COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT Third Progress Report on the Implementation of the EU Strategy and Action Plan for Customs Risk Management
Date: 2021-01-18
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU action, EU control, EU strategy, customs cooperation, customs regulations, customs territory (EU), customs union, exchange of information, import policy, institutional cooperation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.1.2021  SWD(2021) 2 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT Third Progress Report on the Implementation of the EU Strategy and Action Plan for Customs Risk Management {COM(2021) 9 final}  
 
 
 TABLE OF CONTENTS 

1. 

INTRODUCTION ................................................................................................................................... 8 

1.1. 
1.2. 
1.3. 
1.4. 

THE STRATEGY AND ACTION PLAN FOR CUSTOMS RISK MANAGEMENT ......................................... 8 
THE PREVIOUS PROGRESS REPORTS ................................................................................................ 9 
THIRD PROGRESS REPORT (2018-2020): A RESPONSE TO THE COUNCIL’S INVITATION ................... 9 
THE PROCESS OF DRAFTING THE THIRD PROGRESS REPORT ........................................................... 10 

2.  THE PROGRESS REPORT BY OBJECTIVE .................................................................................. 11 

 
 
 
 
 
 

2.1.1. 
2.1.2. 
2.1.3. 
2.1.4. 

2.1. 
OBJECTIVE  1:  IMPROVE  DATA  QUALITY  AND  FILING  ARRANGEMENTS  FOR  EFFECTIVE  RISK 
MANAGEMENT .............................................................................................................................................. 11 
The legal framework ................................................................................................................ 11 
The Union Customs Code evaluation ...................................................................................... 11 
The development and implementation of appropriate IT solutions ......................................... 11 
UCC Import Control System upgrade – ICS2.......................................................................... 13 
2.2. 
OBJECTIVE  2:  ENSURE  AVAILABILITY  OF  SUPPLY  CHAIN  DATA,  SHARING  OF  RISK-RELEVANT 
INFORMATION  AND  CONTROL  RESULTS  AMONG  CUSTOMS  AUTHORITIES  TO  ANALYSE  AND  MITIGATE  RISKS, 
AND ENSURE EQUIVALENT TREATMENT OF ECONOMIC OPERATORS. ............................................................. 14 
2.2.1.  Modification to the legal base ................................................................................................. 14 
Development and implementation of appropriate IT solutions................................................ 14 
2.2.2. 
2.2.3. 
Proposed solutions for traceability of goods’ movement during various customs control stages
14 
The Surveillance 3 System (SURV3) ...................................................................................................... 14 
The common information sharing environment (CISE) ........................................................................... 15 
The Digital Transport and Logistics Forum (DTLF) ............................................................................... 16 
The eManifest pilot project ...................................................................................................................... 17 
The Trade Control and Expert System (TRACES) .................................................................................. 17 
AFIS - CSM ............................................................................................................................................. 18 
2.3. 
OBJECTIVE 3: IMPLEMENT THE CONCEPT OF ‘ASSESS IN ADVANCE — CONTROL WHERE REQUIRED’ 
TO RESPOND ADEQUATELY TO IDENTIFIED EU AND NATIONAL RISKS WHILE MAXIMISING EFFICIENCY IN THE 
USE OF RESOURCES AND FLUIDITY OF THE SUPPLY CHAIN ............................................................................ 18 
2.3.1.  Methodologies to implement the concept of ‘Assess in advance – control where required’ ... 18 
Priority Control Area (PCA) ................................................................................................... 19 
2.3.2. 
Safety ....................................................................................................................................... 19 
2.3.3. 
Financial Risks ........................................................................................................................ 19 
2.3.4. 
Intellectual Property Rights (IPR):.......................................................................................... 20 
2.3.5. 
Product safety and compliance ................................................................................................ 21 
2.3.6. 
2.4. 
IN  EFFECTIVE 
IMPLEMENTATION  OF  THE  COMMON  RISK  MANAGEMENT  FRAMEWORK  AND  TO  INCREASE  RESPONSIVENESS 
TO NEWLY IDENTIFIED RISKS ........................................................................................................................ 22 
The Common Risk criteria (CRC) ............................................................................................ 22 
2.4.1.1. 
Financial Risk Criteria ......................................................................................................................... 22 
2.4.1.2.  The evaluation of the existing Common Risk Criteria (CRC) on Safety and Security ........................ 22 
The Customs Risk Management System (CRMS) ..................................................................... 22 
Actions taken by the Member States under Objective 4 ........................................................... 23 
2.4.3.1.  Methodology used to collect information from Member States .......................................................... 23 
2.4.3.2.  Customs administrations’ level of priority of improving CRMF’s implementation ............................ 24 
2.4.3.3. 
Status of actions aimed at improving the implementation of the CRMF ............................................. 24 
2.4.3.4.  Analysis ............................................................................................................................................... 25 
IT and data resources ............................................................................................................................... 25 
Internal systems ....................................................................................................................................... 26 
Systems, strategies and plans ................................................................................................................... 26 
Common risk criteria and the exchange of risk information .................................................................... 26 
Other activities ......................................................................................................................................... 27 
2.4.3.5.  Developing capacities .......................................................................................................................... 27 
Improving national risk management systems / engines .......................................................................... 27 
Preparations for ICS2 .............................................................................................................................. 29 

OBJECTIVE  4:  STRENGTHEN  CAPACITIES  TO 

SECURE  EQUIVALENCE 

2.4.2. 
2.4.3. 

