infrastructure, international shipments, logistics competence, tracking and tracing and timeliness.  

Page 154 / 237 

 
 
                                                 
167  countries  included  in  the  index.  Nevertheless,  this  means  that  improvement  of  the 
customs procedures has much potential in improving the overall logistic procedure.184 
Administrative set-up 

The  General  Directorate  of  Customs  of  the  Czech  Republic  (hereafter  referred  to  “Czech 
customs”) is subordinated to the Ministry of Finance. The main office is placed in Prague, and 
15  regional  customs  offices  are  spread  across  the  country  based  on  regions.  The  Czech 
customs  has  around  6000  employees  in  total  and  is  responsible  for  processing  customs 
declarations, as well as for policy and IT developments.  
The  Czech  customs  collaborate  with  a  range  of  partner  competent  authorities185  for  the 
verification of customs declarations and checks. It does not have any official / legal mandate 
to  lead  the  national  single  window  initiative  but  does  so  according  to  its  own  and  national 
priorities  and  objectives.  This  means  that  Czech  customs  depends  on  partner  competent 
authorities’ own will of joining the initiative and cannot oblige anyone to join.  

Approach to electronic customs and IT architecture  
The Czech Republic is advanced in digitising customs procedures and has since 2007186 been 
working  towards  a  fully  digitised  customs  clearance  system.  Since  2015,  the  country  has 
worked on a national single window solution, see further detail below.  

The  national  IT  architecture  is  comprised  of  a  combination  EU  trans-national  systems  and 
nationally developed systems, and centralised EU systems and databases are used or contacted 
during  customs  clearance  processes.  The  system  is  built  on  a  web-service  to  web-service 
solution where the economic operator submits its declaration online. The system is supported 
by a digital authentication system. The Czech Republic prefers making use of EU developed 
systems,  since  developing  their  own  systems  otherwise  risks  being  a  heavy  cost  for  a 
relatively small EU Member State.  

Single Window state of play and key initiatives  

On  5  January  2015,  a  first  step  towards  a  G2G  national  single  window  environment  was 
launched in the Czech Republic. The aim of the national single window  was to simplify and 
streamline the validation / verification process of certain  regulatory requirements needed for 
goods subject for non-customs requirements, as well as to improve quantity management. The 
long-term objective was (and is still) to decrease smuggling and fraud and make the clearance 
processes  as  efficient  as  possible.  Another  long-term  objective  is  to  improve  the  B2G 
cooperation,  and  certain  steps  have  been  taken  towards  a  sort  of  customs  portal  called  the 
“cPortal”  for  economic  operators.  From  2019,  certain  tax  forms  will  be  submitted  by 
economic operators trough the portal. In the longer term (sometime between 2020 and 2022), 
the  Czech  customs  would  like  to  use  cPortal  also  for  identification  and  authentication  for 
submitting of customs declarations and related processes.   

In line with these priorities, the Czech Republic joined the EU SW-CVED pilot together with 
four other Member States (Bulgaria, Ireland, Latvia and Slovenia) in 2015. The pilot aims to 
enhance G2G collaboration regarding CVED certificates by linking the customs IT system to 
an  EU  certificates  database  called  “TRACES”  though  a  middleware  provided  by  DG 
TAXUD. The Czech Republic decided in end 2017 to join the successor EU CSW-CERTEX 

184   Source: The World Bank. Mean across logistics performance index 2012-2018. 

https://lpi.worldbank.org/international/aggregated-ranking?sort=asc&order=Customs#datatable (accessed 2019-01-11). 
185   Namely the State Veterinary Service, the Central Institute for Supervising and Testing in Agriculture, the Agricultural 

and Food Inspection Authority, the Environmental Inspectorate and the Trade Inspectorate. 

186   In  2007,  the  Czech  Republic  started  with  the  New  Computerized  Transit-System  and  Export  Control  System,  and  in 

2019 with the Import Control System (source: Czech customs).  

Page 155 / 237 

 
 
                                                 
 
project  to  include  CHED-PP,  COI  and  FLEGT  regulatory  requirements  (covered  by  the 
updated  IT  system  “TRACES  NT”).  Regarding  costs  for  connecting  to  the  EU  SW-CVED 
pilot in 2015, these were approximately EUR 63 000 (including costs for including the CITES 
permits in the national solution). An addition of EUR 16 500 occurred for the upgrading of 
the  systems  in  2015,  and  an  extra  EUR  48 000  for  the  implementing  of  FLEGT  in  the  EU 
CSW  CERTEX  during  2018.  These  costs  are  in  other  words  rather  minor  (partly  thanks  to 
much of the needed  IT solutions  being developed at  the EU level). Being a relatively small 
economy in the EU, the Czech Republic appreciates this and finds its more resource efficient 
making use of IT system developed at an EU level than developing them itself.  

Regarding the administrative set-up for the single window initiative, there are two divisions 
involved  in  the  developments:  the  division  for  service  execution  and  the  division  of 
economics  and  IT  technology.  A  ‘single  window  project  team’  has  been  put  together, 
consisting of three officials from the mentioned divisions. The project team is responsible for 
the  development,  maintenance  and  national  implementation  of  the  single  window  plans.  IT 
systems related to the following five regulatory requirements are being handled by the team:  

  Common  Health  Entry  Document  for  Plants  Plant  Products  and  Plant-propagating 

material (CHED-PP); 

  Certificate of Organic Inspection (COI);  

  Common Veterinary Entry Document (CVED);  

  Forest Law Enforcement, Governance and Trade (FLEGT) and  

  Ozone-Depleting Substances (ODS).  

Currently, the project team is especially working with the conformance testing to include the 
FLEGT in the national single window environment. 

The single window project team is coordinated by a steering board, which is also responsible 
for  all  IT  projects  to  be  implemented  according  to  the  Multi  Annual  Strategic  Plan  for 
customs,  namely  the  Import  Control  System  (ICS),  Export  Control  System  (ECS)  and  the 
New  Computerized  Transit  System  (NCTS).  One  customs  official  (both  chairing  the  single 
window  project  team  and  the  steering  board)  is  responsible  for  the  EU  systems  to  be 
developed according to the Multi Annual Strategic Plan. In addition to this, the steering board 
is  also  guiding  the  national  single  window  developments  as  well  as  the  management  of  the 
Excise Movement  and Control System  (EMCS). This  board meets  every  two months and is 
also  responsible  for  the  communication  at  a  national  level.  The  IT  systems  outlined  in  the 
MASP  (i.e.  ICS,  ECS,  EMCS  and  NCTS)  are  prioritised  due  to  them  being  compulsory  to 
implement. 

The  steering  board  is  an  internal  customs  body,  and  is  in  turn  guided  by  the  steering 
committee / group which is a high level, decision-making body with a policy perspective. The 
group  consists  of  officials  from  the  business  and  IT  domains,  as  well  as  the  contractor 
assigned  to  develop  the  IT  solutions.  The  steering  group  handles  the  overall  process 
management  of  all  the  e-customs  projects  and  takes  policy  decisions  based  on  national 
directives and strategies. The steering group meets every third month.  

Figure  21  below  illustrates  the  organisational  set-up  of  the  bodies  working  with  IT 
developments.  

Page 156 / 237 

 
 
Figure 21: Administrative set-up for bodies working with IT developments 

Steering group  

(policy level)  

Steering board 
(operational level, handling 
MASP) 

Import Control System 
(ICS) 

Export Control System 
(ECS) 

Excise Movement and 
Control System  

(EMCS) 

New Computerized Transit 
System  

(NCTS) 

National single 
window (managed 
a project team) 

Source: figure based on interviews with Czech customs officials in Prague, November 2018 

Current experiences  

This section details the nature and scale of the current problems by analysing the processes for 
clearing  goods  through  the  border  in  the  Czech  Republic.  It  first  presents  an  overview  of 
relevant processes, with a focus on the specific types of goods / regulatory requirements, and 
an  outline  of  how  the  EU  SW-CVED  pilot  (and  its  successor  EU  CSW-CERTEX)  work  in 
practice.  This  is  followed  by  more  detail  regarding  the  most  important  problems  with  the 
current  situation  for  different  stakeholder  groups,  namely  customs  authorities,  partner 
competent authorities and economic operators. 

Overview of clearance processes 

In this section we provide an overview of  goods clearance processes in the Czech Republic. 
We  first  outline  customs  processes  (with  a  focus  on  aspects  with  the  highest  level  of  effort 
and  administrative  burden  and  facilitation  measures).  Then  we  outline  the  regulatory 
processes  for  non-customs  requirements.  The  last  part  of  this  section  details  the  processes 
relating to the EU-CSW pilot project.  

Customs processes 

In 2018, Czech customs processed 10,4 million customs declarations, of which around 43% 
are imports and 57% exports, in addition to around 3,4 million transit arrangements187. Some 
of  these  goods  are  subject  to  regulatory  requirements  in  fields  other  than  customs.  In  those 
cases, Czech customs liaise with the concerned partner competent authorities.  

Customs  checks  (i.e.  documentary  and  physical  checks)  apply  to  both  imports  and  exports. 
Only  around  1%  of  the  customs  declarations  are  checked,  based  on  a  risk  management 
system. The checks are carried out in the customs area od customs offices, at warehouses or at 
the airport. Apart from staffing reasons, the low percentage of checks is due to a combination 

187   Source: Czech customs. 

Page 157 / 237 

 
 
 
                                                 
of facilitating tools such as simplified procedures, a number of authorised economic operators 
and post-clearance audits.  

Non-customs regulatory requirements 

When Czech customs officers check import or export declarations for certain goods they may 
be required to check the regulatory requirements under the competence of partner authorities 
are  fulfilled.  As  already  stated,  sometimes  they  must  also  liaise  with  partner  competence 
authorities  for  physical  checks  of  goods.  The  Czech  customs  could  not  estimate  how  often 
this happens, but it does constitute a significant part of the customs’ officials everyday work. 
The  partner  competent  authorities  most  often  consulted  for  verification  processes  related  to 
regulatory  requirements  are  the  Ministry  of  Agriculture  /  State  Veterinary  Service  /  the 
Central  Institute  for  Supervising  and  Testing  in  Agriculture  (for  CVED  and  CHED-PP  and 
FLEGT),  the  State  Agricultural  Intervention  Fund  (for  AGRIM/AGREX  licenses),  the 
Ministry of Industry and Trade (for dual-use licences), Mining Office (for licenses needed for 
explosive  materials)  and  the  Ministry  of  Environment  (for  CITES).  More  specifically,  the 
following  types  of  regulatory  requirements  account  for  the  most  significant  volumes  in  the 
Czech Republic and are by extension the more resource intensive to manage188:  

  Common  Health  Entry  Document  for  Plant  Protection  (CHED-PP)  (N851):  this 
document  covers  Council  Directive  2000/29/EC  on  protective  measures  against  the 
introduction into the Community of organisms harmful to plants or plant products, and 
against their spread within the Community. In 2017, the number of issued CHED-PP 
was 3896. 

  Common Veterinary Entry Document: Animal Products (CVEDP) (N853): this is 
a  common  EU  certificate  for  the  import  of  veterinary  products  –  in  addition  to  the 
certificate, the EU regulation189 sets down rules for the inspection of goods at border 
inspection posts. In 2017, the number of issued CVED-P was 3487. 

  Certificate of quality (N003): Issued for certain fresh fruit and vegetables, issued by 
the Agriculture and Food inspectorate. The volume of certificates of quality was 2214 
in 2017. 

  Common Veterinary Entry Document: Animals (CVEDA) (C640): a common EU 
certificate for the import of animals - in addition to the certificate, the EU regulation190 
sets  down  rules  for  the  inspection  of  goods  at  border  inspection  posts.  In  2017,  the 
number of issued CVED-A was 1613. 

However, other certificates such as the Common Entry Document (CED), the Convention on 
International Trade in Endangered Species of Wild Fauna and Flora (CITES), the Agricultural 
produce  import  licence  (AGRIM)  and  the  Catch  certificate  are  also  significant  compared  to 
the total (with all of them being issued by a number of around 1200 in 2017).  

For  exports,  the  most  common  regulatory  requirement  is  the  dual  use  export 
authorisation  (X002).  This  is  required  for  goods  which  can  be  used  for  both  civil  and 
military purposes (including software and technology), with 6199 certificates issued in 2017). 

188   Source: Homework assignment 1.  
189   Commission  Regulation  (EC)  No  136/2004  of  22  January  2004  laying  down  procedures  for  veterinary  checks  at 

Community border inspection posts on products imported from third countries 

190   Commission  Regulation  (EC)  No  136/2004  of  22  January  2004  laying  down  procedures  for  veterinary  checks  at 

Community border inspection posts on products imported from third countries 

Page 158 / 237 

 
 
                                                 
Processes relating to key regulatory requirements 

As explained already, the Czech Republic participated in the EU SW-CVED pilot project (and 
is  currently  piloting  its  successor,  the  EU  CSW-CERTEX  project)  and  is  combining  this 
together with its own national single window environment. 

The  ambition  of  the  Czech  customs  single  window  is  to,  at  a  later  stage,  enlarge  the  single 
window to as many partner competent authorities and regulatory requirements as relevant and 
possible, as well as to enlarge to a business-to-government solution to make the process also 
easier for economic operators. The regulatory requirement next in line to be included into the 
national single window system is FLEGT (managed by the Ministry of Agriculture). A future 
long-term  objective  of  the  Czech  customs  is  to  digitise  the  entire  clearance  process, 
connecting all concerned partner competent authorities to the single window environment.  

Certain regulatory requirements are however still (and are expected to continuously be) issued 
and  handled  in  paper  format.  This  is  e.g.  the  case  for  regulatory  requirements  concerning 
dual-use  goods,  cultural  goods  and  waste  goods.  Regarding  the  cultural  goods  and  waste, 
these goods constitute a small part191 of the total when it comes to import / export, and this is 
explained as being one of the reasons to why the responsible ministries do not find the costs 
to  digitise  their  processes  as  justified.  In  difference,  the  reason  for  why  the  certificates  for 
dual-use  goods  are  still  in  paper-format  and  is  said  to  be  due  to  security  concerns.  So  far, 
these ministries have no plans in joining the single window initiative.   

Today,  the  Czech  customs  single  window  system  facilitates  G2G  collaboration  for  the 
following regulatory requirements: 

  Common Veterinary Entry Documents (CVED) through the EU SW-CVED project 
(which uses TRACES to link Czech customs, DG TAXUD and DG SANTE). For the 
CVED, information is shared digitally on request. Data is only stored in one database.  

  Convention  on  International  Trade  in  Endangered  Species  of  Wild  Fauna  and 
Flora (CITES) through a joint IT solution with the Ministry of Environment, data is 
shared digitally on request. Data is only stored in one database. 

  Licences for dual-use goods as well as AGREX/AGRIM, through the Mining Office 
respectively the Ministry of Industry and Trade and the State Agriculture Intervention 
Fund.  This  data  is  being  sent  to  the  Czech  Office  automatically  three  times  per  day 
and stored in a database at the Czech customs, i.e. the data is collected in a static way 
and stored in different databases.    

The collected data is  partly used  for verification  reasons,  and partly  for statistical  purposes, 
since it is being sent by the Czech customs to the Czech statistics office. The single window 
solution is also used for the CITES certificates as a way for the Czech customs to report back 
to the Ministry of Environment regarding consumed quantities.  

Currently there are two steps regarding the issuing of CVEDs, one which is done on a paper 
form, and one which is  done electronically. As explained by the interviewed officials at the 
border inspection post of Prague airport, the CVED still have to be issued in paper-format due 
to  the  provisions  of  the  relevant  EU  legislation,  which  requires  the  certificate  to  be  printed 
and submitted physically to the border inspection post. In addition, since automatic quantity 
management is not yet possible through EU SW-CVED pilot. This is instead done manually 
by  the  customs  officers  (they  print  the  document  and  write  by  hand  on  the  back  of  the 

191   In 2017, 1 import license and 85 export licences were issued for cultural goods. The same number for waste certificates 

was 81 for imports and 1380 for exports.  

Page 159 / 237 

 
 
                                                 
document the quantity consumed). The IT systems and communication between the national 
IT system, DG TAXUD and TRACES work very well according to the Czech customs, and if 
EU legislation did not require the paper copy and if quantity management was included in the 
certificate, the issuing of CVEDs (and later on CHED-PPs) process could be done completely 
electronic.  

Figure 22 illustrates the processes involved in the Czech single window environment from the 
perspective  of  Czech  customs,  with  the  brown  arrow  signalling  the  offline  solution  and  the 
green arrows the online solution. 

Figure 22: The national single window environment of the Czech Republic (2018) 

Business 
operator: 
customs 
declaration + 
regulatory 
requirement 

CITES 
Ministry of 
Environment  

Czech customs  

Czech 
Statistics 
Office 

CVED; CED 
DG TAXUD; 
DG SANTE 

Dual-use; army 
material; civil weapons; 
steel and aluminium, 
explosive 
goods;AGREX/AGRIM
; Mining Office, Ministry 
of Industry and Trade; 
State Agricultural Fund 

Source: Study team based on interviews with Czech customs officials  

Main problems in the Czech Republic 

Several  aspects  of  the  abovementioned  processes  create  problems  for  customs,  partner 
competent  authorities  and  economic  operators.  Using  the  problems  defined  in  the  problem 
tree  (see  section  3  of  the  main  study  report)  as  a  starting  point,  the  ensuing  pages  examine 
these  in  detail.  The  impact  of  each  problem  on  different  stakeholders  is  illustrated  using  a 
rating  system,  where  red  denotes  severe,  amber  denotes  significant  and  green  denotes 
negligible (as explained in the box below). 

Rating system:  

Rating  

Explanation of rating 

Major weakness / problem and significant investment / complex solution needed to 
address this issue which affects multiple stakeholders severely.  

Significant weakness / problem and some investment needed to address this issue 
which affects more than one group of stakeholders significantly. 

Page 160 / 237 

 
 
 
 
 
Problem is only negligible and/or could be easily addressed with few regulatory 
hurdles and does not seriously impact any one stakeholder. 

Problem: Administrative burdens in the management of goods crossing boarders   

Rating  

Explanation of rating 

Main stakeholders affected and how 

Problem and change needed to address 
the issuing of paper-document/lack of 
harmonisation of regulatory 
requirements at both national and EU 
level 

  Customs officials: significant time / 

effort processing regulatory requirements 

  Partner competent authorities: significant 

time / effort producing licenses 

  Economic operators: effort applying to 
different authorities in each Member 
State   

The  administrative  problems  in  the  Czech  Republic  mainly  relate  to  certain  documents 
needing to  be dealt with  in  paper format,  which  especially is  the case  for AGRIM licenses, 
dual-use  goods  and  CVED/CHED-PP.  This  is  both  due  to  national  partner  competent 
authorities  without  digitised  processes,  and  to  EU  legislation  lagging  behind  with 
requirements  of hard-copy documents.  The submission of paper documents is  regarded  as  a 
considerable administrative burden for both economic operators and customs officials, but not 
a major burden (which is why this problem is rated as amber). The single window initiative 
has contributed to certain processes being easier – such as interoperability of the IT system of 
the Czech customs and Ministry of Environment (enabling the exchange of information on the 
CITES  certificates).  However,  since  customs  and  partner  competent  authorities  still  need  to 
deal with certain requirements in paper format, the administrative burden has not significantly 
improved since the introduction of the single window.  

Moreover,  the  economic  operators  we  interviewed  stressed  that  it  is  burdensome  for  them 
with the lack of harmonisation across EU Member States. This means that they are obliged to 
apply  through  different  types  of  process  for  regulatory  requirements  in  different  Member 
States.  For  example,  some  Member  States  only  except  certain  regulatory  requirements  in 
paper-format, while other Member States only accept them digitally.   

Problem: Poor exploitation of electronic exchange of information  

Rating  

Explanation of rating 

Main stakeholders affected and how 

Significant investment needed and 
multiple actors with differing levels of 
resource   

  Economic operator / customs officials / 

partner competent authorities: inefficient 
use of resource and not realising full 
benefits of an electronic environment   

Since  far  from  all  partner  competent  authorities  in  the  Czech  Republic  have  digitised  their 
processes, the exploitation of electronic exchange of information is limited. This is both due 
to  the  partner  competent  authorities  finding  the  digitisation  process  too  costly,  and  to  them 
being unwilling to  go digital (at least for the time being) due to e.g. data security concerns. 
However,  the  current  national  single  window  environment  with  its  collaboration  with  the 
Ministry  of  Environment  on  CITES  shows  that  it  is  possible  to  realise  this  type  of 
collaboration, which has proven to be fruitful in terms of smoother and easier data-sharing.  

Neither the Czech customs nor the interviewed partner competent authorities recognized this 
problem as very prominent. However, they did see it as an area with potential of improvement 

Page 161 / 237 

 
 
 
 
 
 
and  saw  that  a  greater  exploitation  of  electronic  exchange  of  information  would  likely 
generate  cost  savings  and  easier  processes  (which  is  why  also  this  problem  is  graded  as 
amber).  

Problem: Multiplication of information and procedural redundancies 

Rating  

Explanation of rating 

Main stakeholders affected and how 

Significant weakness / problem and 
would require legislative change in 
multiple areas to support 
dematerialisation  

  Partner competent authorities / customs 
officials: inefficient use of resource and 
not realising full benefits of an electronic 
environment   

  Economic operators: multiplication of 

information annoying  

Despite some digitised aspects thanks to the single window environment, there is still a lot of 
paper  documents  which  feed  into  the  clearance  process  or  are  required  alongside.  This  is 
especially  clear  when  it  comes  to  the  issuing  of  the  CVEDs.  Due  to  the  SW-CVED  pilot 
project,  the  application  process  for  the  CVEDs  got  digitised.  But  due  EU  legislation,  the 
certificates still need to be printed in paper-document. This means that two parallel processes 
with  both  the  paper-document  being  issued,  and  the  information  being  available  and  stored 
digitally  are  on-going-  In  other  words,  the  full  potential  and  main  objective  of  the  single 
window  environment  has  not  been  possible  to  yet  achieve,  even  if  the  digitisation  has 
contributed to some improvements when data can ben checked by the Border Inspection Post 
digitally. This is the main reason for why this problem is graded as red. 

Again,  the  economic  operators  stressed  that  they  are  being  obliged  to  submit  the  same 
information  several  times  to  different  Member  States  and  that  this  is  an  annoying  (but  not 
major) issue.  

Problem: Enforcement issues and information gaps  

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem needs EU-wide action – 
harmonisation of systems in order to 
have comparable information across 
borders. 

  Customs officials and competent 

authorities: out of date systems act as a 
brake to collaboration  

In some cases, the absence of centralised system and full data sharing between Member States 
can be justified – as in the case of dual-use licenses where data storage is especially sensitive 
due to national security / trade concerns. However, in other cases, poor exploitation / lack of 
electronic exchange of information risks to result in enforcement difficulties of e.g. quotas or 
sanctions. Especially concerns regarding the quantity management were stressed by the Czech 
customs, since this is not something which is included in the single window environment. Due 
to  the lack of uniformity across the EU with  Member States’ systems  of  recording volumes 
etc differentiating, this entails a barrier for EU-wide enforcement of EU (and national) laws to 
fight smuggling and fraud. 

Likely future developments  

Page 162 / 237 

 
 
 
 
This section provides insight on how the problems described above are likely to evolve in the 
future, either through the continuation of the baseline scenario or pursuit of policy options for 
enhanced G2G and / or B2G collaboration. Potential impacts include direct costs and benefits 
for  different  stakeholders,  as  well  as  indirect  effects  related  to  the  implementation  of  and 
compliance with given regulatory requirements. Below we provide a summary of the expected 
impacts under different scenarios, followed by a summary of how well the problems outlined 
in  section  3.2  would  be  addressed.  For  each  problem,  we  provide  a  rating  of  the  expected 
impact (as outlined below). 

Expected impact ratings:  

Rating 

Explanation of rating 

+++ 

Problem would be substantially improved / eradicated  

++ 

Problem would be improved to a significant extent 

+ 

0 

Problem would see some (limited) positive improvement  

Very limited or no change  

Continuation of the baseline scenario in the Czech Republic 

The SW-CVED pilot project  was positively  regarded by the Czech customs as a step in the 
right direction to more digitised and harmonised procedures. The continuation of the current 
situation would mean a gradual expansion of G2G collaboration in the Czech Republic, as the 
scope of the EU CSW-CERTEX would increase to cover additional regulatory requirements, 
i.e. CHED and COI, as well as FLEGT. Even if the Czech Republic has mainly positive views 
about the EU CSW-CERTEX project, interviewees explained that there are several issues that 
need to be adjusted by further action, such as the non-voluntary participation and change of 
EU legislation.   

The  continuation  of  the  baseline  scenario  is  believed  to  hamper  the  efficient  and  effective 
implementation of the projects, especially due to the voluntary nature of participation of the 
EU Member States. Continuing having the initiative voluntary means the continuation of non-
harmonised  procedures  with  some  EU  Member  States  dealing  with  certain  regulatory 
requirements  in  paper-format,  and  others  electronically,  which  especially  is  a  burden  for 
traders  and  economic  operators.  In  addition,  the  baseline  scenario  would  not  support  Czech 
customs in having more partner competent joining the single window initiative, since it means 
a continued voluntary participation in the project.  

Moreover, the baseline scenario would not address the problem of quantity management since 
it does not entail any EU-wide quantity management for all regulatory requirements, nor the 
legislation  to  enable  information  exchange  on  quantity  management  between  customs  and 
partner competent authorities. Most importantly, it means to continued voluntary participation 
in the project, which limits the enforcement of EU-wide quantity management. According to 
the Czech customs, having a common law on EU customs with quantity management would 
benefit Member States since it would make this process much easier. Quantity management 
will  be  technically  available  in  the  EU  CSW-CERTEX  2.0  for  FLEGT,  COI,  CVED/CED, 
CHED-PP,  ODS  licence  and  F-GAS.  But  the  EU  Member  States  that  are  not  part  of  the 
project will continue to follow their national practices, meaning difficulties in knowing about 
volumes consumed in these Member States for EU CSW-CERTEX members.   

Page 163 / 237 

 
 
 
Problem  

Change 

Administrative burdens in the management of goods crossing borders 

+ 

The problem of administrative burdens in the management of goods crossing borders would continue 
to  be  significant  under  the  baseline  scenario.  Without  any  legislative  changes, all  stakeholders  will 
continue to spend significant time / effort dealing with regulatory requirements which are outside of 
the EU CSW-CERTEX. As long as paper continues to be required alongside electronic certificates, as 
well as the CERTEX project being voluntary, the expected improvements in terms of administrative 
burden are estimated to be low. 

However,  both  the  EU  SW-CVED  pilot  and  the  national  single  window  has  born  some  positive 
results, in terms of smoother processes for checking data between Czech customs and certain partner 
competent authorities.  

Multiplication of information and procedural redundancies 

0 

The  multiplication  of  information  and  procedural  redundancies  remain  under  the  baseline  scenario. 
With  no  change  to  the legal  basis for  customs  and/or  non-customs  regulatory requirements, and  no 
single-entry  point  for  data  submission,  parallel  paper  submission  would  continue,  as  would  the 
duplication of information. This means costs would not differ substantially while the duplication of 
information submitted would continue for economic operators. 

Poor exploitation of electronic exchange of information 

+ 

Over-time the electronic exchange of information is expected to improve as more partner competent 
authorities digitise their systems. However, in order for these partner competent authorities to digitise 
their  systems,  a  push  from  an  EU  level  would  be  needed.  The  better  exploitation  of  electronic 
exchange  of  information  also  depends  on  the  harmonisation  of  procedures  in  countries,  which  this 
option does not ensure.   

However,  both  the  EU  SW-CVED  pilot  and  the  national  single  window  has  born  some  positive 
results,  in  terms  of  smoother  processes  for  exchanging  data  between  Czech  customs  and  certain 
partner competent authorities.   

Enforcement issues and information gaps 

0 

The impacts in relation to enforcement gaps and information gaps are very limited under the baseline 
scenario.  The  main  impacts  would  be  similar  to  the  results  of  the  EU  SW-CVED  (i.e.  more 
understanding  of  controls and  more  targeted  searches  through  better  risk  analysis)  but  expanded  in 
line with increased certificates coverage. However, the voluntary nature of EU CSW-CERTEX means 
it lacks a quantity management function which limits the scope for gains in enforcement. 

Options for enhanced G2G collaboration 

These options involve putting in place a legal base to boost back-end, G2G cooperation on the 
exchange of data relating to a different category of certificates and specific technical solutions 
for implementation. The options are not mutually exclusive but can be combined depending 
on the pros and cons of including different certificate categories.  

Page 164 / 237 

 
 
 
Option  1 is regarded as  positive by both  Czech customs and economic operators, especially 
since  it  would  make  the  CERTEX  system  obligatory  for  all  Member  States.  The  potential 
benefits  are  however  dependent  on  developments  (especially  regarding  EU  legislation)  that 
would  allow  a  full  digitisation  process.  The  TRACES  (and  later  TRACES  NT)  system  is 
appreciated  and  Czech  customs  prefers  to  have  such  a  centrally  managed  IT  solution,  both 
from  a  cost  perspective  (since  the  maintenance  costs  then  would  lie  on  DG  TAXUD)  and 
from a data security perspective (since it would mean that data would not have to be stored at 
a  national  level).  The  Czech  customs  could  not  estimate  how  much  cost  savings  centrally 
developed IT solutions generates, but it would at least be a substantial cost.   

