COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE 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

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   EUROPEAN COMMISSION  Brussels, 28.10.2020  SWD(2020) 239 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE 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) 238 final}  
 
 
Impact assessment on the EU Single Window Environment for Customs initiative  

Executive Summary Sheet 

A. Need for action 

Why? What is the problem being addressed?  
The smooth flow of cross-border trade requires efficient customs clearance and control procedures that ensure the safety and 
security of people and businesses in the EU. This is partly being achieved through the electronic systems mandated in the 
Union  Customs  Code,  which  are  replacing  paper-based  procedures  with  electronic  ones.  However,  more  than  60  non-
customs  EU  acts  as  well  national  non-customs  legislation  (in  health  and  safety,  the  environment,  agriculture,  fisheries, 
international heritage,  market surveillance, etc.)  must also  be enforced at external borders. This requires documents other 
than customs declarations and affects up to 13% of the nearly 300 million goods movements each year, many of which are 
highly  sensitive. Since authorities often  work in silos,  with unaligned systems and processes,  many goods are handled in 
ways that are inefficient, and conducive to error and fraud. For example, some authorisations allow quantities of goods to be 
split  across  multiple  customs  declarations  and  are  valid  EU-wide.  While  authorities  need  to  validate  the  quantities  used, 
manual  checks  are  both  time-consuming  and  insufficiently  accurate.  These  problems  cannot  be  solved  without  new  EU 
action,  partly  because  they  relate  to  EU  formalities.  National  efforts  are  also  often  piecemeal  and  could  exacerbate  the 
problem due to a lack of interoperability and to the cross-border nature of trade. The most relevant EU initiative in this area, 
EU CSW-CERTEX, has had some success but is only voluntary and has a limited scope.  

What is this initiative expected to achieve?  
The general objective is to improve the enforcement of regulatory requirements for an enhanced protection of the EU and to 
facilitate international trade. To meet this objective the initiative will: 
 

define  a  governance  framework  for  enhanced  cooperation  between  customs  and  partner  competent  authorities  and 
develop interoperable solutions where beneficial and appropriate;  
improve working practices between the regulatory authorities involved in international trade to enable more automated, 
electronic and integrated processes for dealing with the goods clearance;  
determine a framework for data harmonisation and enable the re-use of data in order to fulfil the different formalities 
required by customs and non-customs authorities for international trade.  

 

 

What is the value added of action at the EU level?  
The identified problems are inherently transnational, as they involve the cross-border movement of goods, and any error or 
fraud  taking  place  in  an  individual  Member  State  can  have  an  EU-wide  impact.  The  EU,  given  its  responsibility  for  the 
Customs  Union  and  for  the  non-customs  regulatory  requirements  in  question,  is  well  placed  to  coordinate  action,  tackle 
fragmentation and generate economies of scale. Existing and expected action has been shown to be inadequate, because: (i) 
continued  fragmentation/lack  of  interoperability  would  limit  the  benefits  of  gradual  digitalisation  and  modernisation;  (ii) 
national initiatives would be few due to resource constraints and not allow certain key functions such as EU-level quantity 
management;  and  (iii)  EU  CSW-CERTEX  (a  voluntary  initiative)  would  lose  momentum  if  not  followed  by  mandatory 
action.  

B. Solutions 

What  legislative  and  non-legislative  policy  options  have  been  considered?  Is  there  a  preferred 
choice or not? Why?  
Eight policy options were identified. These do not form a list from which a single option could be chosen, but rather fall 
into three broad categories, which could be packaged to form a future policy choice:  
  Category  I  (options  1-4;  combination  of  options  possible):  options  for  government-to-government  cooperation  that 
would make it easier for customs and partner competent authorities to share information. Each option has a different 
scope. Option 1 makes EU CSW-CERTEX mandatory and covers EU regulatory requirements  managed at EU level, 
providing an automated quantity management functionality. Option 2 covers EU regulatory requirements managed in 
national electronic systems. Option 3 covers national regulatory requirements, and option 4 third-country documents.  
  Category  II  (options  5-7;  only  one  option  possible):  options  for  business-to-government  cooperation  aimed  at 
improving  economic  operators’  interactions  with  authorities.  Option  5  sets  up  a  harmonised  trader  portal  for  EU 
certificate  management.  Option  6  establishes  single  windows  at  national  level  to  provide  economic  operators  with 
harmonised access points. Option 7 institutes a single-entry point at EU level.  