 
 
 
 
 

2.4.1. 

 
 

1 

 
 
 
 
 
 

2.4.4. 

 
 
 
 

 
 
 
 

  Measures to tackle undervaluation fraud ................................................................................................. 29 
Other measures ........................................................................................................................................ 29 
 
2.4.3.6.  Cooperation / coordination .................................................................................................................. 31 
Use of tools for the exchange of customs information ............................................................................. 31 
Collaboration forums and project groups ................................................................................................. 32 
Seminars and workshops of the Customs 2020 programme .................................................................... 33 
Bilateral and multilateral cooperation / coordination with other Member States ..................................... 33 
2.4.3.7.  Results – strengthened capacities ........................................................................................................ 34 
Higher quality / more comprehensive / efficient / timelier national customs threat and risk assessments.
34 
 
Better  risk  management  thanks  to  more  consistent  /  effective  sharing  and  deployment  of  national 
customs threat and risk assessments in the CRMF. .......................................................................................... 35 
2.4.3.8.  Outcomes............................................................................................................................................. 36 
Enhanced cooperation and sharing of risk information. ........................................................................... 36 
Enhanced financial risk management....................................................................................................... 37 
Better risk analysis through implemented / improved IT solutions. ......................................................... 38 
Better risk analysis through recruitment and training of customs officers. .............................................. 38 
2.4.3.9.  Encountered challenges, difficulties and barriers ................................................................................ 39 
Other actions taken by the Commission under Objective 4 ..................................................... 40 
2.4.4.1. 
ICS 2 Context ...................................................................................................................................... 40 
2.4.4.2.  Customs 2020 project group on post-clearance audit .......................................................................... 41 
2.4.4.3.  Development of EU common risk criteria under the CRMF. .............................................................. 42 
Cash Controls .......................................................................................................................................... 42 
 
Air Cargo Security ................................................................................................................................... 42 
 
Drug Precursors ....................................................................................................................................... 42 
 
Cultural goods.......................................................................................................................................... 43 
 
 
Firearms ................................................................................................................................................... 43 
  Wildlife trafficking .................................................................................................................................. 43 
  Waste ....................................................................................................................................................... 44 
F-GAS ..................................................................................................................................................... 44 
 
2.5. 
OBJECTIVE 5: PROMOTING INTERAGENCY COOPERATION AND IMPROVING INFORMATION SHARING 
BETWEEN  CUSTOMS  AND  OTHER  AUTHORITIES  AT  THE  MEMBER  STATE  AND  EU  LEVEL  TO  ENSURE 
EFFECTIVE RISK MANAGEMENT .................................................................................................................... 44 
Actions taken by the Member States under Objective 5 ........................................................... 44 
2.5.1.1.  Activities and outputs .......................................................................................................................... 44 
Other law enforcement, including intelligence ........................................................................................ 46 
Environment ............................................................................................................................................ 49 
Transport.................................................................................................................................................. 50 
Interagency cooperation with border guards ............................................................................................ 51 
Animal, food, feed and plant health and safety ........................................................................................ 52 
Product safety and compliance ................................................................................................................ 53 
Intellectual property rights (IPR) ............................................................................................................. 54 
Tax ........................................................................................................................................................... 55 
Non-proliferation and conventional weapons .......................................................................................... 55 
Cultural goods.......................................................................................................................................... 56 
Health protection ..................................................................................................................................... 56 
Other ........................................................................................................................................................ 57 
2.5.1.2.  Results – Improved integration/utilisation of risk information ............................................................ 58 
Improved awareness / understanding of existing and emerging risks. ..................................................... 58 
Increased numbers of seizures ................................................................................................................. 59 
Creation of new and adaptation of existing risk profiles. ......................................................................... 59 
2.5.1.3.  Outcomes............................................................................................................................................. 60 
Improved risk management practices ...................................................................................................... 60 
2.5.1.4.  Encountered challenges, difficulties and barriers ................................................................................ 62 
Other actions taken by the Commission under Objective 5 ..................................................... 63 
2.5.2. 
 
Product safety and compliance ................................................................................................................ 63 
  Wildlife .................................................................................................................................................... 63 
Forest Law Enforcement Governance and Trade (FLEGT) ..................................................................... 64 
 
IPR ........................................................................................................................................................... 64 
 
Traditional own resources ........................................................................................................................ 66 
 
 
VAT ......................................................................................................................................................... 67 
  Waste ....................................................................................................................................................... 67 
F-GAS ..................................................................................................................................................... 67 
 

 
 
 
 
 
 
 
 
 
 
 
 

2.5.1. 