Enhanced  G2G  collaboration  with  more  partner  competent  authorities  joining  the  single 
window  initiative  would  also  mean  greater  possibilities  for  the  Czech  customs  to  exchange 
feedback. This was e.g. the case when the CITES got included in the national single window 
initiative,  which  encouraged  Czech  customs  and  Ministry  of  Environment  to  work  more 
closely together. This is also important from a statistic point of view, and would is likely to 
lead to less risk of fraud in the longer run. This type of obligatory cooperation and joining of 
the  CERTEX  project,  also  with  other  EU  Member  States,  would  also  enable  quantity 
management.  To  fully  benefit  from  the  G2G  solutions,  the  EU  legislation  must  change  in 
order to enable completely digital regulatory requirements.  

With  the  G2G  options,  the  Czech  Republic  would  prefer  for  as  many  EU-wide  regulatory 
requirements as possible to be included. National regulatory requirements are not wished for 
to be included or made possible to access for other EU Member States since it is believed to 
mean  too  great  security  issues.  However,  having  some  IT  solutions  on  third-country 
regulatory requirements (as stipulated in option 4) would be interesting, e.g. when it comes to 
the FLEGT certificate where the Czech Republic has a lot of trade with Indonesia. However, 
this was said to be not a very realistic option.  

Furthermore,  the  Czech  Republic  would  prefer  having  a  centralised  solution,  i.e.  routing 
information  through  the  CERTEX  system,  since  this  type  of  management  would  make  the 
procedures  more  harmonised  and  secure,  compared  to  bilateral  agreements  between  EU 
Member States. 

The table below sums up the expected impacts for enhanced G2G collaboration for the Czech 
Republic for the most pertinent options discussed above. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ (++) 

Depending on the scope of enhanced G2G collaboration, the improvements relating to administrative 
burden could be limited (if there is simply a continued expansion of CERTEX) or more significant. 
For  the  benefits  to  be  significant,  it  would  be  important  for  all  EU  regulatory  requirements  to  be 
accepted digitally and the introduction of quantity management.  

Multiplication of information and procedural redundancies 

+ 

As with the baseline scenario, enhanced G2G collaboration does not necessarily mean a reduction in 
multiplication of information or procedural redundancies. This would require a single-entry point for 
economic  operators  (as  per  B2G  collaboration  outlined  overleaf).  However,  enhanced  G2G 
collaboration could have a positive effect on this aspect if procedures and IT systems get harmonised 
/ made interoperable between partner competent authorities and customs. 

Page 165 / 237 

 
 
Poor exploitation of electronic exchange of information 

++ 

As with customs, economic operators would stand to gain from more seamless connections between 
government  (nationally  and  with  third  party  governments).  This  would  need  to  be  supported  by 
digital signatures to allow for a fully paperless system and a change in costs (i.e. removing / reducing 
the  need  to  send  documents  by  courier  as  well  as  electronically).  The  costs  of  upgrading  partner 
competent authorities’ systems would likely be significant, but would lead to benefits for all in terms 
of smoother operations. 

Enforcement issues and information gaps 

++ 

Enhanced  G2G  collaboration  would  open  opportunities  for  improved  enforcement  and  lead  to 
improvements  in  understanding  of  the  scale  of  problems,  especially  if  the  legal  basis  allows  for 
quantity management. The scale of impact is difficult to estimate but would be positive. 

Options for enhanced B2G collaboration 

Options  5-7  are  about  business-to-government  (B2G),  front-end  cooperation  that  focus  on 
different  ways  of streamlining reporting processes for the economic operators when dealing 
with  the regulatory requirements.  The options for B2G collaboration are  mutually  exclusive 
(meaning only one can be pursued) and range from no action (covered under section 4.1); a 
common  management  portal  (option  5);  interoperable  national  Customs  Single  Windows 
(option 6) and Single EU Customs Single Window trader portal (option 7).  

Both  Czech  customs  and  Czech  economic  operators  want  to  see  advancements  on  the  B2G 
collaboration and all options are welcomed. Option 7 is though regarded as the most preferred 
solution,  since  it  is  very  likely  to  generate  cost  and  time  savings.  However,  Czech  customs 
sees  the  option  as  not  very  feasible  since  it  would  require  substantial  IT  changes  and 
investments  for  all  EU  Member  States.  This  solution  requires  substantial  political  will  at 
European level.  

Option 6 is seen as the most realistic option by Czech customs, even if it would require large 
investments  to  digitise  all  partner  competent  authorities’  processes.  However,  the  benefits 
from doing so in terms of time savings and more secure processes (leading to less fraud and 
smuggling) suggest that the investments would be overweighed by the benefits in the longer 
term. A central solution with DG TAXUD as the coordinator / hub is wished for whichever 
solution that would be perceived. Czech customs would like to see this option together with a 
single-entry point authentication and authorisation, and with connectivity with other Member 
States, and with other IT projects / systems such as de UUMDS, CDMS or the Generic Trader 
Portal. 

The table below sums up the expected impacts for enhanced G2B collaboration for the Czech 
Republic for the most pertinent options discussed above. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+++ 

The  improvements  relating  to  administrative  burden  for  economic  operators  could  be  significant, 
meaning costs savings with less administrative work with only one single entry point. Benefits would 
especially  arise  if  regulatory  requirements  today  issued  in  paper-format  would  be  included  in  the 

Page 166 / 237 

 
 
 
digital solution. 

Multiplication of information and procedural redundancies 

++ 

This would be significantly improved with a single-entry point which would necessarily reduce the 
multiplication of information and could reduce procedural redundancies for all stakeholders, as well 
lead to cost-savings.  

Poor exploitation of electronic exchange of information 

++ 

This would be significantly improved with a single-entry point which would need to be supported by 
full  exploitation  of  electronic  exchange  of  information.  The  benefits  would  bring  added  value  (in 
terms of easier and safer process) for both the officials and economic operators, but not change the 
situation substantially due to the scale of the problem being medium.   

Enforcement issues and information gaps 

++ 

The impacts from enhanced B2G collaboration vis-à-vis enforcement issues may occur as 
a more integrated system provides economic operators with a single reference outlining in 
one place all their obligations (some of which they have might be previously unaware of). 

Conclusions 

This  final  section  draws  conclusions  related  to  the  severity  of  the  problem  in  The  Czech 
Republic and desirability and impacts of the different policy options.  

Nature and scale of problems with the current situation 

The current situation in the Czech Republic illustrates a country that is eager to digitise their 
customs  processes  but  is  hampered  by  issues  relating  to  legislation  or  lack  of  competence  / 
resources. Today, the country has a system with a mix of digital and paper-based regulatory 
requirements.  This  means  that  the  administrative  burden  in  management  of  goods  crossing 
borders is relatively prominent for both officials and economic operators. The exploitation of 
electronic exchange of information is improving (thanks to the single window initiatives) but 
has  a  lot  of  potential  to  improve  even  more  if  more  partner  competent  authorities  would 
digitise their processes. 

The  more  severe  problems  are  about  multiplication  of  information  and  enforcement  issues. 
Both these problems relate to a lack of harmonisation of data and procedures, especially at an 
EU level, meaning that the Czech Republic itself could not do much to solve these problems 
without EU action.  

Problem  

Rating 

Administrative burdens in the management of goods crossing borders 

Poor exploitation of electronic exchange of information  

Multiplication of information and procedural redundancies 

Enforcement issues and information gaps 

Assessment of EU SW-CVED 

Page 167 / 237 

 
 
 
 
 
 
 
 
The Czech Republic has great ambitions of expanding the single window environment and is 
eager to continue the developments of the EU CSW-CERTEX project. However, the country 
is struggling with achieving its objectives due to voluntary Member State participation in the 
EU  CSW-CERTEX  project,  EU  legislation  demanding  paper-copies  and  a  lack  of  clear 
mandate within the country to decide for partner competent authorities to join initiative. The 
EU SW-CVED pilot has made the process smoother for issuing CVEDs, but not as smooth as 
one could hope for (since paper documents are continued to be issued alongside). Regarding 
costs,  it  is  difficult  to  assess  any  exact  numbers,  but  according  to  customs  officials  the 
benefits are likely to overweigh the costs in the long-term, with cost savings of less staffing 
and more efficient procedures – as well as less fraud.  

Feasibility and desirability of the policy options 

The  most  desirable  and  the  most  feasible  scenario  are  inversely  related  in  the  case  of  the 
Czech Republic, as briefly summarised below.  

Scenarios 

Baseline: The baseline scenario would see marginal or no improvements and does not address the main 
problems for the Czech Republic.   

G2G: The expected impacts of enhanced G2G collaboration could be high, especially if paper-
documents were no longer required for regulatory requirements. For the Czech Republic, the most 
important aspect is to make the EU CSW-CERTEX obligatory for all Member States to join, in order to 
enable quantity management (and thereby contribute to the enforcement of EU law to fight smuggling 
and fraud). Moreover, the Czech Republic would prefer IT solutions being developed and maintained 
at an EU level, both to ensure the harmonisation of systems and data across the Member States, and to 
avoid to high costs for the Czech Republic.  

B2G: The B2G solutions are very positively regarded by the Czech Republic, but the G2G solutions 
are prioritised to start with. Despite the more significant expected impacts of option 6 for B2G across 
all problems (and therefore its desirability), the feasibility is at the moment rather low in with too high 
upfront investments required as well as coordination among many partner competent authorities. 

Page 168 / 237 

 
 
 
 
 
 
 
 
FRANCE  

Introduction  

This report is one of the eight country case studies that were carried out to provide evidence 
for the impact assessment of the initiative for developing an EU Single Window environment 
for  customs.  By  collecting  and  analysing  data  on  the  current  situation  and  expected  future 
developments, the case studies aim to generate insight on the nature and scale of any existing 
problems and likely impacts of the policy options defined for the initiative. These include an 
option  for  no  additional  EU  action,  which  would  consist  of  the  continued  existence  and 
gradual  expansion of the EU Customs Single Window-CERTEX project  (simply referred to 
below as CERTEX project). 

Each case study used a common methodology based on a documentary review, feedback from 
national  administrations  provided  through  participation  in  the  project  group  and  interviews 
(mainly  face-to-face)  with  officials  from  customs  and  partner  competent  authorities,  and 
economic operators. The sample of eight Member States was selected in discussion with DG 
TAXUD with a view to covering complementary areas of interest and achieving a degree of 
representativeness.  

Within  this  broader  framework,  the  research  on  individual  case  studies  varied  according  to 
national  specificities  such  as  geography, 
trading  profile,  administrative  set-up  and 
participation in  the EU Single Window-CVED (Common Veterinary Entry Document) pilot 
project (the predecessor to the CERTEX project). 

For France, the case study focused on:  

  Experiences with implementing the national Single Window environment; 

  Reasons  for  not  joining  the  EU  SW-CVED  pilot  and  future  participation  in  the 

CERTEX project; 

  Controls related to export/import of diverse products (AGRIM, CVED and CHED-PP, 

dual use goods, military equipment). 

The evidence for the case study is comprised of desk research and a set of interviews that took 
place  during  the  week  of  3  December  2018.  The  14  interviewees  included  the  customs 
authority  (both  business  and  IT  units),  partner  competent  authorities  responsible  for 
agriculture,  food  and  plant  products,  and  economic  operators  dealing  with  logistics  and  the 
import and export of aerospace and dual-use goods.  

Background  

This  section  presents  an  overview  of  France’s  profile  for  international  trade,  administrative 
and IT set-up for customs and other relevant regulatory requirements, to help understand the 
current  situation  in  France  and  how  it  would  likely  evolve  with  the  policy  options  under 
review. It also briefly presents the national Single Window environment for customs. 

Trading profile 
France’s economy is the third largest in the EU28192. In 2017 (the latest year for which there 
is data), French sales of exported goods represented 9.2% of total EU exports, making it the 
second largest export country in the EU, after Germany.193 Over a seven year period (2011- 

192   European Union, 2018 (see 

https://ec.europa.eu/eurostat/web/products-eurostat-news/-/DDN-20180511-1?inheritRedirect=true) 

193   http://www.worldstopexports.com/top-european-export-countries/ 

Page 169 / 237 

 
 
                                                 
 
2017)  France  accounted  for  about  9.4%  of  EU  imports  and  10.5%  of  EU  exports.194  Most 
French  exports  and  imports  are  to/from  the  United  States  (7%  and  6%  respectively),  and 
China (4% and 5% respectively). 

The main port of entry is Paris Charles de Gaulle Airport. However, in the context of Brexit, 
French customs authorities aim to enhance performance of the ports on the Northern coast, by 
optimising  clearance  processes.  The  UK’s  exit  from  the  EU  will  have  a  direct  impact  on 
customs authorities, economic operations and transport platforms in France. As such, Brexit is 
a significant, logistical and control challenge for these ports and for the cross-Channel fixed 
link.195  French  customs  authorities  have  created  a  “Brexit  mission”,  which  is  assessing  the 
impact of Brexit on customs authorities and economic operators. 

To  get  an  idea  of  France’s  efficiency  in  clearing  goods,  we  looked  at  the  World  Bank’s 
Logistics Performance Index196. In 2018, France ranked highly (16th globally, and 9th among 
EU member States) in terms of trade logistics, including customs performance, infrastructure 
quality,  and  timeliness  of  shipments.197  In  terms  of  customs  specifically198,  France  ranked 
slightly lower, both  globally (19th) and among Member States (10th). Of the six components 
used to calculate the ranking, customs and international shipments199 were the highest scoring 
in France, indicating the clearance process is relatively efficient. 

Administrative set-up 

Several  authorities  have  responsibility  for  matters  that  relate  to  the  Single  Window 
environment  for  customs.  Overall  responsibility  for  border  management  is  held  by  the 
Direction  Générale  des  Douanes  et  Droits  Indirects  (DGDDI),  “Directorate  General  of 
Customs  and  Excise”.  Usually  referred  to  simply  as  “la  douane”  (customs),  it  is  the  French 
law enforcement agency responsible for customs, excise, taxation and related matters200. The 
agency acts as a coast guard, border guard, sea rescue organisation and a customs service.  

Customs works with partner competent authorities (ministries, associations, and other public 
administrations)  to  enforce  legislation  relating  to  prohibitions  and  restrictions  for  various 
goods and services201, such as the Ministry for Agriculture and Food, Directorate General for 
Food  (DGAL)  or  the  National  Interprofessional  Seeds  Association  (Groupement  National 
Interprofessionnel des Semences et des plants – GNIS). 

About  15  competent  authorities  are  responsible  for  controlling  the  import  and  export  of 
various goods,  applying more than 50 regulatory requirements, and delivering more than 30 
Documents  d’Ordre  Public  (DOP),  “documents  of  public  order”  (hereafter  referred  to  as 
“supporting  documents”).  These  relate  to  the  implementation  of  national,  European 

194   Eurostat data on external trade, average for 2011-2017: 

 https://ec.europa.eu/eurostat/web/international-trade-

in-goods/data/database  

195   Douane  francaise,  Conference  de  presse  de  Gerald  Darmanin  sur  les  résultats  de  la  douane  française  pour  2017 

https://www.youtube.com/watch?v=tmgbxh5Gyaw&feature=youtu.be 

196   The LPI relies on an online survey of logistics professionals from the companies responsible for moving goods around 
the  world:  multinational  freight  forwarders  and  the  main  express  carriers.  Freight  forwarders  and  express  carriers  are 
best positioned to assess how countries perform. 

197   The World Bank Group, 2018 (see  

https://lpi.worldbank.org/international/global?sort=asc&order=LPI%20Rank#datatable)  

198   defined as “Efficiency of the clearance process (i.e., speed, simplicity and predictability of formalities) by border control 

agencies, including customs” 

199   Defined as “ease of arranging competitively priced shipments” 
200   Including  preventing  smuggling,  surveillance  of  borders  and  investigating  counterfeit  money.  Since  1995,  the  agency 
has replaced the Border Police in carrying out immigration control at smaller border checkpoints, at maritime borders 
and regional airports. Officers are routinely armed. 

201   A full list of prohibitions and restrictions and relevant government authorities/ departments available here:  

http://www.douane.gouv.fr/articles/a10913-restriction-de-circulation-ou-interdiction-de-certaines-marchandises 

Page 170 / 237 

 
 
                                                 
 
regulations,  or  international  conventions  such  as  the  Convention  on  International  Trade  in 
Endangered Species (CITES). 

Approach to electronic customs and IT architecture 

Digitisation  has  been  one  of  France’s  priorities  for  a  long  time.  It  is  part  of  a  broader 
simplification  programme202  announced  by  the  President  of  France  in  2013,  for  all  public 
services.  Simplification  is  intended  to  make  procedures  faster  and  more  efficient,  for  both 
citizens  and  economic  operators,  with  the  aim  to  stimulate  the  economy.  For  economic 
operators,  it  means  time  and  money  savings,  through  reduced  excessive  and/or  useless 
administrative burdens, a clearer and safer, but also more flexible, legal environment. 
The French Single Window environment, referred to in France as the “GUN”203, is one of the 
485  measures  of  the  simplification  programme.  It  is  a  technical  solution  to  remove  the  last 
barriers to full digitisation of the customs clearance process. It is part of a move towards more 
competitiveness and support to international trade through speed, security, and collaboration 
with economic operators. Within France it is seen as part of the broader international efforts 
promoted  by  the  United  Nations,  the  World  Trade  Organisation  and  the  EU,  to  facilitate 
global  trade  through  digitisation  of  customs  formalities  and  electronic  exchange  of 
information. 

The  national  IT  architecture  combines  EU  trans-national  systems  and  nationally  developed 
systems,  which  are  collectively  used  for  customs  declarations  and  clearance,  risk 
management,  cargo  manifests  and  transit.  It  is  based  on  a  connection  between  customs 
authorities’  system  (“DELT@-G”),  and  partner  competent  authorities’  systems.  Centralised 
EU systems are also contacted during the clearance process. The connection is web-service to 
web-service, supported by a digital authentication system. 

Single Window state of play and key initiatives  

The ”GUN” is a system  that allows the automated control of supporting  documents that are 
required for customs clearance. It is part of the 2008 governmental programme to reduce and 
simplify the administrative burdens on economic operators. Two main criteria where used to 
identify  which  supporting  documents  to  start  with:  the  number  of  customs  declarations 
involved per year and the preparedness of the partner competent authority. 

The  first  connection  was  established  in  December  2015  between  DELT@-G  (customs’ 
system) and i-CITES the Direction Générale de l'Aménagement, du Logement et de la Nature 
(DGALN),  “Directorate-General  for  Planning,  Housing  and  Nature’s”  IT  system.  As  of 
December  2108,  customs  authorities  had  established  links  with  five  partner  competent 
authorities:204 

  January  2016 :  The  Groupement  National  Interprofessionnel  des  Semences  et  des 

plants (GNIS), "National Interprofessional Seeds Association"; 

  June 2016: FranceAgriMer, the French farm office; 

  January  2017 :  The  Institut  de  radioprotection  et  de  sûreté  nucléaire  (IRSN), 

"Radioprotection and Nuclear Safety Institute"; 

  June  2018:  the  Service  des  Biens  à  Double  Usage  (SBDU),  Services  for  dual-use 

goods. 

202   http://simplification.modernisation.gouv.fr/programme-de-simplification/  
203   Guichet Unique National (GUN) du dédouanement 
204   Two more links were in test phase. 

Page 171 / 237 

 
 
                                                 
France decided not to participate in the EU SW-CVED pilot, which allows the EU database 
(TRACES)  to  issue  and  store  CVEDs  to  connect  with  national  customs  processes  in 
participant  countries,  for  two  reasons:  French  customs  wanted  to  keep  the  quantity 
management  functionality205  that  their  system  allows  for,  and  they  were  interested  in 
obtaining  a  PDF  version  of  the  documents  stored  in  the  EU  database,  but  this  functionality 
(which would have allowed for the data to be used) was not part of the pilot. 

Without  these  functions,  the  pilot  was  not  useful  for  France.  Instead,  French  customs 
authorities  created  a  mirror  database,  which  they  call  “TRACES  FR”.  This  version  is 
managed nationally, by French customs, and allows for national level quantity management. 
The inclusion of quantity management and PDFs to the next iteration of TRACES, TRACES 
NT, means France is planning on joining the CERTEX project. 

Current experiences 

This section details the nature and scale of the current problems by analysing the processes for 
clearing goods crossing the French border. It first presents an overview of relevant processes, 
with a focus on specific types of goods and associated regulatory requirements. It then gives 
more detail on the most important problems with the current situation for different stakeholder 
groups. 

Overview of clearance processes 

In  this  section  we  provide  an  overview  of  customs  clearance  processes  in  France.  We  first 
outline facilitation measures as part of the French Single Window environment for customs, 
including regulatory processes for non-customs requirements. The second part of this section 
provides an example of the implementation of a connection between customs’ system and a 
partner competent authority’s system. 

The Single Window environment for customs in France 

In  2017,  French  customs  processed  around  11  million  customs  declarations,  of  which  51% 
were  exports,  31%  imports,  and  18%  transit  arrangements206.  7.9  million  declarations  were 
processed  through  the  Import  Control  System  (ICS)207,  an  increase  of  8,2%  compared  to 
2016.208  Of  the  5.82m  export  declarations,  about  4%  required  supporting  documents  from 
competent authorities209. Of the 3.53m import declarations210, about 7% required supporting 
documents  from  competent  authorities.211  Of  these  467 000  customs  declarations  requiring 
supporting documents from other authorities, in 2017, about 9.2% were processed through the 
“GUN”.  In  2017,  the  following  types  of  regulatory  requirements  accounted  for  the  most 
significant volumes in France, all of which are included in “GUN”: 

205   Customs authorities record the entrance of the goods on the customs territory and give tangible form to it through the 
“attribution douaniere”. This is an annotation on the title, mentioning quantity and value of the goods, number and date 
of the customs declaration. 

206   The codes used in the transit system are listed in Appendix D2 of Commission Delegated Regulation (EU) 2016/341 of 
17 December 2015 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council. The 
designations  of  these  codes  are  not  as  precise  as  those  in  TARIC  (e.g.  there  is  no  distinction  between  CVEDA  and 
CVEDP)  and  the  code  ZZZ  “other”  is  used  for  many  required  documents,  such  as  CITES  permits  and  various  other 
commercial documents. 

207   EU regulation requires operators to make a declaration before importing from third countries. 
208   Direction générale des douanes et droits indirects, 2018, AGIR pour protéger – Résultats 2017 
209   For certain goods, regulatory requirements under the competence of partner administrations are to be fulfilled and added 

to the customs declaration. 

210   Not including small parcels declared through a special electronic clearance procedure. 
211   Customs  declarations  requiring  a  supporting  document  can  be  traced  in  customs’  system,  DELT@-G,  by  mentioning 
specific  codes  in  box  44  of  the  SAD.  Estimations  provided  by  French  customs  are  based  on  a  search  for  the  main 
supporting documents issued by other administrations in box 44. 

Page 172 / 237 

 
 
                                                 
  69,900  (export)  and  26 000  (import)  certificates  of  conformity  for  fruits  and 

vegetables (N002 / national code 2024); 

  50,100  registration  certificates  for  exports  of  second-hand  vehicles  (national 

regulation code 0030); 

  47,900 Common Health Entry Documents for Plant Protection (CHED-PP) (N851) – 
this  document  covers  Council  Directive  2000/29/EC  on  protective  measures  against 
the introduction into the Community of organisms harmful to plants or plant products, 
and against their spread within the Community; 

  46,600 notifications of importation for fruits and vegetables, endorsed by the national 
control  body  (Commission  Implementing  Regulation  (EU)  No  543/2011212,  code 
2026); 

  41,200 Common Veterinary Entry Document: Animal Products CVEDP (N853) – this 

is a common EU certificate for the import of veterinary products213. 

To  enforce  these  requirements  and  the  automated  control  of  the  associated  supporting 
documents,  French  customs  worked  with  partner  competent  authorities,  to  connect  their  IT 
system to DELT@-G, through the “GUN”. This IT system is the basis on which to establish 
these  connections.  The  link  can  only  be  established  if  the  partner  authority’s  system  meets 
certain  requirements,  including  the  quantity  management  function,  stability  and  maturity214. 
The process flow is summarised in annex to this case study report. 

The process for import and export of goods requiring supporting documents included in the 
French Single Window environment is illustrated in the figure below. 

Figure 23: The French Single Window environment for customs 

Source:  adapted  from  Direction  Générale  des  Douanes  et  Droits  Indirects,  Le  GUN  –  Le  Guichet  Unique 
National du dedouanement, September 2017 

212   of 7 June 2011 laying down detailed rules for the application of Council Regulation (EC) No 1234/2007 in respect of the 

fruit and vegetables and processed fruit and vegetables sectors 

213   Commission  Regulation  (EC)  No  136/2004  of  22  January  2004  laying  down  procedures  for  veterinary  checks  at 

Community border inspection posts on products imported from third countries 

214   For military goods for example, the Directorate General of Armaments’ (Direction Générale de l’Armement – DGA) IT 

system is not yet stable and a link with the SW is therefore on hold.  

Page 173 / 237 

 
 
 
                                                 
Since the first connection was established in December 2015, the “GUN” processed 117,820 
customs  declarations.  This  has  increased  with  the  on-boarding  of  new  partner  competent 
authorities. As a result, during the first 10 months of 2018, 38,145 customs declarations were 
processed,  including  more  than  70 000  supporting  documents  that  were  automatically 
controlled through the “GUN”. The figure below presents the share of Single Administrative 
Documents (SADs) dealt with through the “GUN” since its implementation, for each partner 
competent authority. 

Figure 24: Number of declarations processed through the “GUN” 

Source:  adapted  from  Direction  Générale  des  Douanes  et  Droits  Indirects,  Le  GUN  –  Le  Guichet  Unique 
National du dedouanement, September 2017 

In  2018,  three  major  functional  developments  of  the  French  Single  Window  environment 
occurred: 

  Extension  of  the  connection  with  the  GNIS,  "National  Interprofessional  Seeds 
Association",  through  the  sending  back  of  amended  customs  declarations  after 
deliverance of the routing order (detailed box on this below); 

  Two extensions of perimeter for the existing connection with  FranceAgriMer for the 
automated control of additional Agri-food products (milk products to the US and rice) 
requiring Export certificate (AGREX); 
Implementation  of  a  fifth  connection  between  DELT@-G  and  the  system  of  the 
Services for dual-use goods. 

 

Example of a “GUN” connection 

The  following  box  presents  how  the  interface  between  DELT@-G  and  a  partner  competent 
authority’s system, the GNIS – National Interprofessional Seeds Association’s system was set 
up. 

Timeline: Work started end of 2013; connection started end of January 2016. 

Workload: 150-200 person-days for the development of the extranet and interface 

Budget: EUR 400/day – approximately EUR 80 000 

Regulatory basis: 

  Council Directive 2002/53/EC of 13 June 2002 on the common catalogue of varieties of agricultural plant 

species 

  Council Directive 2002/55/EC of 13 June 2002 on the marketing of vegetable seed 

Both directives indicate that only varieties that are registered in the official catalogue can be sold on the EU 

Page 174 / 237 

 
 
 
territory.  According  to  the  national  system,  the  GNIS  is  responsible  for  delivering  an  administrative  visa 
before  the  import.  This  visa  used  to  take  the  shape  of  a  paper  Import  Request  with  three  sections:  one  for 
customs, one for the GNIS and one for the company. 

Volume: 

 

 

 

7 000 import requests /year 

16 companies making more than 100 import requests /year 

1 company making 1 100 import requests /year 

Objective of the project: simplify, facilitate, and increase security of procedures  

Workflow: 

1.  Economic operators – Application on the GNIS’ extranet. Economic operators can validate and send 
the form when completed, but also manage, and sort out validated, used and expired applications. 

2.  GNIS  –  Treatment  of  the  application.  Economic  operators  receive  an  email  when  the  visa  is 

delivered. 

3. 

Interface  Customs-GNIS  –  After  the  reservation,  economic  operators  can  view  availability  on  the 
GNIS’ extranet. Expired visas close after 6 months.  

Outcomes for economic operators: 

  Removal of the administrative burden linked to mail exchanges with the GNIS 

  Management and monitoring tool for applications 

  Reduced delays 

Outcomes for the GNIS: 

  Removal of the administrative burden linked to mail exchanges with economic operators, and of the 

costs of paper documents 

  Removal of the administrative burden linked to the physical stamp on the three sections of the Import 

Request, and of its archiving 

  Same effectiveness of regulatory controls 

  Data processing – no more manual data entry for external trade statistics 

  Development of the extranet 

Main problems in France 

Several  aspects  of  the  abovementioned  processes  create  problems  for  customs,  partner 
competent  authorities  and  economic  operators;  while  there  are  also  aspects  that  are  typical 
problems  elsewhere,  which  are  less  of  a  problem  in  France  because  of  national  initiatives. 
Using the problem tree (see section 3 of the main study report) as a starting point, the ensuing 
pages  examine  the  different  elements  in  detail.  The  impact  of  each  problem  on  different 
stakeholders  is  illustrated  using  a  rating  system,  where  red  denotes  severe,  amber  denotes 
significant and green denotes negligible, as explained in the box below. 