  Category III (option 8): a cross-cutting option to streamline the way customs and partner competent authorities identify 
economic  operators.  It  would  rely  on  the  expanded  use  of  the  existing  Economic  Operator  Registration  and 
Identification (EORI) system, either for registration and validation (8i) or just for validation (8ii).  

options 1, 2, 6, 7 and 8ii were retained for in-depth analysis based on a screening exercise. The impact analysis identified 
impacts  of  a  similar  nature  for  all  options.  Direct  economic  impacts  would  include  one-off  implementation  costs  and 
recurrent costs, and savings from a reduced administrative burden for customs authorities, partner competent authorities and 
economic operators when enforcing EU legislation and dealing with goods clearance. Some (unquantifiable) trade benefits 
would  also  be  achieved.  Enhancing  cooperation  and  facilitating  the  sharing  of  information  between  the  authorities 

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responsible for goods clearance would also improve risk management processes and reduce instances of fraud and human 
error. This  would  in  turn  improve  compliance  with  and  enforcement  of  the  non-customs  legislation,  and  generate  related 
social and environmental benefits.  
Different packages of options were compared in terms of effectiveness (i.e. enforcement of relevant regulatory requirements 
and  trade  facilitation),  efficiency,  coherence  with  other  policies  and  proportionality  to  identify  the  preferred  option.  This 
showed that the largest benefits were only possible from packages including both category I and category II options, while 
option  8  (ii)  adds  incrementally  to  any  package.  Options  1  and  6  were  found  to  be  cost-effective,  coherent  and 
proportionate, while options 2 and (especially) 7 were highly problematic in these respects. The preferred package is thus 
options 1+6+8(ii). 

Who supports which option?  
During the extensive consultation, Member State authorities and economic operators expressed the following views:  
  Option  1:  nearly  unanimous  support,  based  on  the  proven  success  of  its  predecessor  EU  CSW-CERTEX,  important 

expected benefits and relatively limited implementation costs.  

  Option 2: only limited support, due to its complexity and high implementation costs, and limited benefits.  
  Option 6: moderate to strong support. Economic operators appreciated its ability to facilitate trade by delivering on the 

full single window concept by providing a single access point for dealing with clearance requirements. 

  Option 7: very limited support due to its complexity and very high costs. Economic operators viewed it positively for 

its ability to streamline and harmonise customs processes throughout the EU. 

  Option 8(ii): though limited in scope, support from nearly all stakeholders as a way to streamline processes.  

C. Impacts of the preferred option 

What are the benefits of the preferred option (if any, otherwise main ones)?  
The  preferred  policy  package  of  options  1+6+8ii  offers  several  relative  advantages.  It  received  the  highest  levels  of 
stakeholder support. It is also expected to generate significant direct economic benefits, totalling € 209.4m to  € 311.5m per 
year once fully operational (i.e. after a phased implementation over 7 years). While the total economic benefit 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 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 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  in  an  effective  and  proportionate  way,  and 
demonstrating value for money.  

What are the costs of the preferred option (if any, otherwise main ones)?  
One-off  implementation  and  recurrent  costs  would  be  borne  by  the  European  Commission,  national  authorities. 
Implementation costs include IT spending, process change management, training and support, and are expected to be phased 
over  a  period  of  7  years.  Later,  recurrent  costs  will  include  maintenance,  periodic  updates,  support  and  day-to-day 
operations. The estimated costs are (in €m, low and high ranges except for EC costs): 

for  gradual 

Total 
implementation 
years 1-7 

EC 
Total  MS 
authorities  
Total 

64.38 to 127.73  

64.73    Annual total once fully 
operational, from year 
8 onwards 

129.11 to 192.46 

EC 
Total MS 
authorities  
Total 

6.35  
5.91 to 11.75 

12.26 to 18.10 

How will businesses, SMEs and micro-enterprises be affected? 

The main problems affect businesses, especially SMEs, and the initiative therefore focuses on trade facilitation and reducing 
administrative burdens, particularly by saving time and making clearance simpler and more automated. It is estimated that 
the preferred option package would lead to benefits for economic operators of €494.1m to €688.4m during the 7 years of 
phased implementation, followed by yearly benefits of €141.2m to €196.7m, in addition to trade benefits that have not been 
possible to quantity. Since businesses will be not required to purchase new equipment or quickly adopt new processes, costs 
are considered negligible.  

Will there be significant impacts on national budgets and administrations?  
The initiative takes advantage of the Commission’s potential to generate economies of scale. However, there are significant 
costs  for  administrations  in  terms  of  spending  on  IT  hardware  and  software,  process  change  management,  training  and 
support, as detailed above.  

Will there be other significant impacts? 
Extensive  stakeholder  consultation  and  examination  of  similar  initiatives  in  other  Member  States  indicated  no  impacts 
beyond those identified. While issues regarding the protection  and security of economic operators’ data could arise, these 
will be addressed under the relevant EU legislation.  

D. Follow up 

When will the policy be reviewed? 
Regular monitoring and periodic evaluation plans have been developed. The former will rely on sources at both EU level 
(e.g. IT deliverables and statistics) and national level (e.g. data on clearance times). Evaluation will take place 6 years after 
entry into force of the legislation and every 3 years thereafter.  

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