 
 
 

 

2 

 
 
 
 
Cash controls ........................................................................................................................................... 67 
 
Health and safety ..................................................................................................................................... 67 
 
Official Control Regulation (OCR).......................................................................................................... 67 
 
The European agenda on security ........................................................................................... 69 
2.5.3. 
Firearms ................................................................................................................................................... 70 
 
Interagency cooperation with border guards ............................................................................................ 70 
 
Strengthening the EU Authorised Economic Operator (AEO) programme ............................................. 71 
 
The EU Policy Cycle / EMPACT – involvement of the customs authorities – cooperation .................... 71 
 
 
The Customs Cooperation Working Party (CCWP) Action Plan ............................................................. 74 
  Modernisation of EU export control system ............................................................................................ 74 
OBJECTIVE  6:  DEVELOP  COOPERATION  WITH  TRADE  TO  SECURE  AND  FACILITATE  LEGITIMATE 
76 

2.6. 
TRADE 

 

 
 

2.6.2. 

2.6.1. 

 
 
 
 

Actions taken by the Member States under Objective 6 ........................................................... 77 
2.6.1.1.  Activities and outputs .......................................................................................................................... 77 
Cooperation ............................................................................................................................................. 78 
Strengthening the AEO Programme via efforts to raise awareness among AEOs about AEO benefits ... 80 
Strengthening the AEO Programme via concepts for measuring and monitoring its implementation ..... 80 
Other ........................................................................................................................................................ 82 
2.6.1.2.  Results ................................................................................................................................................. 83 
2.6.1.3.  Outcomes............................................................................................................................................. 83 
Improved risk management practices ...................................................................................................... 83 
2.6.1.4.  Encountered challenges, difficulties and barriers ................................................................................ 85 
Actions taken by the Commission under Objective 6 ............................................................... 86 
e-AEO direct trader access .................................................................................................................. 86 
2.6.2.1. 
2.6.2.2. 
Strengthening the robust implementation and awareness raising of the AEO programme .................. 86 
2.6.2.3.  Detection technologies ........................................................................................................................ 87 
PROFILE ................................................................................................................................................. 87 
PEN-CP (Pan-European Network of Customs Practitioners)................................................................... 87 
2.7. 
OBJECTIVE  7:  TAP  THE  POTENTIAL  OF  INTERNATIONAL  COOPERATION,  TO  IMPROVE  RISK 
MANAGEMENT  OF  THE  SUPPLY  CHAIN,  FOR  BETTER  IDENTIFICATION  OF  RISKS,  MORE  EFFECTIVE  RISK 
MITIGATION AND COST REDUCTION FOR OPERATORS AND AUTHORITIES ...................................................... 88 
SSTL ......................................................................................................................................... 88 
2.7.1. 
Bilateral relations .................................................................................................................... 89 
2.7.2. 
Exchanges of information ........................................................................................................................ 89 
 
Customs security agreements ................................................................................................................... 89 
 
EU - Norway dialogue on dual use. ......................................................................................................... 89 
 
Belarus ..................................................................................................................................................... 90 
 
Ukraine .................................................................................................................................................... 90 
 
 
Russia ...................................................................................................................................................... 90 
  Moldova ................................................................................................................................................... 90 
Georgia .................................................................................................................................................... 91 
 
United States ............................................................................................................................................ 91 
 
Canada ..................................................................................................................................................... 91 
 
China ....................................................................................................................................................... 91 
 
Japan ........................................................................................................................................................ 91 
 

3. 
INPUT  FROM  MEMBER  STATES  TO  SUPPORT  FUTURE  DEVELOPMENTS  FOR  THE 
POST-2020 PERIOD ..................................................................................................................................... 92 

3.2. 

3.2.1. 
3.2.2. 

3.1.1. 
3.1.2. 

3.1. 
MAIN  ACHIEVEMENTS  THROUGH  THE  CURRENT  RISK  MANAGEMENT  STRATEGY,  ACCORDING  TO 
THE MEMBER STATES................................................................................................................................... 92 
At the national level ................................................................................................................. 92 
At the EU level ......................................................................................................................... 94 
KEY CHALLENGES CURRENTLY FACED IN CUSTOMS RISK MANAGEMENT ..................................... 95 
Internal challenges .................................................................................................................. 95 
External challenges ................................................................................................................. 95 
PRIORITIES FOR THE FUTURE ........................................................................................................ 97 
Customs administrations’ priorities ........................................................................................ 97 
How a successor to the strategy could support the priorities of Member States ..................... 99 
Ensuring the availability and quality of data. ........................................................................................... 99 
Development / revision of common risk analysis supporting tools .......................................................... 99 
Training for data analysts at the EU level .............................................................................................. 100 

3.3.1. 
3.3.2. 
 