Rating  

Explanation of rating 

Major weakness/problem and significant investment / complex solution needed to 
address this issue, which affects multiple stakeholders severely. 

Page 175 / 237 

 
 
 
 
Significant weakness/problem and some investment needed to address this issue, 
which affects more than one group of stakeholders significantly. 

Problem is only negligible and/or could be easily addressed with few regulatory 
hurdles and does not seriously impact any stakeholder. 

Problem: Administrative burdens in the management of goods crossing borders   

Rating  

Explanation of rating 

Main stakeholders affected and how 

Problem is only negligible in France as 
the national Single Window 
environment allows customs 
authorities’ IT system to go look for 
the competent authority’s supporting 
document in their system (which is 
the case for the highest volumes of 
supporting documents entering/exiting 
France), although this does not cover 
all supporting documents or 
authorities there are no major barriers 
to its extension  

  Customs officials: no time/effort 

 

 

processing supporting documents, where 
a GUN connection exists. 
Partner competent authorities: no 
time/effort exchanging with economic 
operators, where a GUN connection 
exists 
Economic operators: still apply to 
different competent authorities in each 
Member State 

Administrative burdens in the management of goods crossing borders were not considered to 
be  a  significant  problem  in  France,  for  customs  and  partner  competent  authorities,  nor  for 
economic operators. The “GUN” has already brought benefits in terms of efficiently reducing 
the administrative burden in the management of goods crossing borders.  

Customs  authorities’  IT  system  draws  and  checks  information  directly  from  the  partner 
competent authority through the “GUN”, whereas before they had to wait for the documents 
to be manually checked. Human intervention is now about bringing added value: officers do a 
qualitative control  when the system indicates  an error, instead of a systematically checking. 
Similarly, partner competent authorities see the reduced administrative burden through greater 
automation as a benefit. 

Nonetheless,  the  “GUN”  is  still  a  work  in  progress,  as  only  five  connections  exist  as  of 
December  2018,  concerning  a  small  proportion  of  all  the  supporting  documents  despite 
covering the most important (volume-wise) supporting documents for goods in and out of the 
country. 

Problem: Poor exploitation of electronic exchange of information  

Rating  

Explanation of rating 

Main stakeholders affected and how 

Several actors with differing levels of 
digitisation at national and EU levels 
Lack of communication/ 
interoperability between systems 

  Customs officials: limitation of the extent 
to which they can extend the French 
Single Window environment 
  Competent authorities: lack of IT 

 

systems 
Economic operator: G2G – Limited 
impact 

Poor  exploitation  of  electronic  exchange  of  information  remains  an  issue  in  France,  despite 
the  clear  majority  (88%)  of  its  international  trade-related  procedures  being  digital.  The 
“GUN”  initiative  was  used  by  some  partner  competent  authorities  to  push  the  digitisation 
agenda.  Where  there  has  been  digitisation  this  has  already  brought  benefits,  for  instance  in 
terms of making it possible to trace goods, the authority delivering the document knows when 
it  is  being  used,  as  do  economic  operators  and  customs  authorities,  leading  to  better 
monitoring of the use of the supporting documents, and of their chronology.  

Page 176 / 237 

 
 
 
 
 
 
Yet,  some  competent  authorities have not fully  digitised their systems,  while others operate 
without  an  IT  system  in  place  for  regulatory  requirements.  The  Direction  générale  des 
patrimoines, “Department of National Heritage”, for example, does not have an IT system for 
managing supporting documents, and issues them in hard copy. This is a clear barrier to fully 
digitising  customs  clearance  processes.  From  a  customs’  point  of  view,  the  more  digitised 
processes for regulatory requirements the better – as the costs of bridging systems are minor 
compared to the benefits of integrated digital processes. 

This is also the case at EU level, where not all Member States are digitised, clearly limiting 
the  extent  to  which  the  electronic  exchange  of  information  can  happen.  In  addition,  where 
Member States do have fully functioning IT systems, these are not necessarily interoperable 
(meaning  electronic  exchange  of  information  cannot  happen  at  EU  level).  For  example,  the 
second  exporter  of  dual-use  goods  in  France  uses  Dutch  licences,  which  French  customs 
cannot  have  access  to.  This  means  that  economic  operators  need  a  paper  version  of  the 
document  for  customs  clearance  in  France.  Indeed,  customs  clearance  of  goods  using 
supporting  documents  delivered  by  another  Member  State  is  possible  based  on  a  paper 
version of the documents. The digitisation of this process would therefore only be possible if 
electronic  exchange  of  information  between  Member  States’  competent  authorities  were 
possible.215 

Even when there is an EU-level system in place, such as TRACES, its potential functionalities 
for exchange of electronic information are not properly exploited, as explained above. So as 
of December 2018, quantity management and monitoring of the goods is only national.  

Problem: Multiplication of information and procedural redundancies 

Rating  

Explanation of rating 

Main stakeholders affected and how 

Procedural redundancies exist in 
France when digitised supporting 
documents must be printed out due to 
international legislation 

  Customs and competent authorities: 

 

limited impact   
Economic operators: when a paper 
version of a digitised document is needed 
this creates extra work with no added 
value 

Multiplication of information and procedural redundancies were not presented as a significant 
problem in France, whether it be by customs or partner competent authorities. 

Nonetheless, there are cases of procedural redundancies, with some digitised documents that 
must also be presented in paper format for example. This is the case with CITES. The “GUN” 
looks  for  the  import/export  permit  or  re-export  certificate  in  the  Management  Authority’s 
database,  extracts  the  information  in  a  PDF,  which  is  incorporated  into  the  automatic 
authorisation 
the 
permit/certificate.  The  added  value  of  the  “GUN”  is  therefore  diminished  for  economic 
operators  due  to  a  legal  obligation  emanating  from  an  international  convention.216  This  is 
particularly paradoxical given that CITES permits/certificates constituted on average 75% of 
the  declarations  dealt  with  through  the  “GUN”  (see  figure  3).217  Nonetheless,  the  GUN 
connection between DELT@-G and iCITES does bring benefits to economic operators since 

in  Customs’  system.  But  economic  operators  must 

then  print 

215   The  EU  is  working  on  improving  dual-use  controls,  to  move  from  DUeS  to  electronic  licensing.  See: 

http://trade.ec.europa.eu/doclib/docs/2017/december/tradoc_156495.pdf and  
https://supportoffice.jp/outreach/2017/asian_ec/pdf/29Mr.StephaneChardonEU.pdf. 

216   Note that the French Directorate-General for Planning, Housing and Nature and its Swiss counterpart are working on the 
full  digitisation  of  CITES  permits  between  the  two  countries.  Switzerland  represents  around  25%  of  France’s  CITES 
trade with third country. 

217   Note that with the new GUN connections planned for 2019 and the improvements of the one with the Services for dual-

use goods, the share of CITES among the declarations dealt with through the GUN will decrease considerably. 

Page 177 / 237 

 
 
 
                                                 
 
clearance of the goods can happen 24/7, without physically presenting the permit beforehand. 
The economic operator can then go to the customs office with the paper document. 

In addition,  economic operators must create a declaration in  customs’ system  and  apply  for 
supporting documents  in  the different  competent authorities’ systems.  Even though this is  a 
clear procedural redundancy, they did not report it as a problem. They did not actually see the 
benefits  of  a  Single  Entry  Point,  as  economic  operators  consulted  all  had  dedicated 
departments for customs and regulatory requirements. They indicated that these departments 
deal with different issues and are needed anyway. 

Problem: Enforcement issues and information gaps 

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem needs EU-wide action – 
harmonisation of systems to have 
comparable information across borders 
and requirement legislative action. 

  Customs: this is an essential weakness of 
the current environment for EU customs 
  Competent authorities: issues related to 
enforcement of respective regulations 
  Economic operators: indirect impact on 

society more broadly 

The  ”GUN”  led  to  improvements  in  security.  The  risk  of  fraud  was  higher  before  as  the 
beneficiary of the authorisation was responsible for taking the original paper document from 
one customs office to another. 

Nonetheless, poor exploitation of electronic information results in difficulties for enforcement 
of quotas and information gaps within, but  also between, EU Member States.  This  makes it 
difficult to ensure that licenses are not  copied and reused. The lack of harmonisation in EU 
systems  and/or  the  lack  of  EU  legalisation  to  underpin  the  development  of  such  systems, 
means there is a barrier to EU-wide enforcement and gaps in information on the nature and 
scale of enforcement problems in the first place. Most importantly for France, while quantity 
management is possible nationally, this really needs to occur at the level of the single market 
for it to be meaningful. This is a major problem. 

Likely future developments 

This section provides insight on how the problems described above are likely to evolve, either 
through the continuation of the baseline scenario or through the pursuit of policy options for 
enhanced  government-to-government 
(B2G) 
collaboration. Potential impacts include direct costs and benefits for different stakeholders, as 
well  as  indirect  effects  related  to  the  implementation  of,  and  compliance  with,  given 
regulatory requirements. 

and/or  business-to-government 

(G2G) 

Below we provide a summary of the expected impacts under different scenarios, followed by 
a  summary  of  how  well  the  problems  outlined  in  section  3.2  would  be  addressed.  For  each 
problem, we provide a rating of the expected impact (as outlined in the box below). 

Rating  Explanation of rating 

+++ 

Problem would be substantially improved/eradicated 

++ 

Problem would be improved to a significant extent 

+ 

0 

Problem would see some (limited) positive improvement 

Limited or no change  

Page 178 / 237 

 
 
 
 
Continuation of the baseline scenario in France 

For France, the continuation of the baseline scenario would be a continued expansion of the 
national  Single  Window  environment  with  more  connections  established  with  new  partner 
competent authorities. 

In  addition,  France  is  planning  to  join  the  CERTEX  project,  meaning  it  will  connect  the 
“GUN”  with  the  EU’s  TRACES  NT  database,  which  has  the  right  capabilities  in  terms  of 
quantity  management  and  data  summarised  in  a  PDF.  However,  French  customs  will  first 
maintain a mirror database, until the “GUN” connection with TRACES NT is established. 

A  gradual  expansion  of  G2G  collaboration  through  the  increase  of  the  scope  of  the 
CERTEX project to cover other EU regulatory requirements is the target path for French 
customs authorities, the same way the GUN project will continue to be expanded. The one-off 
costs  of  gradually  expanding  the  scope  of  the  CERTEX  project  would  be  borne  by  French 
customs  authorities  (no  other  stakeholders  would  have  any  direct  costs).  These  were  not 
considered to be significant, as the basis is already there. 

The direct  benefits  of joining the CERTEX project  are quantity  management and  electronic 
exchange  of  information,  as  well  as  a  smoother  and  more  efficient  operation  through 
automatic updates on the status of the supporting documents. Some additional benefits could 
occur, in terms of efficiency depending on the regulatory requirements covered. 

According to French customs authorities, the CERTEX project will have an accelerator effect 
on  the  national  Single  Window  environment,  pushing  it  to  realise  its  full  potential.  In 
addition,  the  CERTEX  project  is  viewed  as  a  tool  to  encourage  convergence  and 
harmonisation  at  EU  level,  which  is  essential  for  the  delivery  and  the  effective 
implementation of EU law. 

At  the  national  level,  the  “GUN”  initiative  started  as  a  discussion  with  all  competent 
authorities  and  is  being  implemented  on  a  voluntary  basis  through  bilateral  connections.  
Partner  competent  authorities,  which  are  not  connected  to  “GUN”,  are  expected  to 
progressively introduce/improve their IT systems over the medium to long-term (the one-off 
costs of doing so vary depending on the current state of digitisation of the authority).  In the 
long-term, it is likely that connection with the “GUN” will become mandatory.  

There  have  been  no  formal  discussions  on  the  move  to  a  Single  Entry  Point  in  France  (i.e. 
Business-to-government  collaboration).  Interestingly,  economic  operators  consulted  did  not 
consider  this  necessary.  They  explained  that  within  their  internal  structures,  customs  and 
regulatory  requirements  are  the  responsibility  of  different  departments/services  and  require 
different expertise. As such, they are unfazed by continuing to have separate entry points for 
customs  declarations  and  for  supporting  documents.  Nonetheless,  they  clearly  expressed  an 
appetite  for  full  digitisation  of  all  application  procedures  and  more  generally  of  competent 
authorities to introduce greater efficiencies into the import/export process. 

In  terms  of  indirect  benefits  under  the  baseline  scenario,  continued  cooperation  between 
customs  and  partner  competent  authorities  would  be  likely  to  continue.  The  “GUN”  project 
has already had the effect of improving collaboration between different authorities more than 
expected.  Authorities  must  discuss  extensively  to  establish  a  connection,  and  this  requires 
getting to know each side. As explained by those involved in these processes, teams from the 
different  authorities  work  together  during  the  development  phase  and  continue  to  work 
together on a regular basis to oversee management and delivery. As such, they develop their 
knowledge  of  the  different  relevant  regulations,  which  in  turn  improves  customs-related 
processes.  French  customs  representatives  consulted  acknowledged  that  customs  used  to 

Page 179 / 237 

 
 
constitute a special sector, “where no one usually ventures”, which is not  the case since the 
“GUN” project. 

The  table  below  sums  up  the  expected  impacts  under  the  baseline  scenario  for  each  of  the 
main problems and shows these would be positive overall but not significant. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ 

This  would  continue  to  improve  as  new  partner  competent  authorities  and  regulatory  requirements, 
such  as  war  equipment  for  example,  are  covered.  The  possibility  to  retrieve  information  from 
TRACES NT through the CERTEX project would also remove the potential administrative burden of 
having to look for such information. 

Multiplication of information and procedural redundancies 

+ 

This would also continue to improve as economic operators gradually have fewer authorities to interact 
with, aside from  the application  process for supporting  documents  as linkages  between  customs  and 
partner authorities become automatic. 

Poor exploitation of electronic exchange of information 

+ 

Over time, the electronic exchange of information is expected to improve as more partner competent 
authorities digitise their systems. However, the benefits would be limited by the lack of guarantee that 
other  countries  would  make  the  same  investments.  This  means  information  may  continue  to  be 
incomplete if the CERTEX project is not made mandatory. 

Enforcement issues and information gaps 

+ 

Problem  would  be  solved to  a significant  extent for  French  customs  authorities, who  insisted  on  the 
importance of quantity management and PDF version of supporting documents stored in EU databases. 
Nonetheless, the voluntary nature of the CERTEX project means the scope for gains in enforcement 
remains limited if not all Member States participate. 

Options for enhanced G2G collaboration 

These options  involve putting in  place a legal  basis to  boost back-end, G2G cooperation on 
the exchange of data relating  to a different category of regulatory requirements and specific 
technical  solutions  for  implementation.  The  options  are  not  mutually  exclusive  but  can  be 
combined  depending  on  the  pros  and  cons  of  including  distinct  categories  of  regulatory 
requirements. 

French customs believe that the connection must happen between Member States, i.e. national 
customs authorities must connect to each other. However, they also stressed how complicated 
it  is  nationally  to  connect  to  15  competent  authorities,  so  doubted  the  feasibility  of  G2G 
collaboration between customs authorities at EU level. 

Nonetheless,  the  benefits  of  enhanced  G2G  collaboration  would  be  significant.  Indeed,  it 
would improve security. The more complete the data on goods entering and exiting, the more 
secure the market. In addition, if some aspects are missing, goods are treated differently, and 
the  process  can  be  slower.  For  dual  use  goods  for  example,  French  customs  would  be 
interested in knowing how many licences are delivered in other countries. It could be possible 
by  uploading  licences  on  a  European  platform218.  The  current  decentralised  system  means 

218   Under development. See: http://trade.ec.europa.eu/doclib/docs/2017/december/tradoc_156495.pdf and 

https://supportoffice.jp/outreach/2017/asian_ec/pdf/29Mr.StephaneChardonEU.pdf 

Page 180 / 237 

 
 
 
                                                 
 
Member  States  hold  data  that  are  not  directly  available  to  other  Member  States.  Having 
interoperable systems, only allowing access to the authorisations, is a conceivable solution. In 
this case, interoperability is key. 

Currently,  systems  are  not  interoperable,  and  information  is  hard  to  get.  French  customs 
authorities  believe  that  when  electronic  documents  are  stored  in  national  databases,  the 
identification of the issuing Member State is vital to allow the clearance system to interrogate 
the  right  database.  Therefore,  as  a  first  step  to  G2G,  non-customs  authorities  should  be 
encouraged  to  mention  their  country  code  inside  the  reference  numbers  of  the  supporting 
documents they issue, as with CVEDs, CEDs, etc. The harmonisation of the document codes 
used  in  transit  declarations  (appendix  D2  of  Regulation  2016/341)  and  in  export/import 
declarations  (TARIC  database)  should  also  be  encouraged  to  allow  the  use  of  electronic 
supporting documents both with transit and export/import declarations. 

In the short term, the priority for France is to join the CERTEX project and to expand it to as 
many supporting documents as is possible, but also to provide a solid legal basis to underpin 
it (i.e. option 1). The direct costs of doing so would be the same as for the continuation of the 
baseline,  the  main  additional  benefits  resulting  from  a  solid  legal  basis,  would  be  those 
associated with quantity management (which relate to security and enforcement primarily). 

The table below sums up the expected impacts for enhanced G2G collaboration for France for 
the most pertinent options discussed above, if systems are interoperable. 

Problem 

Administrative burdens in the management of goods crossing borders 

Change 

+ 

This would improve as enhanced G2G collaboration would require less effort from customs/competent 
authorities  to  retrieve  information  from  other  Member  States  or  at  EU  level.  Economic  operators 
would see reduced administrative burden over time. 

Multiplication of information and procedural redundancies 

+ 

This  would  improve  for  customs  and  competent  authorities  as  information  would  not  need  to  be 
duplicated, as it could simply be shared. Yet, economic operators would still have to input information 
through two channels, one for customs, and one for supporting documents. 

Poor exploitation of electronic exchange of information 

++ 

Customs  would  stand  to  gain  from  more  seamless  connections  between  government  (nationally  and 
with  third  party  governments).  This  would  need  to  be  supported  by  digital  signatures  to  allow  for  a 
fully  paperless  system  and  a  change  in  costs.  The  costs  of  upgrading  partner  competent  authorities’ 
systems  could  be  significant  for  some  but  would  lead  to  benefits  for  all  in  terms  of  smoother 
operations. 

Enforcement issues and information gaps 

++ 

Enhanced  G2G  collaboration  would  open  opportunities  for  improved  enforcement  and  lead  to 
improvements in understanding of the scale of problems. The scale of impact is difficult to estimate 
but would be positive. 

Options for enhanced B2G collaboration 

Options  5-7  are  about  B2G,  front-end  cooperation  that  focuses  on  diverse  ways  of 
streamlining reporting processes for the economic operators when dealing with the regulatory 

Page 181 / 237 

 
 
 
requirements.  The  options  for  B2G  collaboration  are  mutually  exclusive  and  range  from  no 
action  (covered  under  section  4.1);  a  common  management  portal  (option  5);  interoperable 
national  Customs  Single  Windows  (option  6),  to  a  Single  Entry  Point  for  Customs-related 
procedures through a trader portal managed at EU level (option 7). 

French  customs  want  their  national  IT  infrastructure  to  remain  in  place.  In  fact,  this  was 
presented  as  a  condition  for  further  developments.  Nonetheless  it  is  essential  that  national 
systems connect with Community tools, such as TRACES (G2G). This is France’s ambition 
and  objective.  Therefore,  option  6  is  viewed  positively  in  France,  as  customs  authorities 
believe  it  would  allow  for  the  continuation  of  the  national  single  window  environment.  In 
their view, option 6 allows for adaptation to national regulatory requirements and associated 
supporting documents.  However, the “GUN” is  limited to G2G cooperation. Neither French 
customs, nor economic operators, are calling for B2G cooperation. As such, their appetite for 
option 6 is based on this understanding of what constitutes a Single Window, which falls short 
of a Single Entry Point. If option 6 were pursued, France want the implementation of a Single 
Entry Point to be optional, given the heavy burdens it would imply on customs and competent 
authorities to change their system again. 

Option  7  is  not  desirable  as  it  does  not  favour  France’s  considerable  advances.  It  does  not 
allow  national  authorities  to  have  access  to  useful  data  either  and  makes  Member  States 
dependent on the European tool, without building their capacity, which is seen as restrictive. 
A harmonised interface for interacting with the various electronic systems used to deal with 
EU regulatory requirements (option 5) would have little impact for many economic operators 
who are already directly connected to customs' and other relevant authorities' systems (using 
the Electronic Data Interchange (EDI)). 

The  table  below  sums  up  the  expected  impacts  for  enhanced  B2G  collaboration  for  France 
assuming option 6 were pursued. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ 

Because the French approach to the Single Window environment does not include a Single Entry 
Point, the improvement in administrative burden would only go so far.  

Multiplication of information and procedural redundancies 

+ 

As with the administrative burden, the possible impact in terms of reducing procedural redundancies 
would be limited but positive. 

Poor exploitation of electronic exchange of information 

+++ 

If  option  6  were  pursued,  all  Member  States  would  have  to  digitise  processes  for  entry  and  exit  of 
goods at the border. This would lead to substantial positive impacts for French customs who currently 
must  deal  with  manual/paper-based  systems  in  other  Member  States  and  are  unable  to  exploit  the 
potential of digitised information at the EU level.  

Enforcement issues and information gaps 

++ 

For  option  6  to  function,  national  Single  Windows  must  be  interoperable.  This  means  that  customs 
authorities in different Member States will need to collaborate with one another thereby encouraging 
convergence  and  harmonisation  at  the  EU  level,  akin  to  the  benefits  observed  in  France  as  customs 
worked  with  competent authorities  to  understand  their  needs and  vice  versa,  as illustrated  in  section 
2.3.1). 

Page 182 / 237 

 
 
 
Conclusions 

This  closing  section  draws  conclusions  related  to  the  severity  of  the  problem  in  France  and 
desirability and impacts of the different policy options. 

Nature and scale of problems with the current situation 

The  current  situation  is  not  optimal  but  still  satisfying  stakeholders  to  a  large  extent, 
especially since improvements linked to the national Single Window environment are likely 
to continue. Nonetheless, electronic exchange of information remains limited due to the low 
level  or  lack  of  digitisation  of  some  partner  competent  authorities,  and  of  some  Member 
States. When these do have IT systems, the exchange of information is limited because of the 
lack  of  interoperability.  The  continued  use  of  paper,  even  where  digital  solutions  are 
implemented, remains a problem for economic operators. The most significant problem is the 
lack of EU-wide quantity management. 

Another problem in France is the impact of Brexit in terms of logistics, both in terms of  the 
capacity of the IT systems to treat a significantly higher number of declarations, or in terms of 
physical set up to allow for inspections by customs and partner competent authorities. 

Problem  

Rating 

Administrative burdens in the management of goods crossing borders 

Poor exploitation of electronic exchange of information  

Multiplication of information and procedural redundancies 

Enforcement issues and information gaps 

Assessment of the EU SW-CVED/CERTEX projects 

Whereas it was not the case for the EU SW-CVED pilot, the CERTEX project is in line with 
French customs authorities’ needs. Customs authorities confirmed the relevance of having an 
EU  level  database,  if  the  information  it  contains  is  usable  and  retrievable  by  national 
authorities.  Although  customs  authorities  were  positive  about  the  functionalities  of  the 
CERTEX project, for the change to be significant at EU level, it would need to be mandatory. 

The cost of bridging French customs’ system  to  the EU’s TRACES  NT  database should be 
minor, as it will only require adapting TRACES FR, the mirror database they already created. 
As is the case of the French Single Window environment in general, the benefits over time are 
greater than the costs: a more efficient and secure customs clearance process. 

Feasibility and desirability of the policy options 

In the case of France, the most desirable policy options lead to the same scenario, as briefly 
summarised below.  

Scenarios 

Baseline:  The  baseline  scenario  would  see  increasing  improvements  linked  to  the  enlargement  of  the 
Single Window environment and French customs engaged in the CERTEX project.  

G2G: The expected impacts of enhanced G2G collaboration could be high, especially if all systems (at 
EU level) were interoperable. 

B2G: Option 6 is desirable for France but there are concerns about any mandatory action. 

Page 183 / 237 

 
 
 
 
 
 
 
APPENDIX C.2: PROCESS FOR ESTABLISHING A GUN CONNECTION 

Figure 25: Typical sequencing/process for the establishment of a new “GUN” connection 

First contact 

(Informal) meeting with partner 
competent authority, incluing 
presentation of the GUN 

Agreement-in-principle 

from both authorities 

Framework 

Perimeter, 
organisation, 
planning, 
etc. 

General 
Functional 
Specification
s (GFS) 

Regulatory 
basis 

Validation of 
the GFS 

Executive 
Committee 
between the 
two authorities 

Realisation 

Contracts for 
interfaces 

Technical 
development 

End-to-end 
testing 

Testing 1 

Testing 2 

Generalisation 

Fictional 
operations 

Monitoring 
and 
Evaluation 

Real 
operations 

Monitoring 
and 
Evaluation 

Diffusion of 
instructions to 
services 

Information to 
operators 

The agreement-in-principle is a roadmap used until full implementation of the connection. It 
is an important political commitment signed by the Director General and sent to the partner 
competent  authority.  Given  that  customs  do  not  financially  support  the  partner  competent 
authority’s  necessary  adaptation,  this  commitment  must  come  from  a  sufficiently  high 
level.219  Communication  is  important  throughout,  as  authorities  must  have  the  same 
understanding  and  definition  of  the  different  components  so  that  systems  are  interoperable. 
Economic operators are systematically involved once the testing phase begins. 

IRELAND  

Introduction  

This  report  forms  one  of  the  eight  country  case  studies  that  were  carried  out  to  provide 
evidence  for  the  impact  assessment  on  a  potential  new  initiative,  namely  the  EU  Single 
Window environment for customs. By collecting and analysing data on the current  situation 
and expected future developments, the case studies aim to generate insight on the nature and 
scale of  any existing problems and likely impacts of the policy options defined for the new 
initiative.  These  include  an  option  for  no  additional  EU  action,  which  would  consist  of  the 
continued  existence  and  gradual  expansion  of  the  EU  Customs  Single  Window-CERTEX 
project (simply referred to as CERTEX project throughout).  

Each  case  study  used  a  common  methodology  based  on  a  document  review,  feedback  from 
national  administrations  provided  through  participation  in  the  project  group  and  interviews 
(mainly  face-to-face)  with  officials  from  customs  and  partner  competent  authorities  and 
economic operators. The sample of eight Member States was selected in discussion with DG 
TAXUD with a view to covering complementary areas of interest and achieving a degree of 
representativeness.  

Within  this  broader  framework,  the  research  on  individual  case  studies  varied  according  to 
national  specificities  such  as  geography, 
trading  profile,  administrative  set-up  and 
participation  (or  not)  in  the  EU  Single  Window-CVED  pilot  project  (EU  SW-CVED,  the 
predecessor to CERTEX project). 

For Ireland, the case study focused on:  

  Experiences with the EU SW-CVED pilot  

  Controls related to import of agricultural products and live animals (AGRIM, CVED 

and CHED-PP) 

219   The role of the sponsor is indeed essential, as (s)he “is accountable for ensuring that the work is governed effectively 
and delivers the objectives that meet identified needs”. Novare Consulting Ltd., Association for Project Management. 

Page 184 / 237 

 
 
 
 
 
 
 
                                                 
It also mentions specific issues relating to port infrastructure (in Dublin), given the impact of 
this on clearance times.  

The case study draws on desk research and a series of interviews from a field visit during the 
week  of  22  October  2018.  The  16  interviews  were  comprised  of  five  customs  officials 
responsible  for  customs  policy,  electronic  customs  and  IT  developments,  partner  competent 
authorities dealing with the import and export of agricultural products and live animals, and 
economic operators including freight forwarders, and agricultural importer/exporters.  

Background  

Some  background  information  is  needed  to  understand  the  current  situation  in  Ireland  and 
how  it  would  likely  evolve  for  the  policy  options  under  review.  This  section  presents  an 
overview of Ireland’s profile for international trade, administrative and IT set-up for customs 
and other relevant regulatory requirements. It also briefly presents progress towards a customs 
single window at national level in Ireland. 

Trading profile   
Ireland accounts for about 1.5 % of EU imports and 3.2 % of EU exports.220 While small, this 
is  a  greater  proportion  of  trade  than  its  4.9  million  /  1  %  of  the  EU  population  would 
suggest.221 Much of this trade takes the form of high value goods from the pharmaceutical / 
health,  aircraft,  and  IT  sectors222.  Certain  agricultural  goods  form  a  significant  part  of  Irish 
trade223.   
Currently the main types of port of entry are sea224 (which is significantly higher in volume) 
and air225. This is unlikely to change significantly, even with Brexit, as trade through the land 
border  with  Northern  Ireland  is  relatively  low.  Nonetheless,  of  note  for  Ireland  is  the 
substantial impact of Brexit, and how this will change Ireland’s trading profile. A recent study 
commissioned for Ireland’s Department for Business, Enterprise and Innovation stated: “Our 
study finds that Ireland is uniquely exposed to Brexit due to a very high trade intensity with 
the UK. Approximately 15 per cent of Irish goods and services exports are destined to the UK. 
In  certain  sectors,  the  UK  is  an  especially  important  market,  such  as  the  agri-food  sector 
where around 40 per cent of exports are destined for the UK. In addition, two-thirds of Irish 
exporters make use of the UK landbridge to access continental markets.”226 

To  get  an  idea  of  Ireland’s  success  in  clearing  goods  efficiently,  we  looked  at  its  logistics 
performance as  assessed by the World  Bank227.  Ireland ranks highly (25th globally, and 12th 
among EU Member States) in terms of trade facilitation and ease of doing business overall228. 

220   Eurostat data on external trade. For info, the gross value of imports to Ireland in 2017 stood at EUR 78,691.1 million, 

and it had a gross value of exports of EUR 121,856.6 million. 

221   Irish Central Statistics Office, 2018 

(see https://www.cso.ie/en/statistics/population/populationandmigrationestimates/)  

222   Source: WTO, Ireland trade profile information (2017); see also Eurostat data (International trade of EU, the euro area 

and the Member States by SITC product group; Code: ext_lt_intertrd). 

223   Source: WTO, Ireland trade profile information (2017) 
224   Eurostat data for Gross weight of goods handled in all ports by direction - annual data Code: mar_go_aa shows annually 

53 351 thousand tonnes pass through Irish ports.  

225   Mainly through Dublin airport (approx 135 000 tonnes annually) but some also through Shannon airport (approx 10 500 
tonnes annually) (Eurostat: Freight and mail air transport by main airports in each reporting country [avia_gooa]) 
226   The  impacts  of  Brexit,  Department  for  Business,  Enterprise  and  Innovation  commissioned  study  (Copenhagen 

Economics, 2017) 

227   The LPI relies on an online survey of logistics professionals from the companies responsible for moving goods around 
the  world:  multinational  freight  forwarders  and  the  main  express  carriers.  Freight  forwarders  and  express  carriers  are 
best positioned to assess how countries perform. 

228   Based on mean across logistics performance index 2012-2018 (https://lpi.worldbank.org/) 

Page 185 / 237 

 
 
                                                 
 
In terms of customs specifically229, Ireland ranks slightly higher globally (22nd), but the same 
place among EU Member States (12th). Of the six components used to calculate the ranking, 
customs  was  the  lowest  scoring  within  Ireland,  followed  by  infrastructure230.  This  suggests 
that, in Ireland, the efficiency of the clearance process is the weakest link and improvements 
here would be important to improve the overall logistics performance. 

Administrative set-up 

Several  authorities  have  responsibility  for  issues  that  relate  to  a  potential  Single  Window 
environment.  First  among  these,  with  overall  responsibility  for  border  management,  are  the 
Revenue Commissioners. Usually referred to simply as “Revenue”, it is the Irish Government 
agency responsible for customs, excise, taxation and related matters231. 

The  Customs  Division  (hereafter  “Irish  customs”)  sits  within  Revenue  and  is  charged  with 
development of policy, legislation and international functions for Customs. The Information 
&  Communications  Technology  &  Logistics  Division  (ICTL),  which  also  sits  within 
Revenue, deals with the IT infrastructure for Irish Customs as well as Taxation. The Customs 
and  the  ICTL  Divisions  share  responsibility  for  the  management  of  Customs’  electronic 
systems. For example, the e-customs branch of the Customs Division manages the day to day 
live issues with the systems and only refers to the ICTL Division if the issue is technical. 

Revenue  works  with  a  range  of  partner  competent  authorities  (government  departments, 
agencies,  commissions,  authorities  and  cultural  institutions)  to  enforcement  legislation 
relating to prohibitions and restrictions for various goods and services232. For example, meat 
or meat products require a licence from the Department of Agriculture, Food and the Marine 
and endangered species require a licence from the National Parks and Wildlife Service. There 
are  17  different  bodies  and  different  units  within  some  of  them  who  are  charged  with 
controlling the import and export of various goods. 

Approach to electronic customs and IT architecture  

Revenue  has  the  so-called  “Automatic  Entry  Processing”  (AEP)  system  for  the  validation, 
processing, duty accounting and clearance of custom declarations. Economic operators use the 
“Direct  Trader  Input”  via  the  Revenue  Online  Services  on  the  Revenue  website  to 
communicate  with  the  AEP233.  Submission  of  the  Single  Administrative  Document  (SAD), 
required  for  all  import  declarations,  is  electronic,  but  a  paper  document  is  sometimes  also 
required when the goods arrive and before they are cleared. This occurs in a minority of cases, 
90% of imports will not require submission of accompanying paper documents. Depending on 
the type of good, certain regulatory requirements are still based on paper documents. The full 
clearance process is explained in more detail in section 3.3.1. 

The  national  IT  architecture  is  a  combination  of  EU  transnational  systems  and  nationally 
developed  systems,  which  collectively  are  used  for  entry  summary  declarations,  risk 
management,  clearance,  cargo  manifests  and  transit.  Centralised  EU  systems  and  databases 

229   defined as “Efficiency of the clearance process (i.e., speed, simplicity and predictability of formalities) by border control 

agencies, including customs” 

230   Quality of trade and transport related infrastructure (e.g., ports, railroads, roads, information technology). 
231   Revenue  currently  employs  approximately  5 968  staff  (full  time  equivalents).  Staff  are  located  in  some  70  Revenue 

offices distributed throughout the country, with head office in Dublin.  

232   A  full  list  of  prohibitions  and  restrictions  and  relevant  government  authorities/  departments  available  here: 

https://www.revenue.ie/en/customs-traders-and-agents/documents/prohibitions-restrictions.pdf  

233   See https://www.revenue.ie/en/customs-traders-and-agents/customs-electronic-systems/aep/direct-trader-input.aspx  

Page 186 / 237 

 
 
                                                 
are also used or contacted during the clearance process234. The connection is web-service to 
web-service, supported by a digital authentication system. 

Single Window state of play and key initiatives 

Ireland does not have a Single Window environment for customs. This means that clearance 
for  any  goods  subject  to  regulatory  requirements  other  than  customs  entails  separate 
interactions for economic operators with customs and partner competent authorities. 

However, Ireland is participating in the EU SW-CVED pilot project, which aims to enhance 
government-to-government (G2G) collaboration regarding CVED by linking the customs  IT 
system to  an EU database called  “TRACES”.  Ireland was the first  Member State to  go live 
with the project in 2015 and decided at the end of 2017 to expand its participation through the 
successor CERTEX project to include CHED-PP and COI, which are covered by an enhanced 
EU database “TRACES NT”. 

As a relatively small Member State (accounting for less than 3% of EU trade), Ireland prefers 
making use of what is developed at EU level, rather than building bespoke national solutions 
for relatively small volumes. EU systems are considered more resource efficient for Ireland, 
where  economies  of  scale  found  in  other  countries  do  not  provide  justification  for  one  off 
investments. In the case of the EU SW-CVED pilot, the cost for Irish customs to connect to 
the EU system was low. It involved three Revenue staff working full-time for a period of two 
months  to  develop  a  bridge  between  the  Irish  web-service  (AEP  system,  Revenue  Online 
Services)  into  TRACES.  Officials  estimated  that  with  the  experience  gained  building  the 
CVED  link,  significantly  fewer  resources  will  be  necessary  to  build  the  link  for  CHED-PP 
and  COI.  In  practice,  the  connection  built  between  the  Irish  system  and  TRACES  requires 
TRACES to be “polled” every hour to check for updates. Where updates have been made in 
TRACES, these then appear as updates in the Customs IT system (AEP). This regular hourly 
polling  goes  on  for  a  period  of  ten  days.  After  that,  manual  checks  regarding  the  status  of 
documents are required. 

Current experiences  

This section details the nature and scale of the current problems by analysing the processes for 
clearing  goods  through  the  border  in  Ireland.  It  first  presents  an  overview  of  relevant 
processes,  with  a  focus  on  the  specific  types  of  goods  /  regulatory  requirements,  and  an 
outline of how the EU SW-CVED pilot (and its successor) work in practice. This is followed 
by more detail regarding the most important problems with the current situation for customs 
authorities, partner competent authorities and economic operators. 

Overview of clearance processes 

In  this  section  we  provide  an  overview  of  goods  clearance  processes  in  Ireland.  We  first 
outline  customs  processes  (with  a  focus  on  aspects  with  the  highest  level  of  effort  and 
administrative burden and facilitation measures). Then we outline the regulatory processes for 
non-customs  requirements.  The  last  part  of  this  section  details  the  processes  relating  to  the 
EU-CSW pilot project.  

Customs processes 

Revenue  processes  around  1.4  million  customs  declarations  every  year,  of  which  53%  are 
imports and 47% exports, in addition to around 57 000 transit arrangements235. Some of these 

234   For  example:  EORI  (Economic  Operator  Registration  Identification),  REX  (Registered  Exporter  System),  CDS 

(Customs Decision System), eBTI (Binding Tariff Information). 

Page 187 / 237 

 
 
                                                 
goods  are  subject  to  regulatory  requirements  in  fields  other  than  customs.  To  enforce  these 
requirement, Irish customs works with partner competent authorities.  
According to customs officers interviewed, around a third of 119236 Trade Facilitation custom 
officers’ working time relates to ensuring compliance with customs procedures and rules. 

Customs checks (i.e. documentary and physical controls) mainly apply to imports. Exports are 
generally checked only for safety and security reasons and in 2016, less than 0.5% of export 
declarations  –  or  3,300  export  declarations  -  were  checked237.  In  2016,  6%  of  import 
declarations  –  or  44,520  -  were  checked  and  less  than  2%  -  or  fewer  than  14,800  -  were 
physically checked. Most of these physical checks were carried out in approved warehouses 
and other premises238, with a very small number at a port or airport.239  

Several factors allow for the low level of import checks, namely pre-authorisation of traders, 
advance  lodgement  of  declarations  and  an  extensive  system  of  post-clearance  checks, 
including customs audits, which are carried out  at  traders’ premises. “Authorised Economic 
Operators”  (AEOs)  have  a  special  status  and  under  agreed  protocols  can  operate  greatly 
simplified customs procedures. There are currently 155 AEOs240. 

Non-customs regulatory requirements 

When  customs  officers  check  import  or  export  declarations  for  certain  goods  they  may  be 
required to check the regulatory requirements under the competence of partner authorities are 
fulfilled.  Sometimes,  they  may  also  need  to  liaise  with  partner  competent  authorities  for 
physical  checks of  goods.  Customs officials estimated this accounted  for two thirds of their 
work.  The  most  frequent  such  regulatory  requirements  involve  collaboration  with  the 
Department for Agriculture, Food and the Marine (regarding AGRIM, CVED and CHED-PP) 
in  Ireland,  and  equivalent  authorities  overseas.  For  exports,  the  main  partner  for  customs  is 
the Department of Business, Enterprise and Innovation (which deals with Dual-Use licenses). 

More  specifically,  the  following  types  of  regulatory  requirement  account  for  the  most 
significant volumes in Ireland and are by extension the more resource intensive to manage:  

  Agricultural  produce  import  licence  (AGRIM)  (L001):  this  is  required  for  the 
import of most agricultural goods from outside the EU241 and issued by EU Member 
States  at  the  national  level.  The  volume  of  AGRIM  is  approximately  9 000  per  year 
(representing just over 1% of import declarations). 

235   Source:  Niall  Cody,  Chairman  of  Revenue  (opening  statement  to  committee  on  Finance,  Public  Expenditure  and 

Reform, and Taoiseach) 25 May 2017  

236   Figure provided by customs authorities on 14 January 2019, specifying that it will be significantly greater in 2019 with 

the arrival of a new deal BREXIT. 

237   The proportion of physical checks on export consignments is generally very low. Nationally, in 2018 less than 0.1% of 

export consignments were flagged for a physical check. 

238   Consignments  of  live  animals  and  products  of  animal  origin  being  brought  into  the  EU  can  only  be  imported  at  an 
approved BIP (Border Inspection Post). Customs cannot permit the release into free circulation of goods or animals not 
already  cleared  by  the  relevant  collocated  BIP.  The  Department  of  Agriculture,  Food  and  the  Marine  has  put 
infrastructure in place and granted approvals as follows:  
Dublin  Port  -  packed  products  of  animal  origin;  Dublin  Airport  –  horses;  and  Shannon  Airport  -  packed  products  of 
animal origin, horses, cattle, sheep pigs and goats. 

239   Source:  Niall  Cody,  Chairman  of  Revenue  (opening  statement  to  committee  on  Finance,  Public  Expenditure  and 

Reform, and Taoiseach) 25 May 2017  

240   Ibid. 
241   Detailed rules for the application of import licences and the product groups for which licences may be required are laid 
down in EU Regulations. The product groups are; beef and veal; cereals; ethyl alcohol of agricultural origin; flax, hemp 
and hempseeds; garlic and preserved mushrooms; milk and milk products; olive oil and table olives; pig meat; poultry; 
rice; seeds; sugar.  

Page 188 / 237 

 
 
                                                                                                                                                         
 
  Common Veterinary Entry Document: Animal Products (CVEDP) (N853): this is 
a  common  EU  certificate  for  the  import  of  veterinary  products  –  in  addition  to  the 
certificate, the EU regulation242 sets down rules for the inspection of goods at border 
inspection posts. Ireland deals with is approximately 8 000 CVED-P per year (or 1% 
of import declarations). 

  Common  Health  Entry  Document  for  Plant  Protection  (CHED-PP)  (N851):  this 
document  covers  Council  Directive  2000/29/EC  on  protective  measures  against  the 
introduction into the Community of organisms harmful to plants or plant products, and 
against their spread within the Community. Ireland deals with approximately 2 500 of 
these documents per year (or 0.3%). 

For exports, one of the most common regulatory requirements – in addition to customs – 
is the Dual use export authorisation (X002). This is required for goods that can be used for 
both civil and military purposes (including software and technology) – this concerns around 
13 000 (or 2% of exports). 

Processes relating to key regulatory requirements  

As explained already, Ireland participated in the  EU SW-CVED pilot project and is piloting 
its successor, the CERTEX project. After some initial hiccups were overcome relating to the 
routing  system  introduced  for  goods  (which  was  not  understood  and  led  to  some  confusion 
among economic operators), the process is operating smoothly. 

The process for import of goods requiring CVED and/or CHED-PP is illustrated in the figure 
below.  As  illustrated,  the  EU  SW-CVED  allows  the  EU  database  for  issuing  and  storing 
CVED and CHED-PP (TRACES) to connect with the Irish customs processes. The importer 
or customs agent has access to the AEP (to complete the SAD) and to TRACES (to complete 
the CVED or CHED-PP). 

The  first  step  in  the  process  requires  the  customs  agent  or  importer  to  apply  for  a  CVED 
through TRACES. The SAD is subsequently lodged and will be rejected in AEP if it does not 
contain the application number from TRACES in Box 44 (the SAD will not be complete until 
the  CVED  or  CHED-PP  is  issued,  unless  the  importer  has  a  valid  CVED  from  another 
Member  State243).  Once  the  SAD  is  in  the  AEP,  the  importer  or  agent  receives  a  MRN 
(Movement  Reference  Number).  With  the  MRN,  the  importer/agent  can  then  input 
information  electronically  for  the  CVED  or  CHED-PP  (including  the  MRN).  The  AEP 
communicates with various EU databases (including TARIC – which includes information on 
veterinary controls required) and gives the consignment one of four possible routings:  

  Green means no checks are required and the goods can enter circulation freely.  

  Red  means  the  goods  need  to  be  controlled  by  customs  (and  require  both  a 

documentation and a physical inspection).  

  Orange means that customs need to check accompanying documentation.  

  Yellow means no customs check is required only a veterinary inspection. In this case, 

the veterinary inspectors complete the CVED in TRACES. 

Throughout  the  processes  shown  below,  a  lot  of  informal  communication  (e.g.  phone  calls) 
also  takes  place  between  customs  officers,  partners  and  agents  to  help  with  planning  and 

242   Commission  Regulation  (EC)  No  136/2004  of  22  January  2004  laying  down  procedures  for  veterinary  checks  at 

Community border inspection posts on products imported from third countries 

243   Requirements for CVED number in SAD allows for automatic clearance of consignments with valid CVEDP generated 

in another Member State. 

Page 189 / 237 

 
 
                                                 
smooth the process. It is also worth reiterating that despite the electronic systems in place, the 
SAD and CVED and CHED-PP (as well as the documents that feed into them) are submitted 
in hard copy.  

Figure 26: Import process 

Source: adapted from presentation by Department for Agriculture, Food and the Marine 

Main problems in Ireland 

Several  aspects  of  the  abovementioned  processes  create  problems  for  customs,  partner 
competent  authorities  and  economic  operators.  Using  the  problems  defined  in  the  problem 
tree  (see  section  3  of  the  main  study  report)  as  a  starting  point,  the  ensuing  pages  examine 
these  in  detail.  The  impact  of  each  problem  on  different  stakeholders  is  illustrated  using  a 
rating  system,  where  red  denotes  severe,  amber  denotes  significant  and  green  denotes 
negligible (as explained in the box below). 

Rating  

Explanation of rating 

Major weakness / problem and significant investment / complex solution needed to 
address this issue which affects multiple stakeholders severely.  

Significant weakness / problem and some investment needed to address this issue which 
affects more than one group of stakeholders significantly. 

Problem is only negligible and/or could be easily addressed with few regulatory hurdles 
and does not seriously impact any one stakeholder. 

Problem: Administrative burdens in the management of goods crossing boarders   

Rating  

Explanation of rating 

Main stakeholders affected and how 

Major weakness / problem and 
significant change needed to address 
this issue due to lack of harmonisation 
of regulatory requirements at EU level 
and perverse incentives from EU 
regulatory requirements. 

  Customs officials: significant time / effort 

processing licenses 

  Partner competent authorities: significant 

time / effort producing licenses 

  Economic operators: apply to different 
authorities in each Member State   

Page 190 / 237 

GreenCustoms physical  check conductedRedOrangeFree circulationVeterinary doc check requiredCustoms Automated Entry Processing (AEP)Physical inspection (at BIP)Receive MRNCVEDGreenRedTRACESCHED-PPCustoms SW-CHED-PP (pilot)Customs SW-CVEDYellowGreenRedCustoms doc  checkEconomic operatorSingle Administrative Document (SAD) Customs doc check conducted by customs officersTrader to amend  
 
 
 
 
 
Feedback  from  customs  officers  and  customs  brokers  showed  that  dealing  with  the  paper-
based  documents  generated  an  unacceptably  high  administrative  burden  in  Ireland.  This  is 
especially  true  of  AGRIM  licenses,  which  were  reported  to  be  the  single  most  time-
consuming aspect of work for customs officers (who manually check the preference and the 
quota). In Dublin Port alone, there are two full-time customs staff dedicated to dealing with 
the administration involved in  checking these licenses. This  was  echoed by customs agents. 
While both customs officers and customs agents reported benefits of the EU SW-CVED, they 
felt these are dwarfed by the effort of dealing with AGRIMs.  

To  understand  the  problem  better,  some  background  to  how  the  AGRIM  works  is  needed. 
AGRIM is the abbreviation for the import license required for the import of most agricultural 
products.  The  license  specifies  the  volume  which  can  be  imported  and  the  customs  duty  (if 
any) applicable. Economic operators have a certain volume that is not subject to duties. The 
more  established  economic  operators  can  build  up  an  economic  case  for  an  entitlement  to 
duty-free import for different goods. 

As  explained  by  customs  officers,  at  the  heart  of  the  problem  of  the  administrative  burden 
they face is the incentive for economic operators to apply for many licenses for small volumes 
to avoid paying customs duties. By doing so, economic operators build up a history and track 
record. Over time, these economic operators establish an entitlement to more quota for import 
of higher value products. 

In  sum,  this  creates  a  mass  of  paperwork  essentially  to  avoid  customs  duties  (as  well  as 
creating trade barriers for smaller companies). To illustrate this, customs officers showed the 
study team a single consignment with 170 individual licenses attached to the same number of 
subsidiary companies (owned by one parent company), each importing 146kg of poultry. This 
allows  the  company  to  avoid  paying  customs  duties  (estimated  at  EUR  61 000).  Since  the 
validation  of  these  licenses  is  entirely  manual,  this  is  hugely  time-consuming  not  just  for 
customs officers, but also for customs agents, who estimated the extra burden of paperwork 
associated with the AGRIM is 20% of the total paperwork they deal with.  

Problem: Poor exploitation of electronic exchange of information  

Rating  

Explanation of rating 

Main stakeholders affected and how 

Significant investment needed and 
multiple actors with differing levels of 
resource   

  Customs officials and competent 

authorities: out of date systems act as a 
brake to collaboration  

  Economic operators: duplication of effort 

Part  of  the  reason  for  the  problem  described  below  (whereby  there  are  paper  and  digital 
versions  of the same documents) is  that few partner competent  authorities have managed to 
fully  digitise  their  systems.  The  Department  for  Agriculture,  Food  and  the  Marine  issues 
AGRIM  in  hard  copy.  The  Dual-use  export  license,  although  based  on  an  e-application,  is 
issued  in  paper  format.  The  same  is  true  for  the  certificate  for  shipment  of  waste  (see  box 
below). These are barriers to digitising customs clearance processes. Significant investments 
in  digital  systems  were  planned  but  require  some  lead  time  (budget  estimations  varied  and 
ranged  from  EUR  100 000  to  1  million).  Adding  to  this,  economic  operators,  stressed  that 
existing  digital  systems  (such  as  the  AEP)  are  slow  and  in  need  of  modernisation.  From 
customs’ point of view, the more digitised processes for regulatory requirements the better – 
as  the  costs  of  bridging  systems  are  minor  compared  to  the  benefits  of  integrated  digital 
processes.  

Page 191 / 237 

 
 
 
 
Even when systems are digitised, many of them do not “speak” to each other, leading to the 
same information being input multiple times. For example, some information in the SAD is 
also included in the CVED application. A Single Entry Point and the re-use of data would be 
simpler. 

Problem: Multiplication of information and procedural redundancies 

Rating  

Explanation of rating 

Main stakeholders affected and how 

Significant weakness / problem and 
would require legislative change in 
multiple areas to support 
dematerialisation  

  Economic operators / customs officials / 
partner competent authorities: inefficient 
use of resource and not realising full 
benefits of an electronic environment   

Despite some digitised aspects (including the EU SW for CVED), there is still a lot of paper 
documents  that  feed  into  the  clearance  process  or  are  required  alongside.  Even  the  SAD, 
which is completed digitally and feeds into the AEP, is printed out and submitted in hard copy 
alongside  other  paper  documents.  The  requirement  for  paper  documents  is  seen  as  an 
inconvenience and inefficient. Given the multiple actors providing various paper documents 
(whether it is a bill of lading or the SAD), the complexity involved in full digitisation, makes 
this  problem  significant.  Within  Ireland,  the  requirement  for  paper  versions  of  documents 
(including  the  SAD  and  CVED)  continues.  Interviewees  implied  that  unless  there  is  a  legal 
imperative for fully digital processes, the parallel systems could continue indefinitely. 

To illustrate the problem, we can look at the case for declarations requiring a CVED. Despite 
the existence of the electronic database and connection between TRACES and Irish customs, 
once customs have conducted their own checks (documentary and, where required, physical 
checks),  a  message  must  be  faxed  to  the  Department  for  Agriculture  to  alert  them  that  the 
goods are ready for inspection. From that point, transportation from the customs warehouse to 
the border inspection post can be arranged. While the input of data into the electronic system 
saves importers /  customs agents  some time (because applications can be copied across and 
edited) at no additional cost (as the service is free), customs agents continue to pay the costs 
of  sending  documents  by  courier  to  customs  for  validation.  Customs  also  must  arrange  for 
storage (for audit purposes). 

Problem: Enforcement issues and information gaps  

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem needs EU-wide action – 
harmonisation of systems to have 
comparable information across 
borders. 

  Customs officials and competent 

authorities: out of date systems act as a 
brake to collaboration  
Economic operators: duplication of effort 

 

Poor  exploitation  of  electronic  information  results  in  difficulties  for  enforcement  of  quotas 
and  information  gaps  within,  but  also  between,  EU  Member  States.  For  example,  in  many 
countries (including Ireland), AGRIMs are only produced in hard copy and not collated in any 
central  database.  This  makes  it  difficult  to  ensure  that  licenses  are  not  copied  and  reused. 
Similarly, for trans-frontier shipments of waste, the lack of uniformity between systems (with 
some  countries  using  digitised  systems  and  some  countries  only  accepting  paper;  and  with 
diverse  ways  of  recording  volumes)  means  there  is  no  EU-wide  data  and  no  way  to 
check/verify  between  countries  (see  also  box  below).  In  both  the  above  cases,  the  lack  of 
harmonisation in EU systems and/or the lack of EU legalisation to underpin the development 

Page 192 / 237 

 
 
 
 
 
 
of such systems, means there is a barrier to EU-wide enforcement and gaps in information on 
the nature and scale of enforcement problems in the first place. 

In some cases, the absence of centralised system and full data sharing between Member States 
can be justified – as in the case of dual-use licenses where data storage is especially sensitive 
due to national security / trade concerns.  

TFS (Trans-Frontier Shipments) Regulations and Procedures in Ireland 

Since 12 July 2007, Dublin City Council has been the designated National Competent Authority for 
the  export,  import  and  transit  of  waste  shipments  as  per  the  Waste  Management  (Shipments  of 
Waste) Regulation244. 

All  trans-frontier  shipments  of  waste  originating  in  any  local  authority  area  in  Ireland  that  are 
subject  to  the  prior  written  notification  procedures  must  be  notified  to  and  through  Dublin  City 
Council at the National TFS Office established to implement and enforce the Regulations. 

As  explained  by  stakeholders  in  Ireland,  national  governments  have  their  own  systems  for 
notification,  some  digitised,  some  not.  Those  that  are  not  digitised  (which  currently  includes 
Ireland) must receive paper documents by courier. It was also explained that the ways of recording 
volumes are not consistent between Member States making it difficult for comparisons to be made 
or  for  the  collation  of  figures  for  different  countries  to  understand  the  volumes  of  waste  being 
exported, and where to. 

Additional  problem  (specific  to  Ireland):  Infrastructure  for  physical  inspection  in 
Dublin Port 

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem is specific to the Port of 
Dublin but causes delay and cost to 
several stakeholders. 

  Customs officials and competent 

authorities: inefficient process and 
administrative effort  

  Economic operator: delays and cost of 

moving goods 

Not  all  problems  are  directly  related  to  the  absence  of  a  Single  Window  environment  for 
customs. Customs officers and veterinary inspectors emphasised that, for the Port of Dublin, 
the infrastructure does not allow for simultaneous inspection of goods by customs and partner 
authorities creating unnecessary delays in the clearance of goods. More specifically, economic 
operators need to transport goods between the customs premises (where customs checks are 
carried out) and Border Inspection Post (where compliance with other regulatory requirements 
is verified). This has been reported as time-consuming and costly. 

Improving the infrastructure for inspection was considered by stakeholders to be a priority to 
speed up clearance processes. By comparison with other problems, this was considered to a 
serious  impediment  to  smooth  clearance  processes.  There  are  intergovernmental  plans  to 
construct new inspection premises for use by all government agencies and within the confines 
of the Port area, and Brexit is speeding them up. 

Likely future developments  

244   S.I.  No.  419  of  2007  Waste  Management  (Shipments  of  Waste)  Regulations,  2007.  These  Regulations  gave  effect  to 
provisions contained in Commission Regulation (EC) No. 1013/2006 on transfrontier shipments of waste, which sets out 
new notification procedures, specifies revised waste listings and strengthens enforcement provisions in relation to waste 
movements within, into and out of the EU. 

Page 193 / 237 

 
 
 
 
                                                 
This section provides insight on how the problems described above are likely to evolve in the 
future, either through the continuation of the baseline scenario or pursuit of policy options for 
enhanced G2G and/or B2G collaboration. Potential impacts include direct costs and benefits 
for  different  stakeholders,  as  well  as  indirect  effects  related  to  the  implementation  of,  and 
compliance  with,  given  regulatory  requirements.  Below  we  provide  a  summary  of  the 
expected impacts under different scenarios, followed by a summary of how well the problems 
outlined  in  section  3.2  would  be  addressed.  For  each  problem,  we  provide  a  rating  of  the 
expected impact (as outlined below). 

Rating 

Explanation of rating 

+++ 

++ 

+ 

0 

Problem would be substantially improved / eradicated  

Problem would be improved to a significant extent 

Problem would see some (limited) positive improvement  

Very limited or no change  

Continuation of the baseline scenario in Ireland 

For  Ireland, the continuation of the baseline scenario implies  a gradual  expansion of G2G 
collaboration as the scope of the CERTEX project is increased to cover other regulatory 
requirements,  namely  CHED-PP  and  COI.  Partner  competent  authorities  are  expected  to 
progressively  introduce  digital  processes  over  the  medium  to  long-term  (i.e.  5  years 
minimum).  The  one-off  costs  of  doing  so  vary  by  authority  (estimates  given  ranged  from 
EUR  100 000  to  EUR  1m).  There  have  been  no  formal  discussions  with  partner  competent 
authorities  on  the  move  to  a  Single  Entry  Point  meaning  there  are  no  near-term  plans  for  a 
national  Single  Window.  There  is  just  an  appetite  for  the  increased  use  of  technology  to 
introduce greater efficiencies into the import/export process.  