 
 

3.3. 

3 

 
 
 
4.  PERFORMANCE AND MONITORING FRAMEWORK ............................................................. 101 

4.1. 
4.2. 

4.2.1. 
4.2.2. 

THE STRATEGY’S INTERVENTION LOGIC ..................................................................................... 101 
THE INDICATOR FRAMEWORK ..................................................................................................... 105 
Developing the indicators for the new strategy ..................................................................... 105 
Indicator tables ...................................................................................................................... 106 

5.  ANNEX: IMPLEMENTATION TABLE .......................................................................................... 115 

OBJECTIVE  4:  STRENGTHEN  CAPACITIES  TO 

5.1. 
OBJECTIVE  1:  IMPROVE  DATA  QUALITY  AND  FILING  ARRANGEMENTS  FOR  EFFECTIVE  RISK 
MANAGEMENT ............................................................................................................................................ 115 
5.2. 
OBJECTIVE  2:  ENSURE  AVAILABILITY  OF  SUPPLY  CHAIN  DATA,  SHARING  OF  RISK-RELEVANT 
INFORMATION  AND  CONTROL  RESULTS  AMONG  CUSTOMS  AUTHORITIES  TO  ANALYSE  AND  MITIGATE  RISKS 
AND ENSURE EQUIVALENT TREATMENT OF ECONOMIC OPERATORS ............................................................ 117 
5.3. 
OBJECTIVE 3: IMPLEMENT  THE  CONCEPT  OF ‘ASSESS  IN  ADVANCE -  CONTROL  WHERE  REQUIRED’ 
TO RESPOND ADEQUATELY TO IDENTIFIED EU AND NATIONAL RISKS WHILE MAXIMISING EFFICIENCY IN THE 
USE OF RESOURCES AND FLUIDITY OF THE SUPPLY CHAIN .......................................................................... 119 
5.4. 
IN  EFFECTIVE 
IMPLEMENTATION  OF  THE  COMMON  RISK  MANAGEMENT  FRAMEWORK  AND  TO  INCREASE  RESPONSIVENESS 
TO NEWLY IDENTIFIED RISKS ...................................................................................................................... 120 
5.5. 
OBJECTIVE 5: PROMOTING INTERAGENCY COOPERATION AND IMPROVING INFORMATION SHARING 
BETWEEN  CUSTOMS  AND  OTHER  AUTHORITIES  AT  THE  MEMBER  STATE  AND  EU  LEVEL  TO  ENSURE 
EFFECTIVE RISK MANAGEMENT .................................................................................................................. 122 
5.6. 
OBJECTIVE  6:  DEVELOP  COOPERATION  WITH  TRADE  TO  SECURE  AND  FACILITATE  LEGITIMATE 
125 
TRADE 
5.7. 
OBJECTIVE  7:  TAP  THE  POTENTIAL  OF  INTERNATIONAL  COOPERATION,  TO  IMPROVE  RISK 
MANAGEMENT  OF  THE  SUPPLY  CHAIN,  FOR  BETTER  IDENTIFICATION  OF  RISKS,  MORE  EFFECTIVE  RISK 
MITIGATION AND COST REDUCTION FOR OPERATORS AND AUTHORITIES .................................................... 128 

SECURE  EQUIVALENCE 

4 

 
 
 
 
 
 
 
 
 
Abbreviations and acronyms 

AEO 
AES 
AFIS 
AI 
AIS 
AM 
AN 
Archeo 

AVSEC 
B2C 
BAPLIE 
BCP 
BSTF 
CBRNE 
CCN 
CCS 
CCU 
CCWP 
CEG CRM 
CELBET 
CITES 

CIVIC  
CLP 
CMRC 
COPIS 
CORE 

COVID-19 
CRC 
CRMF 
CRMS 
CUP 
DEMETER 
ECHA 
EC 
ECS 
EEA 
EIS 

Authorised Economic Operator 
Automated export system 
Anti-fraud information system  
Artificial intelligence 
Automated import system 
Mutual assistance (assistance mutuelle) 
Arrival notifications 
Electronic  information  exchange  platform  managed  by  the  World  Customs 
Organisation 
Aviation security 
Business-to-consumer 
Bayplan/stowage plan occupied and empty locations message  
Border control points 
Baltic Sea Task Force  
Chemical, biological, radiological and nuclear defence 
Common Communication Network 
Cargo Community System 
The Central Coordinating Unit 
Customs Cooperation Working Party  
Customs Expert Group, Customs Control and Risk Management Section 
Customs Eastern and South-Eastern Land Border Expert Team 
Convention  on  International  Trade  in  Endangered  Species  of  Wild  Fauna  and 
Flora 
Common intervention on vulnerability in chains 
Classification, Labelling and Packaging Regulation 
Cash movements risk criteria & standards 
EU-wide anti-counterfeit and anti-piracy information system 
Supply  chain  management  and  supply  chain  security  project  co-funded  by  the 
European Commission 
Coronavirus disease 2019 
Common Risk Criteria  
Common Risk Management Framework 
Customs Risk Management System  
Customs Union Performance 
Joint operation targeting illegal movements of waste 
European Chemicals Agency  
European Commission 
Export control system 
European Express Association 
European information system 