The one-off costs of gradually expanding the scope of the CERTEX project would be borne 
by  Irish  Customs  (no  other  stakeholders  would  have  any  direct  costs).  These  were  not 
considered to be significant (less than 0.5 FTE annually). The direct benefits are positive but 
similarly, are expected to be limited. The benefits of expanding the CERTEX project would 
be akin to the benefits realised through the EU SW-CVED pilot, for instance more efficient 
and effective routing of consignments (as explained under 3.1.1.), and a smoother and more 
efficient  operation  through  automatic  updates  in  the  AEP  on  the  CVED  status.  Some 
additional benefits could occur (in terms of efficiency and ease of doing-business depending 
on the regulatory requirements covered). 

In terms of indirect benefits under the baseline scenario, the EU SW-CVED pilot led to more 
targeted manifest checks limited to risk-based searches for unusual consignments rather than 
systematic checks for “normal” consignments given the improved ability to identify unusual 
consignments. These benefits as well as a continued enhanced cooperation between customs 
and partner competent authorities (i.e. better understanding of each other’s controls creating a 
platform for future increased integration of Customs and partner controls) would be likely to 
continue under the baseline scenario. 

The  table  below  sums  up  the  expected  impacts  under  the  baseline  scenario  for  each  of  the 
main problems and shows these would be positive overall, but would not sufficiently address 
the problems. 

Problem  

Change 

Page 194 / 237 

 
 
 
Administrative burdens in the management of goods crossing borders 

+ 

Customs officers highlighted the expected benefits of CHED-PP. Whereas customs are the “end-user” 
of  CVED,  CHED-PP  is  expected  to  remove  some  procedural  redundancies  and  reduce  the 
administrative  burden  for  customs  officers  (as  well  as  economic  operators).  Customs  officials 
explained the simplifications will not be possible for all types of goods, but for 40% of goods requiring 
CHED-PP, the administrative burden will be lower resulting in time saving. 
Despite  the  improvements  mentioned,  the  problem  of  administrative  burdens  in  the  management  of 
goods  crossing  borders  would  continue  to  be  significant  under  the  baseline  scenario.  Without  any 
legislative changes to the status quo, all stakeholders would continue to spend considerable time/effort 
dealing with regulatory requirements that are outside of the CERTEX project, namely AGRIM, which 
is  a  considerable  portion  of  time.  If  paper  continues  to  be  required  along-side,  the  expected 
improvements in terms of administrative burden are estimated to be low. 

Multiplication of information and procedural redundancies 

0 

The  multiplication  of  information  and  procedural  redundancies  remain  under  the  baseline  scenario. 
With  no  change  to  the  legal  basis  for  customs  and/or  non-customs  regulatory  requirements,  and  no 
Single  Entry  Point  for  data  submission,  parallel  paper  submission  would  continue,  as  would  the 
duplication  of  information.  This  means  costs  would  not  differ  substantially  while  the  duplication  of 
information submitted would continue for economic operators. 

Poor exploitation of electronic exchange of information 

+ 

Over-time the electronic exchange of information is expected to improve as more partner competent 
authorities digitise their systems.  
Realising  the  benefits  of  an  increasingly  paperless  environment  would  allow  customs  officials  and 
competent authorities to collaborate more easily.   
However, the benefits would be limited by the lack of any guarantee that the same investments would 
be made in other countries (e.g. for trans frontier of waste shipment licenses). This means paper may 
have to continue regardless of modernisation efforts in Ireland.  

Enforcement issues and information gaps 

0 

The  impacts  in  relation  to  enforcement  issues  and  information  gaps  are  limited  under  the  baseline 
scenario.  The  main  impacts  would  be  similar  to  the  results  of  the  EU  SW-CVED  pilot  (i.e.  more 
understanding of controls and more targeted searches through better risk analysis) but expanded in line 
with increased supporting documents coverage. However, the voluntary nature of the CERTEX project 
means it lacks a quantity management function, which limits the scope for gains in enforcement.  

Page 195 / 237 

 
 
 
 
Options for enhanced G2G collaboration 

These options involve putting in place a legal base to boost back-end, G2G cooperation on the 
exchange  of  data  relating  to  a  different  category  of  supporting  documents  and  specific 
technical  solutions  for  implementation.  The  options  are  not  mutually  exclusive  but  can  be 
combined  depending  on  the  pros  and  cons  of  including  different  supporting  document 
categories.  

In the short term, the priority for Ireland is the expansion of CERTEX to as many supporting 
documents as is possible and to provide a solid legal base around the project. The direct costs 
of doing so would be the same as for the continuation of the baseline (i.e. 0.5 FTE per annum 
per regulatory requirement), the main additional benefits would result from a solid legal base 
which would allow for quantity management. 

In  the  medium  to  longer-term,  the  main  category  of  supporting  documents  that  customs 
authorities  would  be  interested  in  further  collaboration  are  AGRIM,  given  the  burden 
associated with  them outlined in  detail  in section 3.2. Assuming any legal  issues  relating to 
increased  harmonisation  of  AGRIM  could  be  agreed  at  EU  level,  the  direct  costs  would 
depend  on  the  technical  solution  agreed.  The  option  favoured  by  Ireland  would  be  for  a 
central solution developed at the EU level, which the Irish Department for Agriculture, Food 
and the Marine (and EU counterparts) could access, and which AEP could be connected into. 
As  such,  the  direct  costs  for  Ireland  would  be  low.  The  expected  benefits  would  be  a 
significant  reduction  in  administrative  burden  (estimated  to  take  up  2  FTE  now),  and  an 
improvement  in  the  electronic  exchange  of  information  (the  paper  associated  with  AGRIM 
was estimated to increase paper-flow by 20%). Indirect benefits would be better oversight and 
a reduced possibility for fraud (which is more difficult to quantify). 

For some partner competent authorities there are barriers to enhanced G2G cooperation (e.g. 
dual use export license where sensitive security information is at stake). 

The table below sums up the expected impacts for enhanced G2G collaboration for Ireland for 
the most pertinent options discussed above. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ (++) 

Depending on the scope of enhanced G2G collaboration, the improvements relating to administrative 
burden  could  be  limited (if  there is  simply  a  continued  expansion  of  CERTEX) or  more  significant. 
For the benefits to be significant, it would be important for AGRIM to be digitised throughout the EU 
and linked up to the system.  

Multiplication of information and procedural redundancies 

0 

As with the baseline scenario, enhanced G2G collaboration does not necessarily mean a reduction in 
multiplication of information or procedural redundancies. This would require a Single Entry Point for 
economic operators (as per B2G collaboration outlined overleaf). 

Poor exploitation of electronic exchange of information 

+ 

As with customs, economic operators would stand to gain from more seamless connections between 
government (nationally and with third party governments). This would need to be supported by digital 
signatures to allow for a fully paperless system and a change in costs (i.e. removing/reducing the need 
to  send  documents  by  courier  as  well  as  electronically).  The  costs  of  upgrading  partner  competent 
authorities’  systems  would  be  significant  but  would  lead  to  benefits  for  all  in  terms  of  smoother 
operations. 

Page 196 / 237 

 
 
Enforcement issues and information gaps 

+ 

Enhanced G2G collaboration would open opportunities for improved enforcement and lead to 
improvements in understanding of the scale of problems. The scale of impact is difficult to estimate 
but would be positive.  

Options for enhanced B2G collaboration 

Options 5-7 are about business-to-government,  front-end cooperation that focus on different 
ways  of  streamlining  reporting  processes  for  the  economic  operators  when  dealing  with  the 
regulatory requirements. The options for B2G collaboration are mutually exclusive and range 
from  no  action  (covered  under  section  4.1);  a  common  management  portal  (option  5); 
interoperable  national  Customs  Single  Windows  (option  6)  and  an  EU  Customs  Single 
Window trader portal (option 7).  

In principle, Irish Customs would support Option 6 if it was introduced as part of a realistic 
development plan and if the timing was right (i.e. it would need to be part of a longer-term 
plan). 

Given the other demands on Irish Customs (under the UCC and the UK’s withdrawal from the 
EU)  and  given  Irish  traders  are  not  putting  forward  any  demands  for  a  Single  Entry  Point 
facility,  the  possibilities  for  enhanced  B2G  collaboration  are  considered  unrealistic  in  the 
near-term. In addition, economic operators are experiencing delays and other problems getting 
their supporting documents through the TRACES system means that economic operators are 
failing to realise the full benefits of the solution. 

The  expected  impacts  of  pursuing  option  6  would  be  significant  but  would  also  require 
significant investments by Irish Customs and partner competent authorities. It is problematic 
to  estimate  the  scale  of  the  investments  required  but  given  there  are  at  least  17  different 
partner competent authorities, most of whom need to fully digitise their systems which would 
cost between EUR 100 000 – 1m each, meaning this would be a massive investment. The high 
direct  costs  would  be  mirrored  by  significant  benefits  for  (or  an  eradication  of)  all  the 
problems  currently  encountered.    It  is  difficult  to  estimate  exactly  the  scale  of  benefits  but 
clearly the investment would be matched by a (more) seamless trade environment. 

The  table  below  sums  up  the  expected  impacts  for  enhanced  B2G  collaboration  for  Ireland 
assuming option 6 were pursued.  

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+++ 

The improvements relating to administrative burden could be significant, especially given all the most 
cumbersome processes (such as AGRIM) would have to be included in the national Single Window.  

Multiplication of information and procedural redundancies 

+++ 

This would be significantly improved with a Single Entry Point, which would necessarily reduce the 
multiplication of information and could reduce procedural redundancies for all stakeholders.  

Poor exploitation of electronic exchange of information 

+++ 

This would be significantly improved with a Single Entry Point, which would need to be supported by 
full exploitation of electronic exchange of information.  

Page 197 / 237 

 
 
 
Enforcement issues and information gaps 

++ 

The  impacts  from  enhanced  B2G  collaboration  vis-à-vis  enforcement  issues  may  occur  as  a  more 
integrated system provides economic operators with a single reference outlining in one place all their 
obligations (some of which they have might be previously unaware of). 

Conclusions 

This  last  section  draws  conclusions  related  to  the  severity  of  the  problem  in  Ireland  and 
desirability and impacts of the different policy options.  

Nature and scale of problems with the current situation 

The  current  situation  is  suboptimal,  particularly  in  relation  to  the  administrative  burden 
associated with management of goods crossing borders (for which the processes for dealing 
with AGRIM received most emphasis during the visit) and the poor exploitation of electronic 
information  (given  the  low  level  of  digitisation  of  partner  competent  authorities,  and  the 
continued use of paper even where digital solutions exist). The other severe problem relates to 
infrastructure: The Port of Dublin is not set up efficiently to allow for inspections by customs 
and partner competent authorities, this needlessly adds to timelines for clearance of goods.  

Problem  

Rating 

Administrative burdens in the management of goods crossing borders 

Poor exploitation of electronic exchange of information  

Multiplication of information and procedural redundancies 

Enforcement issues and information gaps 

Assessment of EU SW-CVED 

The EU SW-CVED pilot (and the CERTEX project) corresponds to stakeholders’ needs. For 
CVED,  CHED-PP,  and  COI,  the  competent  authorities  confirmed  the  relevance  of  having 
integrated management of regulatory requirements. However, certain regulatory requirements 
are less relevant for Ireland – for example the volume of trade requiring FLEGT is so low that 
it is not relevant for Ireland. Many needs are not addressed by the EU SW-CVED pilot. For 
example, although economic operators were positive about the relevance of developments, the 
solution had not significantly changed the way they work, either positively or negatively (with 
paper  documents  continuing  to  be  used  alongside).  Economic  operators  also  reported 
problems with the functionalities of the TRACES system. 

The cost of bridging the Irish electronic customs into the EU’s TRACES database was minor 
(3 FTE over 2 months). The benefits (over time) are greater than the costs: more efficient and 
effective  routing  of  consignments  and  a  smoother  and  more  efficient  operation  through 
automatic  updates  in  the  AEP  on  the  CVED  status.  In  sum,  for  Ireland  the  EU  SW-CVED 
pilot  was  an  added  value.  With  no  national  initiatives  on-going,  the  opportunity  to  connect 
into an EU developed initiative was valuable.  

Feasibility and desirability of the policy options 

The most desirable and the most feasible scenario are inversely related in the case of Ireland, 
as briefly summarised below. 

Scenarios 

Page 198 / 237 

 
 
 
 
 
 
 
 
Baseline:  The  baseline  scenario  would  see  marginal  improvements  but  does  not  provide  much  in  the 
way of impetus for improvements to address the main problems for Ireland.   

G2G: The expected impacts of enhanced G2G collaboration could be high, especially if AGRIM were 
digitised and included in any solution. Even if enhanced collaboration only introduced a legal base for 
the CERTEX project, this would lead to positive change and would be feasible. 

B2G:  Despite  the  more  significant  expected  impacts  of  option  6  for  B2G  across  all  problems  (and 
therefore its desirability), the feasibility is low in the immediate term with too high upfront investments 
required as well as coordination among many partner competent authorities.  

NETHERLANDS  

Introduction  

This  report  forms  one  of  the  eight  country  case  studies  that  were  carried  out  to  provide 
evidence  for  the  impact  assessment  on  a  potential  new  initiative,  namely  the  EU  Single 
Window environment for customs. By collecting and analysing data on the current situation 
and expected future developments, the case studies aim to generate insight on the nature and 
scale  of  any  existing  problems  and  likely  impacts  of  the  policy  options  defined  for  the 
potential  new  initiative.  These  include  an  option  for  no  additional  EU  action,  which  would 
consist of the continued existence and gradual expansion of the EU Customs Single Window-
CERTEX project (EU CSW-CERTEX).  

Each  case  study  used  a  common  methodology  based  on  a  document  review,  feedback  from 
national  administrations  provided  through  participation  in  the  project  group  and  interviews 
(mainly  face-to-face)  with  officials  from  customs  and  partner  competent  authorities  and 
economic operators. The sample of eight Member States was selected in discussion with DG 
TAXUD with a view to covering complementary areas of interest and achieving a degree of 
representativeness.  

Within  this  broader  framework,  the  research  on  individual  case  studies  varied  according  to 
trading  profile,  administrative  set-up  and 
national  specificities  such  as  geography, 
participation  (or  not)  in  the  EU  Single  Window-CVED  pilot  project  (EU  SW-CVED,  the 
predecessor to EU CSW-CERTEX).  

For the Netherlands, the case study mainly focused on:  

  Experiences of the country’s current systems for customs clearance processes 
  Regulatory requirements related to import and export of waste material and import and 

export of live animals and animal products245.  

It  also  mentions  specific  issues  relating  to  port  infrastructure  (in  Rotterdam  and  to  some 
extent Amsterdam), given the impact of this on clearance times.  

The  evidence  for  the  case  study  is  comprised  of  desk  research  and  five  interviews  with 
customs  authorities,  partner  competent  authorities  responsible  for  waste  shipments,  and 
economic operators made up of freight forwarders and customs brokers. The interviews took 
place during in the week of 17 December 2018.  

Background  

Some background information is needed to understand the current situation in the Netherlands 
and how it would likely evolve for the policy options under review. This section presents an 

245   A focus due to the profile of the interviewees.  

Page 199 / 237 

 
 
 
                                                 
overview of the Netherland’s profile for international trade, administrative and IT set-up for 
customs and other relevant regulatory requirements. It also briefly presents progress towards a 
customs single window at national level in the Netherlands.  

Trading profile   

International  trade  constitutes  a  significant  part  of  Dutch  prosperity,  being  one  of  the  main 
pillars  of  Dutch  economy.  Due  to  the  country’s  geographical  location  with  the  port  of 
Rotterdam  being  the  largest  European  port  and  the  Amsterdam  Schiphol  airport  being  the 
second largest EU entry point for air cargo, the country is a very important European hub for 
trade. Of EU’s total import / export, the Netherlands accounted for 14.8% respectively 7.6% 
in  2017.246  The  same  year  the  Netherlands  rated  as  the  world’s  fifth  biggest  exporter  and 
eighth  biggest  importer.  The  main  commodity  groups  for  both  exports  and  imports  are 
manufactures (IT and telephone equipment, construction machinery, electrical and electronic 
components,  printing  equipment  and  semi-conductor  manufacturing),  agricultural  products 
(plants, flowers, dairy products, meat, fruit and vegetables) and fuels and mining products.247 
The Rotterdam port creates jobs for about 180 000 people and generates annually a revenue of 
EUR  45-46  billion  for  the  Dutch  economy248  and  the  revenue  generated  only  from  customs 
declarations is about 3% of the country’s total GDP.249 

The Netherland’s main trade partners are EU Member States (mainly Germany, Belgium, the 
United Kingdom, France and Italy), the United States of America and China. Since the United 
Kingdom is a significant trading partner (accounting for 8.6% of Dutch total exports and 5.3% 
of  Dutch  total  imports  in  2017250),  Brexit  is  a  priority  currently  a  priority  issue  for  Dutch 
customs and traders. 

To  understand  the  Netherlands’  success  in  clearing  goods  efficiently,  we  looked  at  the 
country’s logistics performance as assessed by the World Bank. In terms of trade facilitation 
and ease of doing business  overall, the Netherlands is doing very well, ranking number two 
both  globally  and  among  EU  Member  States.  In  terms  of  customs  specifically,  the 
Netherlands  ranks  as  number  three  globally  and  as  number  two  among  EU  Member  States. 
Out of the six components which are used to calculate the ranking, customs was the second 
lowest  scoring  within  the  Netherlands,  after  international  shipments.251  This  suggests  that 
improvements of the customs procedures, as well as the clearance processes of international 
shipments at the port, would enable to even further improve the overall logistic procedure.  

246   Eurostat data on external trade. 
247   Source: WTO, the Netherlands trade profile information (2017).  
248   Source: Port of Rotterdam. https://www.portofrotterdam.com/en (accessed 2018-12-20).  
249   Source: Figures provided by the customs head office on the 18 December 2018. 
250   Source: WTO, the Netherlands trade profile information (2017). 
251   Source: The World Bank. Mean across logistics performance index 2012-2018. 

https://lpi.worldbank.org/international/aggregated-ranking?sort=asc&order=Customs#datatable (accessed 2019-01-07).  

Page 200 / 237 

 
 
                                                 
 
As mentioned above, the case study partly focused on movements of waste across borders. In 
this area the Dutch government is very ambitious, with a vision of having a 100 percent waste 
circular economy by 2050 (and 50 percent in 2030), meaning 100 percent recyclable products. 
Currently,  the  Netherlands  has  about  2-3%  completely  recyclable  products.  This  is  an 
interesting aspect since there is much of waste being shipped out from the port of Rotterdam, 
e.g. waste with the final destination of India or China.252 Since waste shipments are regulated 
by the European Waste Shipment Regulation (EWSR), certain regulatory requirements need 
to be fulfilled. In 2017, 15 245 documents related to waste import were issued, and 9 238 for 
export. This was an increase with 185% from the previous year for import, and with 333% for 
exports.253  This  shows  that  waste  is  an  increasingly  important  good,  which  together  with  it 
being  a  priority  for  the  Dutch  government,  justifies  a  work  towards  more  efficient  and 
effective procedures dealing with waste. Today, these waste documents need to be issued in a 
hard copy according to the EU legislation, which hampers an efficient and modern clearance 
process, according to Dutch officials.  

Administrative set-up 

Dutch customs is part of the Dutch Tax and Customs Administration (“Belastingdienst”) and 
monitor the import, export and transit of goods in the Netherlands. The head office is located 
in Rotterdam and houses about 200 staff members. With eight regional offices, three national 
services  organisations  and  one  national  targeting  centre  spread  across  the  country,  the  total 
number of employees is 4821 (2017), which according to the Dutch customs means 3% of the 
total  customs  officers  across  the  EU.  In  addition,  customs  has  two  facilitations  (one  in 
Rotterdam  and  one  at  Amsterdam  Schiphol  airport)  where  controls  on  import,  export  and 
transit  are  carried  out.  Currently  an  additional  600-900  staff  is  being  hired  to  deal  with 
Brexit’s  consequences  for  Dutch  trade,  which  is  one  out  of  two  main  priority  areas  for  the 
Dutch  customs  at  the  moment.  The  second  priority  area  is  the  compliance  with  the 
requirements of the Union Customs Code.254  

The head office in Rotterdam deals with overarching questions regarding customs procedures, 
but also with issues related to policy and trans-national initiatives (driven by e.g. the EU or 
the World Customs Organization) and IT developments. All single window related initiatives 
as  have  also  been  the  responsibility  of  the  Dutch  customs.  The  regional  and  entry-point 
located offices have a more hands-on, operational function and deal with customs declarations 
processes and risk management related checks.  

Dutch  customs  is  subject  for  about  70  additional  laws  relevant  for  customs  declarations 
regarding the import, export or transit of goods to/from the European Union.255 Some of these 
laws stipulate the obligation of regulatory requirement documents, most of the cases issued by 
partner competent authorities, for the movement of a specific type of good. Therefore, Dutch 
customs collaborate with eight ministries256 and about 20 agencies regarding this aspect. The 
most common regulatory  requirements concern  security and health.  According to the Dutch 
customs,  there  is  no  competitiveness  between  the  partner  competent  authorities,  enabling  a 
well-functioning cooperation and helpful climate between them. 

252   Source: Interview with the Human Environment and Transport Inspectorate on the 17 December 2018.   
253   Source: Figures from Homework assignment 1.  
254   Source: Interview with the customs head office on the 18 December 2018. 
255   Source: Interview with the customs head office on the 18 December 2018. 
256   Namely the Ministry of Finance; Ministry of Economic Affairs and Climate Policy; Ministry of Agriculture, Nature and 
Food Quality; Ministry of Infrastructure and Water Management; Ministry of Foreign Affairs; Ministry of Justice and 
Security; Ministry of Health, Welfare and Sport; Ministry of Education, Culture and Science.  

Page 201 / 237 

 
 
                                                 
In  some  cases,  a  partner  competent  authority  would  be  called  for  by  the  Dutch  customs  to 
assist  in  a  check  of  a  consignment.  For  example,  regarding  waste  shipments,  the  Human 
Environment  and  Transport  Inspectorate  is  sometimes  consulted  since  this  inspectorate  has 
certain  in-house  expertise  regarding  waste.  According  to  the  inspectorate,  it  is  consulted  in 
approximately 25% of the total checks of waste shipments conducted by the customs office at 
the ports.257  

Approach to electronic customs and IT architecture  
The Dutch government’s Digitalisation Strategy258 stipulates that as much as possible should 
be  digitised  within  the  governmental  departments  and  authorities,  as  part  of  the  adaption  to 
the increasingly digitised global world. Currently, all the information that is communicated to 
the  Dutch  customs  is  done  digitally.  It  is  only  certain  regulatory  requirements  that  are 
demanded for in paper format, which is due to EU legislation. When a customs declaration is 
submitted, it is  notified whether  a regulatory  requirement document is  needed, and then the 
process is linked to the relevant partner competent authority.  

The customs declaration process of collecting all relevant data has become smoother during 
the  last  couple  of  years.  Three  years  ago,  the  waiting  time  at  the  Rotterdam  port  for  the 
clearance of goods was in average three days, now it is in average one day. The main reason 
for this decrease in time was the introduction of pre-arrival of information, meaning that the 
customs could do the risk analysis in advance.259 

The Dutch customs  is  using a hybrid  of different  IT solutions,  both  national  (e.g. their own 
customs declaration IT system called the Aangiftesysteem (AGS), where all kinds of customs 
declarations  can  be  done)  and  trans-European  (e.g.  Excise  Movement  and  Control  System, 
Export  Control  System,  Import  Control  System  and  the  Integrated  Tariff  of  the  European 
Union, TARIC, all used for different aspects of the customs clearance processes).  

The  Dutch  customs  is  working  according  to  the  World  Customs’  Organisation  data  model, 
through the EU Customs Data Model system (EU CDMS), the “data model 4.2”. The long-
term objective is to have one data set and one integrated message for all information, instead 
of the current  system  with  separate messages.  In order to  comply with  the system, which is 
part of the new requirements of the Union Customs Code, the Dutch customs must develop an 
interference system.   

Economic Operators have mainly two different options when it comes to communicating with 
the  Dutch  customs’  IT  system.  Either,  they  can  buy  a  data  programme  on  the  market  (or 
develop  it  themselves)  and  then  connect  to  the  customs’  IT  system,  or  they  can  use  a  web-
based  service  and  submit  the  declaration  online.  Customs  does  not  accept  or  provide  any 
paper-documents,  apart  from  certain  regulatory  requirements  with  EU  legal  basis.  The  full 
clearance process is explained in more detail in section 4.3.1. 

Single Window state of play and key initiatives  

The  Netherlands  has  single  window  environments  for  maritime  and  air  transport.  The 
maritime  single  window  means  a  system  with  the  reporting  of  formalities,  e.g.  formalities 
regarding  shipments,  such  as  the  shipment’s  passenger  list  and  produced  waste).  It  has  a 
similar single window environment for air cargo, but it does also include customs (unlike the 
maritime single window).  

257   Source: Interview with the Human Environment and Transport Inspectorate on the 17 December 2018.  
258   “Dutch  Digitalisation  Strategy,  Getting  the  Netherlands  ready  for  the  digital  future”  (2018),  Government  of  the 

Netherlands.  

259   Source: Phone interview with the customs head office on the 20 November 2018.  

Page 202 / 237 

 
 
                                                 
The  long-term  objective  for  the  Netherlands  is  to  have  one,  overarching  single  window 
environment  for  trade  and  transport/logistics  with  all  these,  currently  non-connected  single 
window environments, connected. What is needed achieve this is the interlinking of data, so 
that  data  can  be  reused  for  the  whole  logistic  chain.  According  to  the  Dutch  customs,  the 
country  has  come  a  bit  more  than  half-way  towards  this  objective  and  still  needs  to  invest 
approximately EUR 30-35 000 000 for future steps. The Dutch customs is currently working 
with the transport authorities and ministry of infrastructure and waterways on this project.260 

Currently, the Netherlands has no single window environment for customs, but developments 
are ongoing. The estimated future set-up costs for a customs single window system are EUR 
50-55 000 000  (excluding  maintenance  costs).  The  Dutch  customs  is  also  looking  at 
developments on a national level regarding third countries data exchange, e.g. with countries 
like China and Thailand.  

The Netherlands is not a part of neither the Single Window-CVED pilot project nor the EU 
Customs  Single  Window-CERTEX  project  (EU  CSW-CERTEX).  The  reason  for  not 
participating  is  said  to  be  the  fact  that  the  projects  were  built  on  the  IT  system  Common 
Communication Network (CCN), which the Netherlands is no longer using (instead it is using 
the  updated  version,  CCN2).  Therefore,  the  costs  were  not  justifiable  to  participate  since  it 
would  have  meant  a  step  backwards  IT  wise.  However,  the  country  is  positive  about  the 
initiative  and  believes  that  it  would  be  beneficial  to  join  the  project  since  the  regulatory 
requirements  included  are  relevant  for  the  Netherlands.  As  soon  as  the  project  updates  the 
system to CCN2, the country is likely to join.261   

In  order  to  ease  the  digital  processes,  “Digipoort”  was  developed.  Digipoort  is  a  digital 
system that functions as a post office. It receives all messages for the government, checks the 
message on a number of basic requirements and acknowledges, where required, the receipt of 
the message. The purpose is specially to ease the business-to-government collaboration. For 
customs it is required that all economic operators/freight forwarders that send information to 
customs must be connected to the system. 

Current experiences  

This section details the nature and scale of the current problems by analysing the processes for 
clearing goods through the border in the Netherlands. It first presents an overview of relevant 
processes,  with  a  focus  on  the  specific  types  of  goods  /  regulatory  requirements.  This  is 
followed by more detail regarding the most important problems with the current situation for 
different  stakeholder  groups,  namely  customs  authorities,  partner  competent  authorities  and 
economic operators. 

Overview of clearance processes 

In this section we provide an overview of goods clearance processes in the Netherlands. We 
first  outline  customs  processes  (with  a  focus  on  aspects  with  the  highest  level  of  effort  and 
administrative burden and facilitation measures). Then we outline the regulatory processes for 
non-customs requirements.   

Customs processes 

The  number  of  customs  declarations  is  increasing  every  year.  In  2017,  the  Dutch  customs 
processed  more  than  140  million  customs  declarations  for  import  and  export.  Of  these  the 
about  90%  were  import  declarations.  In  addition  to  this,  around  2,3  million  transit 

260   Source: Homework assignment 3.  
261   Source: Interviews with the customs offices on 29 November and 18 December 2018. 

Page 203 / 237 

 
 
                                                 
arrangements were made. This  is  very high number of declarations, e.g.  one could  compare 
with Ireland where around 1.4 million customs declarations were processed in 2017, or with 
Spain where 37.7 million customs declarations were processed in 2017262.  

The Netherlands has a system for  advanced risk  analysis  and the pre-release of  goods. This 
means that the  goods  after arrival  are either quickly released, or selected for inspection and 
then  released  within  24  hours.263  Authorised  Economic  Operators  also  have  a  special  status 
and under agreed protocols, and can operate greatly simplified customs procedures. In 2017, 
there were 1 563 Authorised Economic Operators in the Netherlands.264 

Non-customs regulatory requirements 

When  customs  officers  check  import  or  export  declarations  for  certain  goods  they  may  be 
required  to  check  regulatory  requirements  issued  by  Dutch  partner  competent  authorities. 
Sometimes,  they may also need to  liaise with  the  partner competent  authorities for physical 
checks of goods, when the authority’s expertise is needed.  

All consignments of animals and animal products are checked when entering the Netherlands. 
Almost  all  live  animals  (mostly  ornamental  fish  and  horses)  are  transported  by  air  and 
therefore  checked  at  the  Border  Inspection  Post  of  Amsterdam  Schiphol  airport,  by  the 
Netherlands  Food  and  Consumer  Safety  Authority.  Animal  products  are  a  common  type  of 
consignment coming to the port of Rotterdam and are also checked by veterinaries from the 
Netherlands  Food  and  Consumer  Safety  Authority  at  the  Border  Inspection  Post.  Due  to 
Brexit, the port of Rotterdam has estimated a need for an additional 20 veterinaries since there 
is  such  a  large  proportion  of  these  types  of  consignments  coming  from  the  United 
Kingdom.265 Customs cannot permit the release into free circulation of goods or animals not 
already cleared by the Border Inspection Post.  

Regarding  other  types  of  consignments,  checks  are  being  conducted  on  a  risk  management 
basis.  Regarding  checks  of  consignments  and  shipments,  certain  checks  can  be  carried  out 
elsewhere  and  not  at  the  airport.  This  could  e.g.  be  certain  checks  of  phytosanitary  goods 
(especially flowers), which sometimes are conducted at the flower auction.  

More  specifically,  the  following  types  of  regulatory  requirement  account  for  the  most 
significant  volumes  in  the  Netherlands  and  are  by  extension  the  more  resource  intensive  to 
manage266:  

  Common  Health  Entry  Document  for  Plant  Protection  (CHED-PP)  (N851):  this 
document  covers  Council  Directive  2000/29/EC  on  protective  measures  against  the 
introduction into the Community of organisms harmful to plants or plant products, and 
against  their  spread  within  the  Community.  In  2017,  the  Netherlands  dealt  with  263 
026 applications. 

  Agricultural  produce  import  licence  (AGRIM)  (L001):  this  is  required  for  the 
import of most agricultural goods from outside the EU267 and issued by EU Member 
States at the national level. In 2017, 133 345 AGRIM licenses were issued.  

262   Source: Irish and Spanish customs.  
263   Source: Homework assignment 3 
264   Source: Figures provided by the customs head office. 
265   Source: Interview with Fenex on the 18 December 2018. 
266   Source: Homework assignment 1.  
267   Detailed rules for the application of import licences and the product groups for which licences may be required are laid 
down in EU Regulations. The product groups are; beef and veal; cereals; ethyl alcohol of agricultural origin; flax, hemp 
and hempseeds; garlic and preserved mushrooms; milk and milk products; olive oil and table olives; pig meat; poultry; 
rice; seeds; sugar.  

Page 204 / 237 

 
 
                                                 
  Certificate  for  conformity  (CoC)  (N002):  this  is  required  for  fresh  vegetables  and 
fruits  and  issued  by  the  Quality  Control  Bureau.  In  2017,  192 537  certificates  were 
issued for imports, and 537 413 for exports. 

  Common Veterinary Entry Document: Animal Products (CVEDP) (N853): this is 
a  common  EU  certificate  for  the  import  of  veterinary  products  –  in  addition  to  the 
certificate, the EU regulation268 sets down rules for the inspection of goods at border 
inspection  posts.  The  volume  of  CVED-P  which  the  Netherlands  dealt  with  in  2017 
was 116 175 for imports during 2017.  

For  exports,  the  most  common  regulatory  requirement  is  the  Dual  use  export 
authorisation  (X002).  In  2017,  194 486  regulatory  requirements  were  issued.  Also  the 
certificate  for  conformity  (N002)  is  largely  issued  for  exports,  with  192 537  regulatory 
requirements issued in 2017. This is required for goods which can be used for both civil and 
military purposes (including software and technology).  

Processes relating to key regulatory requirements  

Since  the  Netherlands  is  not  part  of  the  EU  SW-CVED  project/EU  CSW-CERTEX  project, 
the  importer/exporter  or  customs  agent  contacts  responsible  partner  competent  agency  for 
regulatory  requirements  whenever  needed.  Most  of  the  regulatory  requirements  are  issued 
electronically, but certain are however still also issued in hard copy due to EU legislation.  

Main problems in the Netherlands  

Using the problems defined in the problem tree (see section 3 of the main study report) as a 
starting  point,  the  ensuing  pages  examine  whether  and  how  these  problems  exist  in  the 
Netherlands. The impact of each problem on different stakeholders is illustrated using a rating 
system, where red denotes severe, amber denotes significant and green denotes negligible (as 
explained in the box below). 

Rating system:  

Rating  

Explanation of rating 

Major weakness / problem and significant investment / complex solution needed to 
address this issue which affects multiple stakeholders severely.  

Significant weakness / problem and some investment needed to address this issue 
which affects more than one group of stakeholders significantly. 

Problem is only negligible and/or could be easily addressed with few regulatory 
hurdles and does not seriously impact any one stakeholder. 

Problem: Administrative burdens in the management of goods crossing boarders  
Rating  

Main stakeholders affected and how 

Explanation of rating 

Most processes related to customs 
clearance are already digitised in the 
Netherlands. Documentation that still 

  Partner competent authorities issuing 

regulatory requirements demanded for in 
hard copy: inefficient processes 

268   Commission  Regulation  (EC)  No  136/2004  of  22  January  2004  laying  down  procedures  for  veterinary  checks  at 

Community border inspection posts on products imported from third countries 

Page 205 / 237 

 
 
 
 
 
 
                                                 
  Economic operators dealing with goods 
demanding these types of requirements: 
inefficient processes 

is issued on hard copy are mainly 
regulatory requirements with EU 
legislation as a base. This is seen as a 
problem, but not regarded as a major 
issue since the goods subject for these 
types of non-regulatory requirements 
are not very significant compared to 
the total (although looked at in 
relation to smaller Member States the 
number is still high). However due to 
Brexit, it is likely that the number of 
especially CVEDs will heavily 
increase. Therefore, there is a risk of 
an increased administrative burden in 
relation to this.  

The Netherlands has already a well-developed digitised system and most processes are digital. 
None of the interviewees saw the verification processes related to regulatory requirements as 
major  part  of  their  administrative  burdens  since  the  goods  requiring  these  are  not  that 
significant  compared  to  the  total.  However,  looking  at  the  numbers  in  relation  to  smaller 
Member  States,  they  are  still  high.  For  example,  during  2017  over  122 600  CVEDs  (both 
CVED-A  and  CVED-P)  and  over  260 000  were  issued269,  which  is  a  very  high  number 
compared  to  other  EU  Member  States.  This  means  that  even  if  Dutch  officials  do  not 
recognise  this  as  one  of  the  major  issues,  it  would  still  clearly  mean  improvements  and 
benefits for them in terms of less administrative burden.   

Furthermore, due to Brexit and the Netherlands having much trade with the United Kingdom 
of especially animal products, the number of issued CVEDs is expected to heavily increase. 
This  also  means  that  the  administrative  burden  for  government  officials  and  traders  will 
increase when many more CVEDs will need to be issued.  

One  official  working  at  the  Human  Environment  and  Transport  Inspectorate  (which  e.g. 
issues  waste  certificates)  stressed  however  that  for  certain  regulatory  requirements  with  EU 
legal base, the legislation is lagging behind since it requires that these requirements must be 
submitted  in  hard  copy.  This  was  an  annoying  issue  for  the  Inspectorate  as  well  as  for 
economic  operators  dealing  with  waste,  but  not  described  as  a  severe  problem.  The 
inspectorate  issues  about  3000  export  regulatory  requirements  every  year  and  has  about  12 
full-time  staff  working  with  the  related  processes  of  the  waste  certificates.  If  all  processes 
went completely digital the inspectorate would likely be able to do some cost-savings, since 
they would then probably not need as many employees.  

Problem: Poor exploitation of electronic exchange of information 

Rating  

Explanation of rating 

Main stakeholders affected and how 

This is described as something which 
could be further improved, both in 
order to connect the single window 
systems (e.g. connecting the Maritime 

  Customs officials and partner competent 
authorities: the long-term objective is 
to interconnect all the different 
systems. 

269   Source: Dutch customs, through homework assignment 1. 

Page 206 / 237 

 
 
  
 
 
                                                 
single window system with customs 
procedures), and to improve risk 
management procedures. However, it 
is not recognised as a significant 
problem.   

 

Economic operators: would welcome 
better exploitation of information. 

Dutch  customs  has,  as  already  mentioned,  the  ambition  to  interconnect  different  single 
window  environments  and  make  them  interoperable.  The  customs  found  it  unfortunate  that 
e.g.  the  maritime  single  window  had  not  been  fully  exploited  to  also  include  customs 
procedures. The Netherlands believes that there is room from improvements, but it did not see 
this  as  a  severe  nor  prioritised  issue.  Furthermore,  Dutch  customs  found  it  positive  that  all 
systems  are  not  connected  and  that  there  are  different  and  separated  procedures  and  IT 
systems. The reason for this was said to be that this made the system less vulnerable, meaning 
that if one system is bugging, it will not completely shut down all processes. Regarding the 
economic operators, they  did  describe a situation where they often have to  submit the same 
information  several  times,  but  did  not  consider  this  too  much  of  a  problem  thanks  to  the 
current,  rapid  online  mechanisms  of  submitting  information.  However,  they  would  still 
appreciate  better  exploitation  and  reuse  of  information  –  anything  that  makes  their  forward 
processes quicker and easier is welcomed.  

Problem: Multiplication of information and procedural redundancies 

Rating  

Explanation of rating 

Main stakeholders affected and how 

In today’s IT landscape, this is not 
seen as an issue since it is reportedly 
no longer costly nor time-consuming 
to submit data messages.  

  Economic operators: duplication of 

submission of information was not said 
not be a problem. 

As mentioned in the previous point, the Dutch trade associations / economic operators stated 
that the submission of information to application and regulatory requirement procedures is not 
seen as such a much of a problem. This  used to be a problem before,  when  you had to  pay 
money to  submit information online and when this process  was rather time-consuming. But 
nowadays, these processes are for free and goes very quick.  

According  to  the  trade  associations  (and  the  customs),  the  single  window  idea  of  a  ‘single’ 
point  of  the  submission  of  information  is  built  on  an  out-dated  idea.  But  again,  of  course, 
anything  that  makes  the  processes  easier  and  quicker  is  appreciated.  As  stated  before,  the 
Dutch customs underlined however that there is a point of not interconnecting all the systems, 
to make it safer; certain information is not to be shared too easily, such as data about dual-use 
goods.  

Problem: Enforcement issues and information gaps  

Rating  

Explanation of rating 

Main stakeholders affected and how 

The problems described in relation to 
this is mainly related to the regulatory 
requirements that have an EU legal 
base, since these are the only ones 
issued in hard copy. The enforcement 

  Customs officials and competent 

authorities: outdated EU legislation / 
unharmonized data procedures hampers 
efficient processes   

  Economic operators: annoying and 

Page 207 / 237 

 
 
 
 
 
 
 
 
unpractical which paper documents  

of these types of regulatory 
requirements is said to sometimes be 
problematic due to these documents 
still being needed in paper-format, and 
the lack of harmonisation of 
procedures across the European 
Union.  

The  main  problem  for  Dutch  customs  related  to  enforcement  is  that  it  cannot  completely 
digitise  all  their  customs  processes  since  certain  EU  legislation  still  requires  regulatory 
requirements to be issued on paper. This also means that certain EU Member States only have 
the  information  on  paper  and  other  only  digital,  which  can  long  processes  when  countries 
need  to  communicate  with  each  other  regarding  certain  types  of  documents  (e.g.  to  check 
whether the regulatory requirement is valid / authentic).  

Similarly, for trans-frontier shipments of waste, the lack of uniformity between systems (with 
some  countries  using  digitised  systems  and  some  countries  only  accepting  paper;  and  with 
different ways of recording volumes) means there is no EU-wide data and no way to check / 
verify  between  countries  (see  also  box  below).  In  both  the  above  cases,  the  lack  of 
harmonisation in EU systems and/or the lack of EU legalisation to underpin the development 
of such systems, means there is a barrier to EU-wide enforcement and gaps in information on 
the nature and scale of enforcement problems in the first place.  

However, in some cases, the absence of centralised system and full data sharing between 
Member States can be justified – as in the case of dual-use licenses where data storage is 
especially sensitive due to national security / trade concerns.  

Likely future developments  

This section provides insight on how the problems described above are likely to evolve in the 
future, either through the continuation of the baseline scenario or pursuit of policy options for 
enhanced G2G and / or B2G collaboration. Potential impacts include direct costs and benefits 
for  different  stakeholders,  as  well  as  indirect  effects  related  to  the  implementation  of  and 
compliance with given regulatory requirements. Below we provide a summary of the expected 
impacts under different scenarios, followed by a summary of how well the problems outlined 
in  section  3.2  would  be  addressed.  For  each  problem,  we  provide  a  rating  of  the  expected 
impact (as outlined below). 

Expected impact ratings:  

Rating 

Explanation of rating 

+++ 

Problem would be substantially improved / eradicated  

++ 

Problem would be improved to a significant extent 

+ 

0 

Problem would see some (limited) positive improvement  

Very limited or no change  

Continuation of the baseline scenario in the Netherlands 

Page 208 / 237 

 
 
 
 
For the Netherlands, the continuation of the baseline scenario would mean an expansion of the 
G2G collaboration, as it would eventually join the EU SCW-CERTEX (from the moment the 
CERTEX  project  has  updated  its  IT  system  to  CCN2).  The  one-off  costs  for  joining  the 
project would be borne by Dutch customs, and are expected to not be very significant since 
the  IT  systems  are  already  in  place.  The  direct  benefits  of  joining  the  project  would 
expectedly be enhanced coordination between customs and the partner competent authorities, 
as well as better routing of consignments. Especially with regards to CHED certificates being 
part of the EU SCW-CERTEX, this would likely benefit the Dutch customs since the CHED 
permits  are  likely  to  increase  heavily  due  to  Brexit.  The  indirect  benefits  are  related  to  risk 
management, since a participation in the EU SCW-CERTEX is expected to lead to enhanced 
cooperation between customs and partner authorities (both at a national and European level).  

Continuing  with  the  developments  at  a  national  level,  the  Dutch  customs  will  take  their 
overarching,  national  single  window  plans  further  on  and  expect  to  have  such  a  system  in 
place  post  2028.  In  principle,  all  certificates  that  are  related  to  goods  crossing  the  external 
border of the EU into the Netherlands will be covered in the future system.  

The  table  below  sums  up  the  expected  impacts  under  the  baseline  scenario  for  each  of  the 
main problems and shows these would be positive overall.  

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ 

Dutch  customs  highlighted  the  probable  benefits  of  having  the  partner  competent  authorities  even  more 
coordinated when joining the EU CSW-CERTEX (which it plans to do  when the  EU CSW-CERTEX project 
goes on to CCN2, as earlier mentioned). One benefit mentioned by customs is e.g. improvements for the risk 
management processes, since it would mean easier communication between partner competent authorities.  

The baseline scenario does not ensure that paper-documents would no longer be required. This means that the 
scenario would however have small change on the administrative burden for the Netherlands. 

Multiplication of information and procedural redundancies 

0 

The  multiplication  of  information  and  procedural  redundancies  remain  under  the  baseline  scenario.  With  no 
change to the legal basis for customs and/or non-customs regulatory requirements, and no single-entry point for 
data  submission,  parallel  paper  submission  would  continue,  as  would  the  duplication  of  information.  This 
means costs  would not differ  substantially  while the duplication of information submitted would continue  for 
economic operators. 

Poor exploitation of electronic exchange of information 

0 

The electronic change of information is expected to improve over time as more partner competent make their IT 
systems interoperable with EU IT systems and databases through EU SCW-CERTEX. Moreover, this will allow 
Dutch  customs  and  customs  officials  to  more  easily  collaborate.  However,  due  to  the  voluntary  basis  of  the 
baseline  scenario,  there  is  a  risk  that  EU  Member  States  not  participating  in  the  EU  SCW-CERTEX  will 
continue with paper-based certificates, resulting in no better electronic exchange of information.  

Enforcement issues and information gaps 

0 

The impacts in relation to enforcement gaps and information gaps are very limited under the baseline scenario. 
The  main  impacts  would  be  about  more  understanding  of  controls  and  more  targeted  searches  through  better 
risk analysis. However, the main issue related to enforcement for the Netherlands is about the EU legal basis for 
the certificates that demand the paper copies, i.e. the baseline scenario would have to entail juridical changes to 

Page 209 / 237 

 
 
generate benefits for the country.  

Options for enhanced G2G collaboration 

These options involve putting in place a legal base to boost back-end, G2G cooperation on the 
exchange of data relating to a different category of certificates and specific technical solutions 
for implementation. The options are not mutually exclusive but can be combined depending 
on the pros and cons of including different certificate categories. 

Option 1 is regarded as positive by the Dutch interviewees, and benefits in terms of smoother 
communications  between  authorities  when  they  join  the  EU  CSW-CERTEX  project.  The 
greater  potential  benefits  are  however  dependent  on  developments  regarding  EU  legislation 
that  would  allow  a  full  digitisation  process  specific  regulatory  requirement,  e.g.  related  to 
waste, animals and animal products.  

With  the  G2G  options,  the  Netherlands  would  prefer  for  as  many  EU-wide  regulatory 
requirements  as  possible  to  be  included.  National  regulatory  requirements  however  are  not 
wished for to be included or made possible to access for other EU Member States since it is 
believed  to  mean  too  great  security  issues.  The  Netherlands  would  probably  not  prefer  a 
centralised  solution,  since  they  already  have  their  own,  well-functioning  IT  systems.  In 
addition, having decentralised IT solutions is seen as safer than having a central solution, if 
there would be IT problems.  

The  table  below  sums  up  the  expected  impacts  for  enhanced  G2G  collaboration  for  the 
Netherlands for the most pertinent options discussed above. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

 + (++) 

Dutch  customs  highlighted  the  probable  benefits  of  having  the  partner  competent  authorities  even 
more  coordinated  when  joining  the  EU  CSW-CERTEX,  e.g.  when  it  comes  to  risk  management 
processes  requiring  communication  between  the  authorities  (as  already  mentioned).  However,  the 
existing  administrative  burden  is  mainly  related  to  certain  regulatory  requirements  still  needed  in 
paper-copy.  If  certain  certificates,  such  as  the  AGRIM  or  the  CHED  were  completely  digitised,  it 
would  reduce  administrative  burdens  for  Dutch  officials.  Dutch  customs  could  not  estimate  how 
much cost-savings they would generate from this, but looking at the numbers of 122 600 CVEDs and 
over 260 000 CHED-PPs issued in 2017, in addition to around 133 000 AGRIM and AGREX licenses 
issued  in  2017270,  it  would  likely  be  positive.  Furthermore,  the  Human  Environment  and Transport 
Inspectorate  dealing  with  waste  stated  that  it  would  for  sure  reduce  their  administrative  burden 
dramatically if certificates were harmonised and fully digitised in all Member States. If this happened, 
the Inspectorate would probably be able to gain at least the equivalent of 12 full-time working staff.  

Multiplication of information and procedural redundancies 

0 

As with the baseline scenario, enhanced G2G collaboration does not necessarily mean a reduction in 
multiplication of information or procedural redundancies. This would require a single-entry point for 
economic operators (as per B2G collaboration outlined overleaf). 

270   Source: Dutch customs through homework assignment 1.  

Page 210 / 237 

 
 
 
                                                 
Poor exploitation of electronic exchange of information 

+ 

As with customs, economic operators would stand to gain from more seamless connections between 
government  (nationally  and  with  third  party  governments).  This  would  need  to  be  supported  by 
digital signatures to allow for a fully paperless system and a change in costs (i.e. removing / reducing 
the  need  to  send  documents  by  courier  as  well  as  electronically).  It  is  unclear  how  significant  the 
costs would be to organise the needed IT systems, but most partner competent authorities’ systems 
are  at  least  already  in  place.  The  scale  of  impact  is  difficult  to  estimate  but  would  be  somewhat 
positive. However, since for most declarations the electronic exchange of information is already fine, 
the  enhanced  G2G  cooperation  is  not  believed  to  change  much  regarding  the  exploitation  of 
information.  

Enforcement issues and information gaps 

++ 

Enhanced  G2G  collaboration  would  open  opportunities  for  improved  enforcement  and  lead  to 
improvements  in  understanding  the  scale  of  problems,  especially  if  the  legal  basis  allows  for 
completely  digitising  the  regulatory  requirements.  This  would  then  likely  lead  to  cost-savings  for 
both partner competent authorities and economic operators since they would have to spend less time 
conducting controls and spending time with submitting customs declarations. The scale of impact is 
difficult to estimate but would be positive, especially for goods such as waste and animals and animal 
products, goods that today require certificates issued in paper-document.  

Options for enhanced B2G collaboration 

Options  5-7  are  about  business-to-government  (B2G),  front-end  cooperation  that  focus  on 
different  ways  of streamlining reporting processes for the economic operators when dealing 
with  the regulatory requirements. The options for B2G collaboration are  mutually  exclusive 
(meaning only one can be pursued) and range from no action (covered under section 4.1); a 
common  management  portal  (option  5);  interoperable  national  Customs  Single  Windows 
(option 6) and Single EU Customs Single Window trader portal (option 7).  

In general, the Dutch interviewees are positive about the B2G options and believes that they 
would  lead  to  beneficial  impacts,  especially  for  the  economic  operators.  These  impacts 
concern having easier and smoother processes, which mean less time spent on administration, 
which  in  turn  means  cost-savings.  Dutch  customs  would  especially  support  a  realisation  of 
option  6,  recognising  it  as  the  most  desirable  and  realistic  proposal  for  the  customs  and 
partner  competent  authorities.  With  this  option, Dutch  customs  would  like  to  have  as  many 
regulatory requirements as possible included, including AGRIM/AGREX and certificates for 
dual-use  and  strategic  goods.  This  is  believed  to  likely  lead  to  smoother  processes  and 
therefore  cost-savings  for  both  authorities  and  economic  operators.  However,  seen  that  the 
biggest priorities for the Dutch customs is Brexit and the requirements of the Union Customs 
Code, it is stressed that a realistic, long-term timeframe is needed.  

For Dutch traders, the submission of information into different systems is not said to be the 
main hurdle, even if the harmonisation of data would be appreciated and likely lead to time 
(and cost) savings for them. A greater problem is the tracking of documents and procedures 
that can be troublesome. For economic operators and freight forwarders, the biggest concern 
is to deliver the good to its destination in time. If this entire process is made faster and easier, 
it will lead to great benefits for the economic operators in terms of cost-savings and content 
customers.    A  system  where  documents  could  be  tracked  during  the  entire  logistic  chain  is 
therefore demanded for, since many economic operators use customs brokers to handle their 

Page 211 / 237 

 
 
 
customs  declaration  procedures  since  it  still  requires  great  administrative  work.  If  customs 
declaration procedures were made simpler, e.g. by some of the features proposed trough the 
B2G solutions, this could potentially mean cost-savings if economic operators then would not 
need to pay for customs brokers.   

According to the interviewed Dutch trade associations, around 15-20% of their members deal 
with regulatory requirements needed for goods transported from or to third countries.  

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

++ 

The improvements relating to administrative burden could be significant, especially if the regulatory 
requirements today needed in paper-format would be covered an made fully digital.  

Multiplication of information and procedural redundancies 

++ 

This would be significantly improved with a single-entry point which would necessarily reduce the 
multiplication of information and could reduce procedural redundancies for especially the economic 
operates, as well lead to cost-savings due to more efficient processes.  

Poor exploitation of electronic exchange of information 

+ 

This would be significantly improved with a single-entry point which would need to be supported by 
full exploitation of electronic exchange of information. 

Enforcement issues and information gaps 

+(+) 

The impacts from enhanced B2G collaboration vis-à-vis enforcement issues may occur if 
a more integrated system provides economic operators with a single reference outlining in 
one  place  all  their  obligations.  If  this  system  also  would  entail  some  sort  of  tracking  of 
documents feature, it would be especially appreciated by Dutch economic operators.  

Conclusions 

This final section draws conclusions related to the severity of the problem in the Netherlands 
and desirability and impacts of the different policy options.  

Nature and scale of problems with the current situation 

The  Netherlands  has  come  far  when  it  comes  to  its  digitisation  of  customs  related  IT 
processes, which likely is due to it being a very significant country for EU trade. Therefore, 
some  of  the  problems  we  identified  in  the  problem  tree,  is  not  very  significant  for  the 
Netherlands.  In  addition,  the  number  of  goods  requiring  these  types  of  regulatory 
requirements are not said to be very substantial (however, we don’t have any exact numbers 
on this and the data from the interviews should not be seen as comprehensive).  

Based on the interviews during our field visit, the single window initiative does not appear to 
be as needed or would contribute with as much added value for the Netherlands as it would 
for  other  Member  States  who  have  come  less  far  with  their  digitisation.  In  addition,  other 
priorities  are  much  more  prominent  for  the  Dutch  customs  administration  and  economic 
operators  at  the  moment,  such  as  the  Union  Customs  Code  and  future  consequences  due  to 
Brexit. Although, due to a lot of trade with animals and animal product trade with the United 

Page 212 / 237 

 
 
 
  
Kingdom, the number of CHEDs will most likely heavily increase post-Brexit, meaning that 
administrative burdens related to the issuing of these certificates risks to increase.  

Even if the problems described are not said to be severe for the Netherlands, it does not mean 
that an EU single window solution would not generate any positive effects for the country. It 
would for sure bring certain benefits when it comes to more efficient communication between 
the  customs  office  and  partner  competent  authorities  regarding  checking  procedures.  If  the 
legal  basis  of  certain  EU  regulatory  requirements  would  be  changed  to  allow  the  complete 
digitisation of these requirements, it would be especially beneficial and lead to  cost-savings 
for both state and business.  

Problem  

Rating 

Administrative burdens in the management of goods crossing borders 

Poor exploitation of electronic exchange of information  

Multiplication of information and procedural redundancies 

Enforcement issues and information gaps 

Feasibility and desirability of the policy options 

The most desirable and the most feasible scenario are briefly summarised below. 

Scenarios 

Baseline:  The  Netherlands  is  planning  on joining  the  EU  CSW-CERTEX (when  the  project  goes  on 
CCN2)  and  the  baseline  scenario  would  thereby  bring  certain  improvements  in  terms  of  enhanced 
cooperation between concerned authorities.   

G2G:  The  expected  impacts  of  enhanced  G2G  collaboration  would  be  positive,  enabling  better 
coordination  for  risk  management  processes  and  less  administrative  burden  if  full  digitisation  was 
ensured.  

B2G:  All  B2G  options  are  positively  regarded  and  believed  to  lead  to  positive  impacts.  Despite  the 
more  significant  expected  impacts  of  option  6  for  B2G  across  all  problems  (and  therefore  its 
desirability),  the  feasibility  is  seen  as  rather  low  in  the  immediate  term  with  too  high  upfront 
investments required as well as coordination among many partner competent authorities. In summary, 
action on the B2G perspective is wished for, but with a realistic timeframe.  

Page 213 / 237 

 
 
 
 
 
 
   
 
 
 
  
 
 
SPAIN 

Introduction  

This report is one of the eight country case studies that were carried out to provide evidence 
for the impact assessment of the initiative for developing an EU Single Window environment 
for  customs.  By  collecting  and  analysing  data  on  the  current  situation  and  expected  future 
developments, the case studies aim to generate insight on the nature and scale of any existing 
problems  and  likely  impacts  of  the  policy  options  defined  for  the  potential  new  initiative. 
These  include  an  option  for  no  additional  EU  action,  which  would  consist  of  the  continued 
existence and  gradual  expansion of the EU Customs  Single Window:  Certificates Exchange 
project  (simply  referred  to  as  CERTEX  project  throughout)  without  a  legal  framework  and 
therefore based on Member States’ voluntary participation.  

Each case study used a common methodology based on a documentary review, feedback from 
national  administrations  provided  through  participation  in  the  project  group  and  interviews 
(mainly  face-to-face)  with  officials  from  customs  and  partner  competent  authorities,  and 
economic operators. The sample of eight Member States was selected in discussion with DG 
TAXUD with a view to covering complementary areas of interest and achieving a degree of 
representativeness.  

Within  this  broader  framework,  the  research  on  individual  case  studies  varied  according  to 
national  specificities  such  as  geography, 
trading  profile,  administrative  set-up  and 
participation  in  the  EU  Single  Window  –  Common  Veterinary  Entry  Document  (EU  SW-
CVED) pilot project (the predecessor to the CERTEX project). 

For Spain, the case study focused on:  

  Experiences  with  an  advanced  national  Single  Window  environment  that  is 

comparable with the CERTEX project 

  Likely future developments 
  Problems specific to Spain 

It concludes on the successes of the initiative in Spain and the desirability and impacts of the 
different policy options. 

The evidence for the case study is comprised of desk research and interviews with 16 customs 
authorities  (policy  managers,  electronic  customs  coordinators  and  IT  specialists),  partner 
competent  authorities  (responsible  for  health,  economy,  medicinal  products,  agriculture, 
fisheries and food) and economic operators (customs brokers and freight forwarders) carried 
out during a field visit that took place during the week of 12 November 2018.  