5 

 
 
 
 
to  combating  counterfeiting  and  customs  IPR 

ELO 
EMPACT  
ENS 
EO 
EORI 
EU 
FORUM 
FOS 
FRC 
GDP 
GDPR 
HYGIEA 

The central excise liaison office 
European multidisciplinary platform against criminal threats 
Entry summary declaration 
Economic operator 
Economic Operators Registration and Identification 
European Union 
Forum for Exchange of Information on Enforcement 
Framework of Standards  
Financial Risk Criteria 
Gross domestic product 
General Data Protection Regulation 
Joint  operation  related 
enforcement for fast moving consumer goods 
Contact group of customs managers working in the major EU airports 
Import Control System 
Internet of Things 
Intellectual property rights 
Information technology 
Joint Action Day 
Joint Customs Operations 
Land Frontier Contact Group 

ICARUS 
ICS 
IoT 
IPR 
IT 
JAD 
JCO 
LFCG 
MAR-INFO  Group  of  partners  from  northern  and  southern  regions,  working  to  prevent 
smuggle  of  drugs,  drugs  precursors,  high  tax  goods,  and  goods  related  to 
terrorism and organised crime in the maritime area 
Multi-annual Strategic Plan  
Memorandum of Agreement 
Memorandum of Understanding 
Mutual recognition agreements 
Member State 
Market Surveillance Authority 
New Computerised Transit System 
National Entry System 
National Passenger Information Unit  
New psychoactive substances 
National single window 
Operational action plan 
Operational Coordination Centre 
Organised Crime Group 

MASP 
MOA 
MOU 
MRA 
MS 
MSA 
NCTS 
NES 
NPIU 
NPS 
NSW 
OAP 
OCC 
OCG 
ODYSSUD  Contact group of customs managers working in the major southern ports 
OLAF 
OPSON 
PARCS 

European Anti-fraud Office 
Joint operation targeting fake and substandard food and beverages 
Expert group on the protection of health, cultural heritage, the environment and 
nature 

6 

 
 
 
PCA 
PCA 
PEN-CP 
PIU 
PLACI 
PN 
PNR 
PROFILE 

RACER 
RALFH 
RAPEX 
RASFF 
REACH 

REACH-EN-
FORCE 
RIF 
RIMSCO 
RTG 
SAD 
Silver Axe 
SIS 
SOCTA 
SPOC 
SRSP 
SSTL 
SW  
SWOT 
TCG 
Thunderball 
TRIP 
TS 
TS 
UCC 
VAT 
VIN 
WCO 

Priority Control Area 
Partner Competent Authority 
Pan-European Network of Customs Practitioners 
Passenger Information Unit 
Pre-loading advanced cargo information 
Presentation notifications 
Passenger Name Record  
Horizon 2020 research project that leverages modern data analytics and new data 
sources for effective customs risk management 
Relevant, accepted, credible, easy to monitor and robust 
Contact group of customs managers working in the major northern ports 
Rapid alert system for non-food products 
Rapid alert system for food and feed 
Regulation  on  protection  of  human  health  and  the  environment  from  the  risks 
that can be posed by chemicals 
Enforcement project of the European Chemicals Agency 

Risk information form 
Risk Management Strategy Implementation Coordination Group 
Rubber-tyred gantry crane 
Single administrative document 
Joint operation to combat illegal and counterfeit pesticides 
Schengen Information System 
Serious Organised Crime Threat Assessment 
Single Point Network Contact  
Structural reform support programme 
Safe and Secure Trade Lanes 
Single Window 
Strengths, Weaknesses, Opportunities, and Threats 
Trade Contact Group for Customs 
Joint operation to combat wildlife crime 
Travel information point 
Technical specifications  
Temporary storage 
Union Customs Code 
Value added tax 
Vehicle identification number 
World Customs Organisation  

7 

 
 
 
 
 
 
1. INTRODUCTION 

1.1.  The Strategy and Action Plan for customs risk management 

On  21 August  2014,  the  European  Commission  adopted  a  Communication  on  the  EU 
Strategy and Action Plan for customs risk management titled ‘Tackling risks, strengthening 
supply chain security and facilitating trade’1. 

The strategy comprises seven key objectives, underpinned by the overall aim of reaching a 
high  quality,  multi-layered  approach  to  risk  management,  which  is  both  effective  and 
efficient. The seven key objectives are: 

1. 

Improving data quality and filing arrangements 

2.  Ensuring  availability  of  supply  chain  data  and  sharing  of  risk-relevant  information 

among customs authorities 

3. 

Implementing control and risk mitigation measures where required 

4.  Strengthening capacities 

5.  Promoting  interagency  cooperation  and  information  sharing  between  customs  and 

other authorities at Member State and EU level 

6.  Enhancing cooperation with trade  

7.  Tapping the potential of international customs cooperation 

The  strategy  outlines  appropriate  risk  mitigation  and  control  measures  to  be  used  at  the 
most opportune time and place in the supply chain. It takes account of the variable nature 
and  broad  range  of  risks  to  be  addressed,  and  the  primary  responsibility  of  customs 
authorities in supervising the EU’s international trade in goods.  

The  strategy  also  takes  into  account  the  role  of  other  competent  authorities  involved  in 
supply  chain  movements,  and  emphasises  the  need  for  complementarity.  It  also  refers  to 
the  international  context  of  risks  and  the  importance  of  international  cooperation  in  risk 
management.  

It further takes into consideration:  

 

 

the importance for the EU of facilitating and accelerating trade;  

the central role of economic operators; and 

1 

COM(2014) 527 final. 

8 

 
 
 
 
                                                 
 

the necessity to avoid undue disruption of logistics and supply chain processes. 

1.2.   The previous progress reports2 

The  Commission  presented  its  first  progress  report  on  the  implementation  of  the  EU 
Strategy and Action Plan for customs risk management3 to the Council and the European 
Parliament in July 2016. The report aimed to give an overall qualitative assessment of the 
strategy’s  implementation,  highlight  the  progress  made  under  each  of  the  seven  key 
objectives and draw some preliminary conclusions.  

The second progress report4 was presented to the Council and the European Parliament in 
July 2018. Similar to  the first  report, it  provided an overall qualitative assessment  of the 
strategy’s  implementation,  by  outlining  the  progress  made  under  each  of  the  seven  key 
objectives since the publication of the first report.  

Rather  than  attempting  to  assess  the  strategy’s  impact,  these  two  progress  reports  were 
based  on  a  qualitative  survey,  which  gathered  input  from  Commission  departments  and 
Member States’ authorities on the implementation of the individual actions measures under 
the strategy in order to identify both successes and challenges.  

1.3.   Third progress report (2018-2020): A response to the Council’s invitation 

On  8 January  2019,  the  Council  adopted  its  conclusions  on  the  Commission’s  second 
progress  report5. It welcomed the progress made  on implementing the strategy, including 
the  strengthened  collaboration  between  all  actors  involved.  The  Council  also  praised  the 
launch  of  new  initiatives,  in  particular  the  Commission’s  decision  on  Financial  Risk 
Criteria and the participation of customs administrations in security-related activities.   

It underlined the need to continue to implement the strategy efficiently and in line with the 
work plan for electronic systems as mentioned in Article 280 of the Union Customs Code 
(UCC) and as foreseen for the implementation of the UCC.  

The  Council  also  noted  that  the  customs-trade  partnership  as  well  as  cooperation  with 
international partners needs to be further explored and strengthened in order to: (i) promote 
competitiveness; (ii) ensure supply chain security;  (iii) facilitate the legitimate movement 
of goods; and (iv) carry out effective and efficient customs controls. 

2  

4  

5  

The first progress report covered the period 2015-2016 whilst the second progress report covered the  
period 2017-2018. 
First Progress Report on the implementation of the  EU Strategy and  Action Plan  for customs risk  
management: 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52016DC0476&from=EN 
Second Progress Report on the implementation of the EU Strategy and Action Plan for customs risk  
management: 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0549&from=en. 
2019/C24/06. 

9 

 
 
 
                                                 
  
 
  
   
  
  
It underlined that risk management is an ongoing process, which is not limited to specific 
actions  with  a  well-defined  beginning  and  end  dates,  and  that  customs  authorities  must 
therefore continue to innovate and be prepared to respond to new and emerging threats.  

The Commission was invited to present its third progress report on the implementation of 
the strategy within 2 years, and to develop - in close cooperation with the Member States - 
an efficient reporting mechanism to measure the impact of outcomes and results of specific 
actions deriving from the strategy. 

The  new  monitoring  system  has  not  been  applied  to  the  current  2014-2020  strategy  and 
action  plan  given  that  they  will  be  ending  shortly.  Instead,  this  report  contains  a  well-
developed draft monitoring system that will be recalibrated in line with the objectives and 
actions of the future strategy to be proposed by the Commission. 

Responding  to  the  Council’s  request,  the  Commission  has  adopted  this  third  progress 
report  on  the  implementation  of  the  EU  Strategy  and  the  Action  Plan  for  customs  risk 
management (‘the report’) accompanied by this Staff Working Document. 