Background 

This section presents an overview of Spain’s profile for international trade, administrative and 
IT  set-up  for  customs  and  other  relevant  regulatory  requirements.  It  helps  understand  the 
current national situation and how it would likely evolve for the policy options under review. 
It also briefly presents progress towards a national Single Window in Spain. 

Trading profile 
Spain accounts for about 6.6% of EU imports and 5% of EU exports.271 This is slightly lower 
than Spain’s share of the EU’s population (which is 9.1%).272 Outside the EU, 4% of Spain 

271   Eurostat data on external trade (average for 2011-2017): 

https://ec.europa.eu/eurostat/web/international-trade-in-goods/data/database 

Page 214 / 237 

 
 
                                                 
 
exports go to the United States and 3% to Morocco. In terms of imports from outside the EU, 
7% come from China and 4% from the US.273 The main types of entry are sea274 and air275. 

Spain is the biggest importer of seafood products in the EU, and the fourth importer globally. 
Its  system  of  Illegal,  Unreported  and  Unregulated  (IUU)  import  controls  is  one  of  the  most 
comprehensive  in  the  EU.  Spain  has  indeed  prioritised  implementation  of  the  Catch 
Certificate scheme. More generally, Spain has developed rigorous import controls, including 
to detect products originating IUU fishing.276 

To get an idea of Spain’s success in clearing goods efficiently, we looked at the World Bank’s 
Logistics  Performance  Index277.  Spain  ranks  highly  (18th  globally,  and  11th  among  EU 
Member States) in terms of trade facilitation and ease of doing business overall278. In terms of 
customs specifically279, Spain ranks slightly lower globally (21st), but the same place among 
EU  Member  States  (11th).  Of  the  six  components  that  are  used  to  calculate  the  ranking, 
customs were the lowest scoring in Spain. This suggests that, in Spain, the efficiency of the 
clearance  process  is  the  weakest  link  and  further  improvements  here  would  increase  the 
overall Logistics Performance. 

Administrative set-up 

In Spain, customs are the responsibility of the Agencia Estatal de Administración Tributaria, 
commonly known as  Agencia  Tributaria, or Tax Agency, since its formation on 1st January 
1992. The mission of this public law entity, which is attached to the Ministerio de Hacienda, 
“Ministry of the Treasury”, is the effective implementation of the tax and customs systems in 
Spain,  and  related  matters280.  The  Tax  Agency  has  its  own  legal  status,  which  is  different 
from  that  of  the  General  Administration  of  the  State  and  includes  a  certain  autonomy  in 
budgetary and personnel281 management issues. 

The  Tax  Agency  has  17  special  delegations  in  regional  offices,  one  for  each  autonomous 
community, and representatives in provinces as well. Customs and Excise is one of the Tax 
Agency’s  four  operational  departments,  which  all  have  a  representative  in  each  of  the  17 
regional  offices.  In  addition,  the  Tax  Agency  has  its  own  internal  IT  department, 
distinguishing it from other public law entities, most of which outsource these services. 

272   https://ec.europa.eu/eurostat/documents/2995521/9063738/3-10072018-BP-EN.pdf/ccdfc838-d909-4fd8-b3f9-

db0d65ea457f 

273   https://europa.eu/european-union/about-eu/countries/member-countries/spain_en 
274   Continuous increase since 2013 (397 462 thousands of tonnes, to 485 805 thousand tonnes in 2017).  

See https://ec.europa.eu/eurostat/web/products-datasets/-/mar_go_aa 

275   Continuous increase since 2013 (160 884 tonnes, to 201 607 tonnes in 2017).  

See https://ec.europa.eu/eurostat/web/products-datasets/product?code=avia_goocc  

276   The Environmental Justice Foundation (EJF), Oceana, The Pew Charitable Trusts and WWF, ISSUE BRIEF: Improving 
performance in the fight against illegal, unreported and unregulated (IUU) fishing, Span  – Leading implementation of 
the EU’s Regulation to combat illegal fishing, June 2017  

277   The LPI relies on an online survey of logistics professionals from the companies responsible for moving goods around 
the  world:  multinational  freight  forwarders  and  the  main  express  carriers.  Freight  forwarders  and  express  carriers  are 
best positioned to assess how countries perform. 

278   Based on mean across logistics performance index 2012-2018.    
See https://lpi.worldbank.org/international/aggregated-ranking 

279   defined as “Efficiency of the clearance process (i.e., speed, simplicity and predictability of formalities) by border control 

agencies, including customs” 

280   Such as resources belonging to other State Public Administrations and the EU, which are entrusted to the Tax Agency 

for management, by law or agreement. 

281   In 2016, the Tax Agency had a staff of 25,014 people. See: 

https://www.agenciatributaria.es/AEAT.internet/en_gb/Inicio/La_Agencia_Tributaria/Memorias_y_estadisticas_tributari
as/Memorias/Memorias_de_la_Agencia_Tributaria/_Ayuda_Memoria_2016/2__INFORMACION_INSTITUCIONAL/2
_2__Plantilla_y_presupuesto/2_2__Plantilla_y_presupuesto.html 

Page 215 / 237 

 
 
                                                                                                                                                         
 
 
 
The Spanish Customs and Excise Department 

The Departamento de Aduanas e Impuestos Especiales, “Customs and Excise Department”, is 
structured  in  eight  Deputy  Directorates  General282,  two283  of  which  work  under  the  Deputy 
Directorate General for Customs Surveillance, employing half the Department’s personnel. 
The Customs and Excise Department’s remit284 includes management and inspection of taxes 
on foreign trade; control of the traffic of goods under the different customs and fiscal regimes; 
management  and  inspection  of  excise  duties285;  fight  against  customs  fraud,  but  also 
smuggling,  drugs  precursors  diversion  and  money  laundering;  foreign  trade  statistics; 
development  of  draft  customs  and  excise  duties  regulations  and  programmes286;  definition, 
management  of  risk  analysis  systems  in  the  field  of  external  trade,  safety  and  security  and 
excise duties; management of the Authorised Economic Operator (AEO) status, etc. 

The  strategy  of  the  Customs  and  Excise  administration  has  evolved  over  the  years,  but  its 
mission has always been to  collect and to  protect287.  In addition,  the Union Customs Code 
(UCC)288 brought in a new role for Member States’ customs authorities, with an emphasis on 
security, since customs are the ones at the border. As a result, during 2017-2018, the Customs 
and  Excise  Department  carried  out  more  actions  related  to  the  security  of  the  international 
supply chain, at the entry and exit of goods. To control the borders, the Customs and Excise 
Department  receives  the  help  of  the  Civil  Guard,  with  4 000  dedicated  staff  under  the 
supervision of customs. 

In  addition,  Customs  work  with  several  competent  authorities,  such  as  the  Ministries  of 
Economy  and  Business,  of  Health,  Consumption  and  Social  Welfare,  or  of  Agriculture, 
Fisheries  and  Food,  to  enforce  trade-related  legislation.  For  example,  supporting  documents 
required by the EU for imports or exports of agricultural products are delivered to importers 
of food from third countries by the Ministry of Industry, Trade and Tourism. 

Approach to electronic customs and IT architecture 

Since  the  1990s,  the  Tax  Agency  has  had  a  strong  focus  on  the  provision  of  technical 
solutions  that  could  improve  services  to  taxpayers.  Its  first  e-Administration  project 
(COMPAS289) in 1992 predates the widespread use of the Internet.  Since then, the objective 
has always been to facilitate the import and export of goods. To do so, the Tax Agency was 
provided  with  the  required  technological  systems  but  also  with  internal  developers  and 
designers. Customs authorities’ IT department is in a leading position, as an integrated part of 
the  management  processes.  Highly  qualified  civil  servants  lead  projects  focusing  on 
decreasing  the  cost  of  citizens’  fiscal  obligations,  such  as  the  development  of  the  Single 
Window, with external technical support. A general helpdesk, with a specialised group for IT 

282   Planning  Statistics  and  Coordination;  Customs  Management;  Management  &  Supervision  of  Excise  Duties;  Auditing 

and Investigation; Chemical-Technological; International Relations; 

283   Operations; Logistics. 
284   established by Regulation of 10 December 2007: Orden PRE/3581/2007, de 10 de diciembre, por la que se establecen 
los departamentos de la Agencia Estatal de Administración Tributaria y se les atribuyen funciones y competencias. 

285   In 2016, excise represented 11% of the total tax collection. 
286   The Customs and Excise Department can make proposals because they are the ones applying the regulations, but they 

have no competencies for the elaboration and approval of tributary norms. 

287   First, local economic operators; then the national industry, during the 19th century, and national consumers, during the 

20th century; and today, citizens in general. 

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

Customs Code 

289   Comunicación de Manifiestos a Puertos y Aduanas, “Communication of Manifests to Ports and Customs”  – about Port 
authorities  sending  information  on  the  arrival  of  the  goods  to  customs  offices,  and  the  exchange  of  export  data  in 
EDIFACT format, in June 1994, with the port of Barcelona using a Value-Added Network (VAN). 

Page 216 / 237 

 
 
                                                 
issues  and  another  one  for  business  issues290,  was  created  to  make  it  easy  for  economic 
operators to interact with the Tax Agency’ systems. The Tax Agency therefore became a key 
player in terms of IT development. 
Today, within the Tax Agency, almost everything291 is electronic, and no declaration remains 
in paper format. 

E-documents Processed in 2017 by Spanish Customs 

Foreign trade 

Total 

Electronic 

% 

Import SAD 

Export SAD 

Warehousing SAD 

Transit SAD 

Intrastat 

ENS/EXS 
Temporary Storage292 / Loading 
Manifests 

5 812 022 

5 807 549 

99.92% 

7 649 155 

7 648 886 

100.00% 

416 030 

656 487 

684 994 

415 998 

656 354 

684 303 

99.99% 

99.98% 

99.90% 

4 602 071 

4 602 071 

100.00% 

994 744 

991 309 

99.65% 

Total 

20 815 503 

20 806 470 

99.96% 

Source: Presentation on Spanish IT structure, 12/11/2018 

The  Tax  Agency  uses  a  single  centralised  and  integrated  information  system  for  all 
procedures  and  all  Customs  Offices  in  the  country.  It  is  a  set  of  computer  systems  for 
management, collection, inspection, and accounting, built  on a single linear database shared 
between the different departments, which feed it with relevant information293. This database is 
optimised for consultation and useful to fight against fraud and crime. The information system 
is  web-based,  with  an  Intranet  Technology.  Customs  and  excise  are  completely  integrated 
within the Tax Information System. For Customs, there are two main subsystems: 

  The Operational Database for management purposes (BUDA); 

  The  Business  Intelligence  Database  for  analysis  (Zújar,  a  data  warehouse  with  a 

machine-to-machine possibility, connected to businesses directly). 

Economic operators access the system through the internet and can: 

  Consult  information  (import  duties,  TARIC,  import  guarantees,  sent  excises 

declarations status, situation of chemical analysis of goods, etc.); 

  e-sign e-forms (on-line declaration, validation and response, Customs Decisions); 

 

Interchange  Electronic  Data  (EDI)  for  Customs  and  Excises  declarations  (Import, 
Export, NCTS, ENS, EXS Excises AccDoc, etc.); 

290   About six people reply to requests regarding customs applications. 
291   The procedure says if it is possible to do it by paper for citizens lacking the IT skills, who can also go to public offices 

and ask for help. 

292   The summary declaration for temporary storage is based on a system-to-system exchange but can also be uploaded on 

the portal and on the web office. 

293   Such as: Profits and deductions for personal work, financial investments, renting properties, buy and sell declarations, 
investigations of Customs Surveillance, import and export, currency entry and exit, property register, declarations. 

Page 217 / 237 

 
 
                                                 
  Get on-line validation and responses. 

Economic  operators  can  also  access  the  Operational  Database.  All  of  this  is  done  with  an 
advanced level of security through encrypted transmission (SSL Protocol). 

Customs’ systems are connected to other governmental bodies through an intergovernmental 
network  called  SARA,  and  to  other  Member  States  through  the  Common  Communication 
Network (CCN). 

Single Window state of play and key initiatives 

Spain has an electronic Single Window environment for customs, which was set up as part of 
the  Reform  of  the  Public  Administration.  It  aims  at  centralising  information  required  from 
economic operators by different authorities linked to international trade, to avoid duplication 
and reduce the administrative burden. 
The Working Group began on 16th October 2013, and the pilot project started on 1st January 
2016 in the ports of Vigo, Marín, Barcelona, Algeciras, Santa Cruz de Tenerife, and Bilbao 
for imports in containers. It was then extended to all ports and airports on 1st September 2017, 
for imports only. As of 30th November 2017, the plan is to expand it to all goods, including 
bulk cargo. 

The  next  step  for  Spain  is  to  develop  a  Single  Entry  Point  (SEP).  Even  though  discussions 
have  started  with  competent  authorities  that  are  already  part  of  the  Single  Window 
environment, there is no agreed timeline for the implementation of the SEP. 

The advanced state of play of the Spanish Single Window environment explains why Spain 
chose  not  to  participate  in  the  EU  SW-CVED  pilot  project,  which  aims  to  enhance 
Government-to-Government  (G2G)  collaboration  regarding  CVEDs  by  linking  national 
customs’ IT systems to an EU database called “TRACES” through middleware provided by 
DG TAXUD. This  system  does not  allow to check supporting documents, nor to  access  the 
information they contain. 

Characteristics of the Spanish Single Window: 

  Single access point for all the documents from all parties involved 
  Compatible with simplified customs declaration procedure 
  Compatible with centralised national system 
  Open process 
 
Imports only 

Current experiences 

This section details the nature and scale of the current problems by analysing the processes for 
clearing goods through the border in Spain. It first presents an overview of relevant processes, 
with a focus on the specific types of goods and regulatory requirements, and an outline of how 
the Spanish Single Window environment works in practice. This is followed by more detail 
regarding  the  most  important  problems  with  the  current  situation  for  customs,  partner 
competent authorities, and economic operators. 

Overview of clearance processes 

In  this  section  we  provide  an  overview  of  customs  clearance  processes  in  Spain.  We  first 
outline customs processes, with a focus on the Spanish Single Window environment. The last 
part of this section details the processes relating to the next steps for Spain. 

Page 218 / 237 

 
 
 
Customs processes 

In  2017,  the  Tax  Agency  processed  around  37.7  million  customs  declarations  (10  million 
more  than  in  2015),  of  which  79%  were  exports  and  19%  imports,  in  addition  to  930,206 
transit arrangements.294 Some of these goods are subject to regulatory requirements in fields 
other  than  customs.  To  enforce  these  requirements,  Spanish  customs  work  with  partner 
competent  authorities  (Border  Inspection  Services),  in  charge  of  32  distinct  types  of 
supporting documents. 

he  Spanish  Single  Window  covers  imports  only.  It  involves  the  Tax  Agency,  Border 
Inspection Services (BIS) and economic operators, but also Ports of the State. It is a tool that 
makes  cooperation  and  interaction  between  these  stakeholders  possible.  The  process  for 
import of goods through the Spanish Single Window environment is illustrated in the figure 
below. The example shows all the possibilities of the Spanish Single Window environment, 
but  other  scenarios  are  possible,  as  it  is  designed  as  an  open  and  flexible  process  to 
accommodate different situations. 

Figure 27: The Spanish Single Window environment (for imports by sea) 

Source: adapted from Departamento de Aduanas e Impuestos Especiales, Ventanilla Única Aduanera 

Economic  operators  can  start  inputting  information  up  to  30  days  before  the  arrival  of  the 
goods295, filling in an incomplete pre-declaration296. This allows them to get information on 
which  supporting  documents  they  need,  on  whether  these  are  part  of  the  Single  Window 
environment  and  which  BIS(s)  to  apply  to.  Once  the  Tax  Agency  receives  this  Pre-
Declaration,  it  is  issued  with  a  Movement  Reference  Number  (MRN).  Economic  Operators 
can use this number to apply for supporting documents to the relevant BIS(s), who will send 
the  necessary  data  directly  to  the  Tax  Agency.  The  link  with  the  import  declaration  is 
automatic and does not require any further action from the economic operator. The Complete 
Pre-Declaration automatically becomes the Single Administrative Document (SAD) when the 
goods arrive, which leads to their automatic release. Once the economic operators have sent a 

294   Figures provided by Spanish customs 
295   After 30 days, the declaration is classified as “no arrival of the goods”. 
296   If  the  declaration  is  incomplete,  the  economic  operator  must  send  the  complete  version  later,  after  which  the  Tax 

Agency might send back the list of required supporting documents still missing. 

Page 219 / 237 

 
 
 
                                                 
declaration, whether complete or incomplete, they can consult and send information through 
the SW at any time. 

If  physical  control  is  required,  BIS(s)  must  request  it  through  the  Single  Window  but  also 
send the answer to the economic operator directly. Information for/from the physical control 
is  at  stakeholders’  disposal  through  the  Single  Window.  For  maritime  transport,  there  is  a 
specific functionality to allow for the only once positioning of containers at seaports (referred 
to as the “one-stop-shop” mechanism). Once activated the summary declaration for temporary 
storage  and  once  received  the  answer  from  all  the  relevant  BIS(s)  and  from  customs 
authorities, the operator must present a “request for preliminary actions” for the “positioning 
with  SAD”  of  the  container.  Then  the  Tax  Agency,  after  checking  that  there  is  no  other 
necessary recognition, authorises the positioning and informs the operator, the BIS(s) and the 
Port of the State.297 The economic operator must apply to customs authorities, who decide to 
put  container  at  disposal  of  the  BIS(s).  Port  Authorities  access  information  from  the  Single 
Window  through  the  Ports  of  the  State  with  whom  the  Tax  Agency  has  an  agreement  for 
exchange of information. Ports of the state must inform the Tax Agency once all the controls 
are  done.  BIS(s)  communicate  any  decision  directly  to  the  Tax  Agency  through  the  Single 
Window, which includes two kinds of risk analysis systems: 

  A complex On-line Risk Analysis System for Customs Clearance, with an anti-fraud 

control both in data capture and after clearance of goods. 

  The  system  instantaneously  replies  to  each  declaration,  based  on  an  automated  risk 
analysis,  in  one  synchronous  transaction298.  Whatever  is  needed  is  performed  within 
two seconds. It is therefore important to have all the information in the system. As an 
example,  for  the  Entry  Summary  Declaration  (ENS),  the  automated  risk  analysis  is 
performed  within  the  same  transaction  and  a  first  result  can  be  provided  to  the 
economic operator (red, orange, yellow or green channel). 

Functionalities of the Spanish Single Window: 

  Web services 
  G2G exchange of information 
  Pre-SAD and MRN included in the supporting document for automatic clearance 
  Common repository of documents (which all stakeholders can access) 
  Only once positioning of containers at seaports (One Stop Shop) 
  Automated reception of the supporting documents  

As of 30th November 2017, the following functionalities were missing from the Spanish SW: 

  Single Entry Point – being developed with BIS(s) 
  Advance notice of controls299 

  Expansion to exports 

297   For air transport, this kind of only once positioning of the goods is not required. 
298   There are also mechanisms to provide asynchronous communication with economic operators, but it is not the preferred 

way. 

299   Art.  24.3  DA:  “Cuando  un  AEO  presente  una  declaración  de  depósito  temporal  o  una  declaración  en  aduana  de 
conformidad con el artículo 171 del Código, la aduana competente para recibir dicha declaración de depósito temporal o 
dicha declaración en aduana notificará al AEO, en caso de que el envío haya sido seleccionado para un control aduanero, 
al respecto. Dicha notificación se efectuará antes de la presentación de las mercancías ante la aduana.” – "When an AEO 
submits  a  declaration  of  temporary  storage  or  a  customs  declaration  in  accordance  with  Article  171  of  the  Code,  the 
customs office competent to receive such declaration of temporary storage or such customs declaration to customs shall 
notify the AEO, in case the shipment has been selected for a customs control, in this regard. Such notification shall be 
made before the presentation of the goods to customs. " 

Page 220 / 237 

 
 
 
                                                 
A  “News”  section  on  the  website  explains  everything  that  could  change  for  economic 
operators, including new requirements. 

Non-customs regulatory requirements 

The  following  types  of  regulatory  requirement  account  for  the  most  significant  volumes  in 
Spain, and are part of the national Single Window: 

  Common  Health  Entry  Document  for  Plant  Protection  (CHED-PP)  (N851):  this 
document  covers  Council  Directive  2000/29/EC  on  protective  measures  against  the 
introduction into the Community of organisms harmful to plants or plant products, and 
against their spread within the Community. Spain deals with approximately more than 
300 000 of these documents per year for imports. 

  Certificate of quality (N003) – Also more than 300 000 per year. 
  Common Veterinary Entry Document: Animal Products (CVEDP) (N853): this is 
a  common  EU  supporting  document  for  the  import  of  veterinary  products  –the  EU 
regulation300  also  sets  down  rules  for  the  inspection  of  goods  at  border  inspection 
posts. Spain deals with approximately 200 000 CVED-P per year. 

With  the  Servicio  Oficial  de  Inspección,  Vigilancia  y  Regulación  de  las  Exportaciones 
(SOIVRE), the Inspection Service of the Ministry of Economy and Business, for example, the 
input  tray  runs  every  3  minutes.  A  delivery  execution,  in  peak  hours,  can  contain  224 
charges/imputations,  133  responses  sent  by  the  Tax  Agency,  128  discharges/authorisations 
sent  to  the  Tax  Agency  and  101  validations  sent  to  the  Tax  Agency,  which  make  586 
messages in one submission. 

Cost/benefits of the Spanish Single Window environment  

The  cost  of  the  Spanish  Single  Window  for  partner  authorities  is  the  development  of  the 
complex  computer  system.  Once  implemented,  this  system  facilitates  their  work  and  is  the 
perfect tool to manage controls. Its functionalities also entail savings for companies. 

It is not easy to calculate the economic costs involved in adapting partner authorities’ systems 
to  the  Single  Window.  It  is  the  result  of  several  years  of  work,  and  continuous  problem 
solving. The main challenge for competent authorities, as is the case of the Secretary of State 
for Trade for example, is finding the budget to start working on new developments. 

In the IT department, two part-time employees are responsible for managing the system and 
improvements,  and  three  part-time  employees  work  in  the  communications  and  systems 
departments.  Internally,  approximately  393  people  use  the  Secretary  of  State  for  Trade’s 
system daily, and the external users are approximately 3,200. 

For partner competent authorities, the system presents different advantages. They can: 

  carry out the monitoring plan and control frequency; 

  manage alerts and controls; 

  designate official control; 

  gather data and report on rejections, and authorisations of national destination. 

The  Spanish  Single  Window  groups  the  procedures  that  must  be  followed  for  customs  and 
other regulatory requirements: 

300   Commission  Regulation  (EC)  No  136/2004  of  22  January  2004  laying  down  procedures  for  veterinary  checks  at 

Community border inspection posts on products imported from third countries 

Page 221 / 237 

 
 
                                                 
 

 

 

 

to shorten processing times, 

to unify the forms, 

to reduce the use of paper,  

to  accelerate  customs  clearance,  coordinating  physical  controls  so  that  they  are 
carried out in a single moment by all the BIS(s) involved. 

The  Spanish  Single  Window  enhanced  cooperation  in  both  government-to-government,  at 
national  and  with  the  European  level,  and  business-to-government  cooperation  at  national 
level.  It provides economic operators with  a harmonised access  point to  fulfil all regulatory 
requirements.  The  Tax  Agency  acts  as  a  hub  for  receiving  relevant  information  from 
economic operators on behalf of partner  competent  authorities. Before, it  was the economic 
operator who had to coordinate the different physical controls. 

Benefits of the Spanish Single Window for economic operators: 

  Voluntary process 
  Possibility to issue pre-declarations without the supporting documents 
  Possibility not to include the supporting document(s) in box 44 of the SAD 
  Possibility to start the process at any time with any step 

Main problems in Spain 

Several  aspects  of  the  abovementioned  processes  can  be  problematic  for  customs, 
partner competent authorities and economic operators. Using the problems defined in the 
problem  tree  (see  section  3  of  the  main  study  report)  as  a  starting  point,  the  ensuing 
pages  examine  these  in  detail.  The  impact  of  each  problem  on  different  stakeholders  is 
illustrated  using  a  rating  system,  where  red  denotes  severe,  amber  denotes  significant 
and green denotes negligible (as explained in the box below). 

Rating  

Explanation of rating 

Major weakness/problem and significant investment / complex solution needed to 
address this issue which affects multiple stakeholders severely.  

Significant weakness/problem and some investment needed to address this issue which 
affects more than one group of stakeholders significantly. 

Problem is only negligible and/or could be easily addressed with few regulatory hurdles 
and does not seriously impact any one stakeholder. 

Problem: Administrative burdens in the management of goods crossing borders  

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem is only negligible in 
Spain as the national Single Window 
environment significantly reduced 
administrative burdens in the 
management of goods crossing borders, 
especially for economic operators, 
although it is still expanding 

  Customs authorities: significantly reduced 

administrative burden 

  Partner competent authorities: limited to 
physical controls and production of 
supporting documents 

  Economic operators: still apply for 

supporting documents with each relevant 
competent authority and to different 

Page 222 / 237 

 
 
 
 
 
 
 
 
authorities in each Member State but the 
process thereafter is more streamlined in 
the Single Window due to G2G 

Administrative burdens in the management of goods crossing borders were not considered to 
be  a  significant  problem  in  Spain.  These  were  indeed  significantly  reduced  with  the 
implementation  of  the  national  Single  Window  environment,  which  has  brought  benefits  in 
terms of efficiency of the customs clearance process through greater G2G cooperation. 

The most important administrative burden that remains is for economic operators, who must 
apply  to  different  national  authorities  and  in  each  Member  State,  in  addition  to  making  the 
customs  declaration.  This  was  not  considered  as  a  major  issue  by  economic  operators 
consulted  because  they  are  aware  of  Spanish  customs’  work  towards  an  SEP.  According  to 
them, this would constitute an ideal situation, which means the current one is not. 

Problem: Multiplication of information and procedural redundancies 

Rating  

Explanation of rating 

Main stakeholders affected and how 

Procedural redundancies exist in Spain 
when digitised supporting documents 
must be printed out for archiving or for 
legislative reasons 

  Customs authorities: limited impact 
  Competent authorities: inefficient use of 

resources and not realising full benefits of 
an electronic environment 

  Economic operators: must apply for 

supporting documents to the competent 
authorities, in addition to enter 
information in customs’ system 

Multiplication  of  information  and  procedural  redundancies  were  not  presented  as  a  major 
problem  in  Spain  but  do  remain,  despite  significant  improvements.  For  example,  before  the 
Single  Window  environment  was  introduced,  customs  authorities  used  to  control  the  same 
goods in several occasions, which is not the case anymore. 

One problem that emerged during the interview with the central sanitary authority (Ministry 
of Health, Consumption and Social Welfare), whose competence covers the sanitary control 
of  goods  for  human  consumption  (products  of  animal  and  non-animal  origin  from  third 
countries)  regarding  the  way  the  information  is  stored  and  shared.  Even  though  it  is  done 
through TRACES, a paper version of the documents is also stored in every BIP for at least 3 
years.301 So even when systems are fully digitised, a paper copy is still required for archiving 
based on an out of date regulation. Indeed, there are laws that still require paper documents, 
meaning it would be necessary to review the entire body of legislation to adapt it to the Single 
Window environment. 

The  main  procedural  redundancy  is  for  economic  operator,  who  must  make  the  customs 
declaration in customs’ system, and then apply for the required supporting documents to the 
different  competent  authorities.  Both  customs  and  national  authorities  are  aware  of  this 
redundancy,  which  is  why  they  are  working  on  the  SEP,  which  would  make  the  customs 
clearance process even simpler for economic operators. 

Problem: Poor exploitation of electronic exchange of information  

Rating  

Explanation of rating 

Main stakeholders affected and how 

301   This was not confirmed by other authorities and therefore seemed to be a specificity of the Sanitary authority. 

Page 223 / 237 

 
 
 
                                                 
Several actors with different priorities, 
and budgets, 
Lack of communication/ 
interoperability between systems 

  Customs authorities: limitation of the 

extent to which they can expand the 
Spanish Single Window environment  
  Competent authorities: lack of budget to 
develop the systems required to join the 
Spanish Single Window 

  Economic operator: must apply for 

supporting documents to each relevant 
competent authority and to different 
authorities in each Member State 

Poor  exploitation  of  electronic  exchange  of  information  remains  an  issue  in  Spain,  despite 
99.6%  of  Customs  and  Excise  documents  processed  during  2017  being  digital.302  A  few 
competent authorities have not managed to fully digitise their systems and lack the budget to 
do  so.  Competent  authorities’  budget  is  therefore  a  barrier  to  the  expansion  of  the  Spanish 
Single  Window  environment.  Competent  authorities  indeed  need  to  adapt  their  system  to 
customs’,  which  is  costly.  Optimal  exploitation  of  electronic  exchange  of  information  at 
national level is therefore a matter of competent authorities’ priorities. 