The  present  Commission  Staff  Working  Document  provides  detailed  information  on  the 
actions’  implementation,  objective  by  objective.  In  Part  3,  the  Commission  shares  some 
reflections on the next strategy. For example, it plans to reshape and strengthen the current 
risk management framework in order to achieve a more responsive and structured approach 
to  risk  management.  In  Part  4  the  Commission  presents  ideas  and  suggestions  for 
establishing a monitoring system. This system, which will be tailored to the next strategy 
and developed in close cooperation with the Member States, will enable the Commission to 
better evaluate its implementation. 

1.4.   The process of drafting the third progress report 

To  prepare  this  third  progress  report  the  Commission  gathered  information  from  various 
sources, including: 

  open source information; 
 
in-house expertise; and  
  a survey of all Member States asking about their progress on several actions under 

objectives 4, 5 and 6. 

In  this  report,  the  achievements  are  presented  according  to  the  seven  objectives  of  the 
strategy  rather  than,  as  in  the  two  previous  reports,  by  sub  actions.  This  is  because  the 
activities  of  national  administrations  cannot  easily  be  disentangled  and  classified  under 
individual  actions  and  sub-actions  as  defined  in  the  Strategy.  Many  activities  actually 
simultaneously cover several actions and/or sub-actions.  

In  addition,  as  noted  by  the  Council,  risk  management  is  a  process  that  is  not  limited  to 
actions  with  clearly  identified  beginning  and  end  dates.  Consequently,  a  number  of  the 
strategy’s  actions  and  sub-actions  are  continuous  or  permanent  in  nature  and  therefore 
considered as being permanently ‘in progress’ or ‘ongoing’. 

10 

 
 
 
 
 
 
2. THE PROGRESS REPORT BY OBJECTIVE 

2.1.  Objective  1:  Improve  data  quality  and  filing  arrangements  for  effective 

risk management 

As mentioned in the previous progress  reports, the strategy and the action plan call for a 
legal  framework to  be set  up to  ensure the availability of high-quality supply chain  data. 
For goods entering the EU, this concerns for instance data on advance cargo information 
relating to supply chain movements. Such data not only needs to be available but also have 
to  be  used  adequately  by  customs  and  other  competent  authorities  for  the  purpose  of 
customs risk management. 

2.1.1. 

The legal framework 

The legal  framework consists  of the Union Customs Code (UCC)6  and the detailed  rules 
contained  in  the  delegated  and  implementing  acts.  The  Code’s  substantive  provisions 
entered into force on 1 May 2016.  

While the Commission has not identified any major problem in the application of the Code 
regarding the quality of data for the ENS, other issues relating to data quality might need to 
be addressed in the future. It is clear that the benefits and the impact of the Code will only 
be fully materialised when all the related IT systems will be available.  

2.1.2. 

The Union Customs Code evaluation  

By the end of 2021, The Commission will carry out an evaluation to establish whether the 
Union  Customs  Code  and  the  electronic  systems  completed  by  that  date  are  still  fit  for 
purpose to reach the objective to ensure modernised, streamlined and simplified processes 
for the assistance of compliant traders and customs authorities without hampering customs 
capacities to identify and tackle risks.  

This  evaluation  will  support  future  decisions  on  whether  the  Code  and  its  implementing 
and  delegated  acts  should  be  revised.  It  will  in  particular  consider  whether  the  Code  is 
sufficiently flexible to deal with the management of customs formalities during crises such 
as the current Covid-19 pandemic and with new business models such as e-commerce.  

2.1.3. 

The development and implementation of appropriate IT 

solutions 

The implementation of the UCC largely relies on a series of 17 electronic systems. 

6  

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 

11 

 
 
 
 
                                                 
  
 
Fourteen  of  those  are  trans-European  systems  to  be  developed  or  upgraded  by  the 
Commission (although with national components), while the remaining three are national 
systems to be developed or upgraded by the Member States individually.  

Overview completed and ongoing projects 

Completed projects 

Ongoing projects 

UCC Registered Exporter System (REX) 

UCC  Notification  of  Arrival 
Presentation  Notification 
Temporary Storage (TS) 

(PN) 

(NA), 
and 

UCC Customs Decisions System (CDS) 

UCC National Import Systems upgrade 

UCC Direct Trader Access to the European 
Information System (UUM&DS) 

UCC Special Procedures 

UCC  Economic  Operator  Registration  and 
Identification System Upgrade (EORI2) 

UCC Guarantee Management (GUM) 

UCC Surveillance 3 (SURV3) 

UCC Import Control System 2 (ICS2) 

UCC Binding Tariff Information (BTI) 

UCC Proof Of Union Status (POUS) 

UCC  Authorised  Economic  Operators 
upgrade (AEO) 

UCC  Centralised  Clearance  for  Import 
(CCI) 

Information  Sheets 

INFORMATION 

for  Special 
SHEETS 

UCC 
Procedures 
(INF)  

UCC  New  Computerised  Transit  System 
upgrade (NCTS)  

UCC Automated Export System (AES) 