Competent  authorities  from  the  Ministry  of  Health,  Consumption  and  Social  Welfare 
indicated poor exploitation of electronic exchange of information to be a problem at EU level. 
Because  of  their  experience  of  the  Single  Window  project,  national  authorities  can  feel  the 
difference at EU level. It makes the fact that improvements are necessary with other MSs and 
the  EU  even  more  obvious.  There  is  no  real  time  communication  between  all  authorities 
involved at EU level. This means that to exchange information at EU level requires an action 
from authorities involved, to make a request for example. 

Problem: Enforcement issues and information gaps  

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem requires EU-wide 
legislative action, including 
harmonisation of systems to have 
comparable information across borders. 

  Customs authorities: believe this is an 
essential weakness of the current 
environment for EU customs 

  Competent authorities: issues related to 
enforcement of respective regulations 
  Economic operator: indirect impact on 

society more broadly 

Poor  exploitation  of  electronic  information  results  in  difficulties  for  enforcement  of  quotas 
and information gaps within, but also between, EU Member States. The lack of harmonisation 
in EU systems and/or of EU legalisation to underpin the development of such systems, means 
there is a barrier to EU-wide enforcement and gaps in information on the nature and scale of 
enforcement problems in the first place. 

According  to  representatives  of  competent  authorities,  the  problem  is  that  the  European 
Commission does not offer an integrated system for the implementation of controls based on 
Community  law.  Some  countries  created  their  own  systems,  which  is  costly,  based  on  their 
own interpretation  of the law. There are countries where controls  are strict and precise, and 

302   Source: Presentation on Spanish IT structure, 12/11/2018 

Page 224 / 237 

 
 
 
 
 
                                                 
others where not. Economic operators therefore change countries through which they import 
goods depending on how controls are carried out. Their goods then disappear from controls in 
Spain even though it is their destination. For example, SOIVRE’s representative reported that 
imports  of  small  electronic  material  recently  decreased  in  Spain,  because  they  are  imported 
through the Netherlands, where controls are not as detailed. A 2018 report from the European 
Parliament confirms that: 

“There  is  currently  an  imbalance  in  the  performance  of  customs  control  by 
Member  States.  This  imbalance  is  due  both  to  geographic  differences  between 
Member  States  and  in  their  respective  capacities  and  resources,  as  well  as  to  a 
lack  of  standardised  customs  controls.  […] The  provision  of  equivalent  customs 
control  equipment  is  therefore  an  important  element  in  addressing  the  existing 
imbalance.  It  will  improve  equivalence  in  the  performance  of  customs  controls 
throughout Member States and thereby avoid the diversion of the flows of goods 
towards  the  weakest  points.  All  the  goods  entering  the  customs  territory  of  the 
Union should be subject to thorough controls in order to avoid “port-shopping” 
by custom fraudsters.” 303 

Additional problem (specific to Spain): Resistance to digitisation 

Rating  

Explanation of rating 

Main stakeholders affected and how 

This problem is specific to a few 
places in Spain, where officials are 
reluctant to using digitised 
documents 

  Customs authorities: limitation of their efforts 
  Competent authorities: inefficient process and 

administrative effort  

  Economic operator: delays, cost of storing 

goods, administrative burden, etc. 

According to one of the economic operators consulted, the problem is that customs processes 
depend on the point of entry, and more specifically on the personnel in charge. For the border 
sanitary control for example, in Vitoria they are working with PDFs and electronic signatures. 
It works well because the person responsible is cooperative. But in Madrid, the person wants 
economic operators to go to the office, queue, etc. In Barcelona, it is the same, and the person 
is in the city centre. It is the only process that is not part of the Spanish Single Window. The 
idea that it depends on the team in charge was echoed by other economic operators consulted. 

Likely future developments 

This section provides insight on how the problems described above are likely to evolve, either 
through  the  continuation  of  the  baseline  scenario  or  pursuit  of  policy  options  for  enhanced 
government-to-government  (G2G)  and/or  business-to-government  (B2G)  collaboration. 
Potential  impacts  include  direct  costs  and  benefits  for  different  stakeholders,  as  well  as 
indirect  effects  related  to  the  implementation  of  and  compliance  with  given  regulatory 
requirements.  Below  we  provide  a  summary  of  the  expected  impacts  under  different 
scenarios, followed by a summary of how well the problems outlined in section 5.3.2 would 
be  addressed.  For  each  problem,  we  provide  a  rating  of  the  expected  impact  (as  outlined 
below). 

303   Committee on the Internal Market and Consumer Protection,  Report on the proposal for a regulation of the European 
Parliament  and  of  the  Council  establishing,  as  part  of  the  Integrated  Border  Management  Fund,  the  instrument  for 
financial support for customs control equipment (COM(2018)0474 – C8-0273/2018 – 2018/0258(COD)), 12 December 
2018  
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+REPORT+A8-2018-
0460+0+DOC+XML+V0//EN  

Page 225 / 237 

 
 
 
                                                 
 
Rating  Explanation of rating 

+++ 

Problem would be substantially improved / eradicated  

++ 

Problem would be improved to a significant extent 

+ 

0 

Problem would see some (limited) positive improvement  

Very limited or no change  

Continuation of the baseline scenario in Spain 

For  Spain,  the  continuation  of  the  baseline  scenario  implies  a  gradual  expansion  of  G2G 
collaboration  at  national  level  as  the  scope  of  the  Spanish  Single  Window  will  continue  to 
increase.  All  competent  authorities  are  expected  to  progressively  join  the  Spanish  Single 
Window. In addition, there are formal discussions with partner competent authorities on the 
move to a SEP. 

The one-off costs of gradually expanding the scope of the Spanish Single Window would be 
borne  by  competent  authorities  (and  would  vary).  Competent  authorities  that  already  joined 
considered the direct benefits to be worth it, for instance more efficient and effective routing 
of consignments, and a smoother and more efficient operation through automatic updates in 
the system.  

In addition,  concrete plans exist  for a national Single Window which would go further than 
G2G cooperation. Spain is indeed aiming towards an SEP for economic operators to facilitate 
the  submission  of  customs  and  non-customs  information  required  for  the  import/export  of 
goods. Customs authorities are working with Phytosanitary, Waste, Pharmacy, SOIVRE (both 
Commercial  Safety  and  Commercial  Quality,  and  electrical  and  electronic  equipment) 
authorities to analyse the data required to be added to the customs declaration and on the flow 
of  messages.  This  would  cover  all  the  supporting  documents  from  the  partner  authorities 
involved. At the time of writing, this would not cover AGRIM, AGREX, CITES, dual use and 
cultural goods, invasive exotic species, ecological products. 

this  national  Single  Window 

For 
to  constitute  an  SEP  for  economic  operators 
importing/exporting  products  through  Spain,  EU  databases  would  need  to  receive  the 
applications  for  some  EU  supporting  documents  directly  from  national  customs  authorities 
instead  of  economic  operators.  Currently,  economic  operators  apply  for  these  supporting 
documents directly to the EU level. In this national Single Window scenario, customs would 
send these applications from the customs declaration, which would include the additional data 
required for each type of supporting document. 

Spanish  customs  are  also  working  on  the  advance  notice  of  controls  to  AEO  and  on 
expanding the Single Window to exports. 

For  these  changes  to  be  implemented  smoothly,  information  is  key.  Customs  authorities 
created a Single Window portal on the web page of the Tax Agency, including a description 
of the project, with access to technical documentation, presentations, etc.304 

The  main  costs  related  to  these  developments  are  technical  ones,  but  because  Customs 
authorities  have  an  internal  IT  department,  it  is  not  possible  to  make  an  estimation.  Partner 
authorities  have  external  IT  experts,  so  each  authority  will  make  an  estimation  of  the  costs 
and  include  it  in  its  budget.  The  situation  is  different  depending  on  each  authority’s  budget 
allocation, projects and priorities. 

304   http://www.eugo.es/ 

Page 226 / 237 

 
 
 
                                                 
What Spanish competent authorities want is to be able to see is which supporting documents 
have been used. The next step is to feed the national database with data from European ones 
and see when an SAD is being modified. It will allow the national system to generate various 
levels of risks. This is foreseen within the next year, but it depends on the budget allocated to 
the project, which is being decided at the level of the Secretary of State. 

The  table  below  sums  up  the  expected  impacts  under  the  baseline  scenario  for  each  of  the 
main problems and shows these would be positive overall but would not sufficiently address 
the problems. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ 

As  more  competent  authorities  join  the  Spanish  Single  Window,  administrative  burdens  (which  are 
already considered to be reasonably low) decrease further. 

Multiplication of information and procedural redundancies 

++ 

When the SEP becomes a reality, procedural redundancies for economic operators will disappear. 

Poor exploitation of electronic exchange of information 

+ 

Over time, the electronic exchange of information is expected to improve as more partner competent 
authorities digitise their system and adapt it to join the Spanish Single Window. However, the benefits 
would  be  limited  by  the  lack  of  any  guarantee  that  the  same  investments  would  be  made  in  other 
Member States. 

Enforcement issues and information gaps 

0 

The  impacts  in  relation  to  enforcement  gaps  and  information  gaps  are  limited  under  the  baseline 
scenario.  The  voluntary  nature  of  the  CERTEX  project  means  it  lacks  an  EU  level  quantity 
management function that limits the scope for gains in enforcement. 

Options for enhanced G2G collaboration 

These options involve putting in place a legal base to boost back-end, G2G cooperation on the 
exchange  of  data  relating  to  a  different  category  of  supporting  documents  and  specific 
technical  solutions  for  implementation.  The  options  are  not  mutually  exclusive  but  can  be 
combined  depending  on  the  pros  and  cons  of  including  distinct  categories  of  supporting 
documents. 

In the short term, the priority for Spain is the expansion of the national Single Window to as 
many supporting documents as possible. The direct costs and benefits of doing so would be 
the same as for the continuation of the baseline scenario. 

In  the  medium  to  longer  term,  the  main  category  of  supporting  documents  that  customs 
authorities  would  be  interested  in  further  collaboration  are  AGRIM,  AGREX,  CITES,  dual 
use  and  cultural  goods,  invasive  exotic  species,  ecological  products,  given  that  coverage  of 
these  is  not  foreseen  under  the  baseline  scenario.  The  direct  costs  would  depend  on  the 
technical  solution  agreed on. The option favoured by Spain  would be for a central  database 
developed  at  EU  level.  As  such,  the  direct  costs  for  Spain  would  be  low.  The  expected 
benefits would be an improvement in the electronic exchange of information. Indirect benefits 
would be better oversight. 

The  representative  of  the  Sanitary  authority  indicated  that  communication  between  all  the 
authorities  involved,  in  Spain,  but  also  with  authorities  of  other  MS  and  with  the  EU  level 
must be fluid. This require improving G2G collaboration. 

Page 227 / 237 

 
 
 
CERTEX constitutes a solid basis for enhanced G2G collaboration at EU level. At the time of 
writing, SOIVRE is connected to CERTEX, and it is working. In the future, SOIVRE would 
like CERTEX to connect  to  all the different  databases.  Both  SOIVRE and national  customs 
authorities  would  like  to  get  the  information  from  CERTEX  without  having  to  request  it. 
Supporting documents would be downloaded automatically into the national system, without 
the  competent  authority  requesting  it.  It  is  possible  to  attribute  the  supporting  documents 
before  the  arrival  of  the  goods.  For  now,  national  authorities  must  enter  the  information  in 
TRACES  to  get  this  information.  This  is  duplication  given  that  economic  operators  have 
already entered the information. It would therefore be possible to do quantity management at 
national level, as a first step, and at EU level if CERTEX were to become mandatory. In terms 
of customs, it does not change anything whether the information come from TRACES or from 
SOIVRE. They would use digital signature for TRACES. 

The table below sums up the expected impacts for enhanced G2G collaboration for Spain for 
the most pertinent options discussed above. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+ 

The  administrative  burdens  will  decrease  as  more  competent  authorities  join  the  Spanish  Single 
Window. 

Multiplication of information and procedural redundancies 

+ 

As with the baseline scenario, enhanced G2G collaboration does not necessarily mean a reduction in 
multiplication of information or procedural redundancies for economic operators. Nonetheless, it could 
avoid duplication linked to the retrieval of information from the EU level by national authorities. 

Poor exploitation of electronic exchange of information 

+ 

As  with  customs,  economic  operators  would  gain  from  more  seamless  connections  between 
governments (nationally and with third party governments). This would need to be supported by digital 
signatures to allow for a fully paperless system. 

Enforcement issues and information gaps 

++ 

Enhanced  G2G  collaboration  would  open  opportunities  for  improved  enforcement  and  lead  to 
improvements  in  understanding  of  the  scale  of  problems,  especially  if  the  legal  basis  allows  for 
quantity management. The impact is hard to estimate but would be positive. 

Options for enhanced B2G collaboration 

Options 5-7 are about  business-to-government  (B2G),  front-end  cooperation that focuses on 
diverse ways of  streamlining reporting  processes for economic operators  when dealing with 
the  regulatory  requirements.  The  options  for  B2G  collaboration  are  mutually  exclusive  and 
range  from  no  action  (covered  under  section  4.1);  through  a  common  management  portal 
(option  5);  interoperable  national  Customs  Single  Windows  (option  6),  to  a  Single  EU 
Customs Single Window trader portal (option 7). 

Page 228 / 237 

 
 
 
For  Spanish  customs  and  partner  authorities,  it  is  essential  that  the  European  Commission 
considers that Member States have their own systems. For them, the only way forward is to 
facilitate the union of these systems.  It should be possible to exchange information between 
the  European  level  and  the  national  systems.  For  Spanish  partner  authorities,  this  could  be 
done either directly or via the Customs authorities of each country. For them, this exchange of 
information should be: 

  online; 

 

for web services; 

  done using XM files (or compatible with); and  

 

respect the complex systems already implemented in the different countries. 

The possibilities for enhanced B2G collaboration are supposed to realise in the near-term in 
Spain through the SEP. Indeed, as mentioned above, Spanish customs decided to include an 
SEP in their national Single Window, and they are already working on it. Partner authorities 
are  also  in  favour  of  this  evolution  of  the  Single  Window,  as  a  trade  facilitation  measure. 
According  to  SOIVRE’s  representative  consulted,  it  is  necessary  that  economic  operators 
interact  with  a  single  interface.  Given  Spain  already  has  a  national  Single  Window,  they 
would  like  to  maintain  it,  which  is  possible  with  option  6.  Spain  plans  on  connecting  to 
TRACES NT, when it is operational. So, in theory, Spanish Customs support Option 6, but it 
needs to be part of a realistic development plan at EU level. Data harmonisation is required, 
whether it be customs or regulatory requirements-related. This should be the first step in terms 
of future developments  of the EU environment  for customs, according to  partner competent 
authorities.  It will make  the  development  of a  real  SEP  at  national  level  easier.  It  should at 
least include EU supporting documents in EU databases. 

The  expected  impacts  of  pursuing  option  6  would  be  significant  but  would  also  require 
significant  investments  by  other  Member  States.  Spanish  customs  understand  that  countries 
with  only  a  few  supporting  documents  do  not  believe  it  is  worth  investing  in  a  complex 
information system. 

The  table  below  sums  up  the  expected  impacts  for  enhanced  B2G  collaboration  for  Spain 
assuming option 6 (which is favoured) were pursued. 

Problem  

Administrative burdens in the management of goods crossing borders 

Change 

+++ 

The  improvements  relating  to  administrative  burdens  would  be  significant  for  economic  operators 
through the SEP, as they would only have to input information in only one place (only once principle). 

Multiplication of information and procedural redundancies 

++ 

This  would  be  significantly  improved  as  a  SEP  would  necessarily  reduce  the  multiplication  of 
information and could reduce procedural redundancies for all stakeholders.  

Poor exploitation of electronic exchange of information 

+++ 

This would be significantly improved if option 6 makes it mandatory for all Member States to develop 
a Single Window in an interoperable way. 

Enforcement issues and information gaps 

++ 

A more integrated system would provide economic operators with a single reference outlining all their 
obligations in one place. 

Page 229 / 237 

 
 
 
Conclusions 

This  closing  section  draws  conclusions  related  to  the  severity  of  the  problem  in  Spain  and 
desirability and impacts of the different policy options. 

Nature and scale of problems with the current situation 

The current situation is not yet optimal, but stakeholders consulted were broadly satisfaction 
with recent developments and plan for further improvement in Spain. Nonetheless, electronic 
exchange  of  information  is  sometimes  limited  due  to  partner  competent  authorities’  distinct 
priorities, and some Member States’ level of digitisation. The exchange of information is also 
limited  because  of  the  lack  of  interoperability  of  different  systems.  The  most  significant 
problem is linked to interpretation of Community law and the resulting differences in terms of 
controls  as  well  as  the  lack  of  EU-wide  quantity  management,  which  create  distortions  of 
competition between Member States within the customs union. 

Problem  

Rating 

Administrative burdens in the management of goods crossing borders 

Multiplication of information and procedural redundancies 

Poor exploitation of electronic exchange of information  

Enforcement issues and information gaps 

Additional problem (specific to Spain): Resistance to digitisation 

Learning from the Spanish Single Window 

Understanding the reasons behind the development of the Spanish Single Window might have 
broader lessons for other Member States. The economic crisis was an important driver for the 
project. Indeed, the Single Window freed up significant resources, which could be redeployed 
elsewhere. Another key factor was having an integrated IT department working in partnership 
with customs within the Tax Agency. Spanish customs’ main objective is facilitation which is 
the purpose of the Single Window. Finally, Spanish customs authorities insisted on the human 
aspect, and on their participatory approach and relation building. 

Neither  the  EU  SW-CVED  pilot,  nor  the  EU  CSW-CERTEX  project  provided  sufficient 
benefits  for Spanish  authorities to  take part. Nonetheless,  customs authorities confirmed the 
relevance  of  having  EU  level  databases  for  EU  level  supporting  documents,  but  the 
information  they  contain  must  be  usable  and  retrievable  by  national  authorities.  Spanish 
customs authorities would like to be able to automatically upload and download data to/from 
TRACES NT, to avoid any duplication of tasks. 

Feasibility and desirability of the policy options 

In  the  case  of  Spain,  the  most  desirable  policy  options  are  linked  to  option  6,  as  briefly 
summarised below.  

Scenarios 

Baseline: The baseline scenario would see increasing improvements linked to the enlargement of the 
Single Window environment and the introduction of a SEP at national level. 

Page 230 / 237 

 
 
 
 
 
 
 
 
G2G: The expected impacts of enhanced G2G collaboration would be high, especially if all systems 
(at EU level) were interoperable. 

B2G:  Option  6  is  highly  desirable  for  Spain  but  would  be  optimal  only  if  it  is  mandatory  for  all 
Member  States  to  develop  a  Single  Window,  and  if  it  includes  G2G  cooperation  (as  described 
above). 

Page 231 / 237 

 
 
GERMANY 

Introduction and evidence base 

The research on Germany was based on interviews with the Federal Customs Authority, three 
partner  competent  authorities  (responsible  for  dual  use  licences  at  the  federal  level,  and  the 
CVED / CHED and waste shipment formalities for the state of Hamburg), and four economic 
operators  (comprised  of  a  multinational  chemicals  company,  a  freight  forwarder,  a  customs 
broker and a large automaker), in addition to documents provided by the interviewees.  

Administrative set-up 

Due  to  its  federal  structure,  the  German  customs  authority  does  not  play  a  leading  role  in 
coordinating  border  management  with  other  authorities  responsible  for  formalities.  Rather, 
this is addressed in different ways depending on the situation in specific federal states. This 
was described a barrier to progress on establishing a single window environment in Germany, 
and to participating in EU CSW-CERTEX.  

Progress so far towards a customs single window 

Germany is not participating in EU CSW-CERTEX or pursuing a national single window for 
the  moment.  However,  there  is  G2G  collaboration  between  customs  and  the  authority 
responsible for dual use licenses that resembles EU CSW-CERTEX for this purpose.  

The  customs  authority  gave  several  reasons  for  the  lack  of  progress  and  enthusiasm  so  far. 
Most importantly (1) other priorities related to IT projects stipulated in the MASP / UCC, and 
Brexit; (2) much of the existing non-customs legislation does not allow for enhanced G2G or 
B2G solutions (3) Germany’s federal structure (with responsibilities for relevant  regulations 
being spread across a patchwork of authorities at different levels) makes it especially hard for 
customs  to  assume  a  leadership  role;  (4)  the  strong  role  of  port  community  systems  in 
Germany, which in many places were described as replicating a lot of what a single window 
would do.  

Any problems with the status quo 

Interviewees  responsible  for  CVED  /  CHED  formalities  and  waste  shipment  described 
laborious  processes  for  dealing  with  clearance  for  relevant  goods,  in  all  cases  involving 
original paper documents. The customs authority confirmed that the situation was similar for 
goods subject  to  other non-customs  formalities. This  was seen to  lead require excess  labour 
and  delays,  as  well  as  potentially  causing  errors.  While  figures  could  not  be  provided,  the 
situation was considered problematic by all interviewees, especially those economic operators 
which  trade  in  goods  subject  to  significant  non-customs  formalities  (e.g.  fresh  fruits  and 
vegetables).  

However,  some  economic  operators  (e.g.  the  car  industry)  emphasised  that  non-customs 
supporting documents play only a very minor role in the time needed for goods clearance. In 
other words, the importance of this issue depends strongly on the goods concerned.  

Likely future developments  

Enthusiasm  for  a  future  EU  single  window  environment  for  customs.  Economic  operators 
were in general enthusiastic about any simplification and trade facilitation measures, while the 
customs authority and partner competent authorities were in principle open if the political will 
and necessary financial resources could be secured. Moreover, partner competent authorities 
emphasised the importance of maintaining high standards of safety and security.  

Page 232 / 237 

 
ITALY 

Introduction and evidence base 

Evidence base. The research on Italy was based on interviews with the customs authority, four 
partner competent authorities (responsible for CVED / CHED, sanitary certificates, hazardous 
chemicals  and  AGRIM  /  AGREX  licences)  and  three  economic  operators  (of  which  two 
customs brokers and a freight forwarder), in addition to documents provided by interviewees.  

Administrative set-up 

The  Italian  customs  authority  has  a  leading  role  for  coordinating  border  management,  as 
defined  in  a  national  legislation,  which  it  then  uses  as  a  basis  for  establishing  service  line 
agreements and memoranda of understanding with partner competent authorities.  

Progress so far towards a customs single window 

Italy does not participate in EU CSW-CERTEX, but has an advanced national single window 
which  involves  G2G  collaboration  for  CVED  and  CED  certificates  and  AGREX/AGRIM 
licenses, as well as several national certificates. Conceptually and practically, this functions in 
a  similar  way  as  EU  CSW-CERTEX,  but  involves  information  stored  at  national  level.  For 
documents using EU databases such as TRACES, the data is replicated nationally so that the 
necessary  processes  can  be  carried  out.  The  amount  of  progress  achieved  was  attributed  to 
leadership  of  the  customs  authority,  which  is  enshrined  in  national  legislation,  and  mutual 
interest from customs and partner government authorities.  

Any problems with the status quo 

Unlike  other  countries,  Italy  has  managed  to  do  away  with  paper  for  the  supporting 
documents  included  in  their  single  window,  for  all  declarations  except  the  small  minority 
involving other Member States.  

Stakeholders on both sides of the table were very positive about the results achieved so far in 
terms of increased efficiency, improved risk management and better enforcement (along with 
knock-on effects  like improved human health). While they had trouble  quantifying benefits, 
before and after examples showed that the achievements were very significant. Customs and 
partner competent felt that documentary controls were quicker, while physical controls were 
easier to coordinate. Moreover, the provision of electronic data, with quantity management at 
national level, was seen to allow for double checking that reduced error rates.  

Examples  can  at  least  give  a  partial  idea  of  the  types  of  gains  that  could  be  expected.  For 
instance,  a  customs  broker  in  Italy  explained  that,  prior  to  the  national  single  window,  the 
operator  was  responsible  for  physically  transporting  documents  between  competent  partner 
authorities  and  the  customs  authority.  This  required  considerable  time  and  /  or  costs  from 
courier  services,  in  addition  to  leading  to  delays  that  had  knock-on  effects  such  as  storage 
costs and lost business from disappointed customers. These costs have now been cut to zero, 
since  the  supporting  documents  in  question  are  sent  electronically  between  authorities, 
without  any  action  from  the  economic  operator.  Similarly,  the  national  single  window  has 
allowed  economic  operators  to  conduct  detailed  status  checks  on  their  declarations  online, 
avoiding un-necessary calls to the authorities or trips to pick up goods that are not ready. The 
introduction  of  the  single  window  has  also  led  to  coordinated  checks  between  customs  and 
partner  competent  authorities, avoiding the movement of containers  at  cost  to  the economic 
operators that previously took place. 

Page 233 / 237 

 
The  costs  of  putting  the  single  window  in  place  mainly  related  to  IT  infrastructure,  while 
training  and  teething  costs  were  seen  as  relatively  manageable  (if  not  completely 
insubstantial).  Unfortunately,  the  customs  authority  was  not  authorised  to  provide  cost  data 
figures due to the politically sensitive nature of budget information.  

Likely future developments  

In the absence of EU action, the national single window initiative would continue to be used. 
However, the customs authority indicated that its expansion would likely slow down or stop, 
given that there an expectation that the single window will be taken forward at EU level.  

Given  this  and  the  notable  success  so  far  at  national  level,  customs  and  partner  competent 
authorities  are  very  keen  on  advancing  the  single  window  at  European  level.  This  was 
expected  to  reduce  costs  and  introduce  functions  like  quantity  management  for  documents 
involving  multiple  Member  States  and,  more  importantly  from  their  perspective,  to  reduce 
discrepancies  in  enforcement  between  Member  States.  This  was  seen  as  a  very  big  deal, 
because the Italians worry about unfair competition due to lax enforcement in other parts of 
the EU.  

Page 234 / 237 

 
 
 
 
ROMANIA 

Introduction and evidence base 

The  research  on  Romania  was  based  on  interviews  with  the  customs  authority,  three 
partner competent  authorities (responsible for CVED /  CHED, FLEGT  certificates, and 
AGRIM  /  AGREX  licences)  and  four  economic  operators  (of  which  three  customs 
brokers  dealing  with  different  types  of  goods  and  one  freight  forwarder)  in  addition  to 
documents provided by interviewees. 

Administrative set-up 

Customs has a leading role in coordinating border management, which it uses to establish 
collaboration and service line agreements with partner competent authorities, though the 
level of collaboration varies strongly by the authority in question.  

Progress so far towards a customs single window 

Romania is not currently participating in EU CSW-CERTEX or having a national single 
window,  with  the  lack  of  progress  mainly  attributed  to  resource  constraints.  However, 
there  are  agreements  in  place  with  the  authorities  responsible  for  CVED  /  CHED 
certificates  that  allow  for  a  degree  of  coordination  regarding  the  submission  of 
documents  and  controls.  Romania  has  also  decided  to  join  EU  CSW-CERTEX  in  the 
next two years and has started taking steps in terms of IT developments. 

Problems with the status quo 

For most EU-normed certificates, paper is still used in Romania. This requires economic 
operators to shuffle paper between authorities and face potentially long waiting times and 
delays, while there are reportedly plenty of human errors regarding enforcement.  

Likely future developments  

The customs authority and other interviewees were generally positive about any EU-led 
trade facilitation initiatives. However, it was also explained that the low levels of trade in 
many of the goods that would be included in a potential initiative (e.g. COI) meant that 
the  current  situation  was  not  seen  as  overly  problematic,  whereas  the  potential  gains 
would  be  limited  in  scale.  Also  considering  resource  constraints,  the  customs  authority 
and  partner  competent  authorities  felt  that  EU  support  would  be  important  in  deciding 
whether to make improvements.  

 
      
 
 
ANNEX 17: OVERVIEW OF POLICY OPTIONS 

Option category 

Overview 

Category  I:  government-
to-government 
cooperation  to  make  it 
easier  for  customs  and 
competent 
partner 
authorities 
share 
to 
information 

at 

Category  II:  business-to-
government  cooperation 
improving 
aimed 
economic 
operators’ 
interactions with customs 
and  partner  competent 
authorities 

Category  III:  Expansion 
of  the  use  of  Economic 
Operator Registration and 
Information (EORI) 

Option  1:  Interconnecting  national  customs  systems  to  EU 
non-customs  regulatory  formalities  digitally  available  at  EU 
level 

Option  2:  Interconnecting  national  customs  systems  to  EU 
non-customs  regulatory  formalities  digitally  available  at 
Member State level  

Option  3:  Interconnecting  customs  systems  to  national  non-
customs regulatory requirements in another Member State 

Option  4:  Interconnecting  national  customs  systems  to  EU 
non-customs regulatory formalities digitally available in third 
countries 

Option 5:  Harmonised portal for economic operators to  fulfil 
EU non-customs regulatory requirements 

Option  6:  Harmonised  national  single-entry  points  for 
economic  operators  to  fulfil  customs  and  non-customs 
regulatory requirements 

Option  7:  EU  single-entry  point  for  economic  operators  to 
fulfil customs and non-customs formalities  

Option  8  (i):  Extended  use  of  the  Economic  Operator 
Registration  and  Identification  System  (EORI)  to  partner 
competent  authorities  for  registration,  identification  and 
validation purposes 

Option  8  (ii):  Extended  use  of  EORI  system  to  partner 
competent authorities for validation purposes 

Page 236 / 237