While  tangible  progress  is  being  made  in  this  area  with,  eight  systems  already  deployed 
and operational, nine systems are still in development, in line with the planning defined in 
the UCC Work Programme. This timing is due to technical difficulties and financial costs 
for  Member  States,  in  particular  because  the  systems  are  highly  complex  and 
interconnected but also because there must be a smooth transition from existing systems to 
upgraded ones, so that the impact on trade is minimised and that controls are not disrupted. 
As  the  Commission  has  suggested  in  20187,  the  costs  of  separate  and  uncoordinated  IT 
activities  by  the  Member  States  would  have  been  very  likely  significantly  higher  than 

7  

Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the  IT  strategy  for  
customs (COM(2018) 178). 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
  
under the current  collaboration. The Commission  is  working to  ensure the completion of 
all the Union Custom Code electronic systems by 2025 and it publishes annual reports on 
progress achieved in this regard.  

2.1.4. 

UCC Import Control System upgrade – ICS2  

For goods entering the EU, one such IT system is the EU advance cargo information (the 
introduction  of  the  Import  Control  System  2  ‘ICS2’  IT  system)  whose  reform  and 
development are ongoing. The UCC has introduced new requirements in connection to the 
lodgement and treatment of pre-arrival declarations. The aim is to strengthen the safety and 
security of the supply chain (all modes of transport), EU citizens and internal market. This 
is  done  by  improving  advance  cargo  data  quality  (in  the  form  of  entry  summary 
declarations), data filing by different supply chain actors (i.e. implementing multiple filing 
requirements), real-time data availability across the multiple Member States and real-time 
collaboration  on  risk  analysis  and  sharing  related  risk  and  control  information.  This 
requires  a  complete  overhaul  of  the  EU  advance  cargo  information  system  and  regime, 
leading to a completely new IT architecture and the phasing out of existing ICS in different 
phases, as the new ICS2 comes into operation in three releases. 

The  current  Import  Control  System  (ICS)  became  operational  in  all  Member  States  in 
2011, enabling the customs  office of the Member State of first  entry to  receive the entry 
summary declaration (ENS) and use it to perform the necessary safety and security-related 
risk analysis.  

The development of ICS2 is ongoing and will be delivered in three phases or releases, as 
shown in the summary table below. 

Release 

Coverage 

(Planned) completion 

Technical 
specifications 

Conformance 
testing 

Deployment 

Release 1 

Obligation on the relevant 
EOs (postal operators and 
express carriers in air 
transport) to provide the 
minimum data (i.e. ENS 
pre-loading dataset) 

06/2018 

06/2020 

03/2021 

13 

 
 
 
 
 
 
Release 2 

Release 3 

Implementation of 
complete new ENS 
obligations and related 
business and risk 
management processes 
for all the goods in air 
traffic 

Implementation of the 
complete new ENS 
obligations and related 
business and risk 
management processes 
for all goods in maritime 
and inland waterways, 
road and rail traffic (incl. 
goods in postal 
consignments) 

06/2018 

07/2022 

03/2023 – 10/2023 

06/2018 

07/2023 

03/2024 – 10/2024 

2.2.  Objective  2:  Ensure  availability  of  supply  chain  data,  sharing  of  risk-
relevant  information  and  control  results  among  customs  authorities  to 
analyse  and  mitigate  risks,  and  ensure  equivalent  treatment  of  economic 
operators. 

Improving  data  filing  arrangements  and  ensuring  the  availability  and  sharing  of  supply 
chain  data  and  risk-relevant  information  between  customs  authorities  depends  on  the 
existence of a legal base and the development and availability of the necessary IT systems. 

2.2.1.  Modification to the legal base 

As  far  as  the  ICS2  system  is  concerned,  the  Commission  and  Member  States  have 
progressed with the necessary modifications to the legal rules of the Union Customs Code 
package. The legal provisions have been adopted by the Commission in 2020. 

2.2.2. 

Development and implementation of appropriate IT solutions  

These developments are described above under Objective 1. 

2.2.3. 

Proposed solutions for traceability of goods’ movement during 

various customs control stages 

  The Surveillance 3 System (SURV3) 

An important database is the Surveillance 3 System. The Surveillance database records and 
centralises  on  a  daily  basis  all  EU  trade  data  (imports  and  exports)  provided  by  national 
customs  authorities.  It  currently  contains  2.6  billion  records  at  transaction  level  and 
continues to be updated on a daily basis. The SURV3 system introduced an upgrade to the 
standard exchange of information in the earlier (SURV2) system to align the system with 

14 

 
 
 
 
 
UCC  requirements.  The  upgrade  implemented  electronic  data-processing  techniques  and 
established  adequate  functionalities  needed  for  processing  and  analysing  the  full 
surveillance dataset obtained from Member States.  

The project  has been implemented in  three phases. Phase 1 has been in  production since 
2 October 2017. The elaboration activities of phase 2 (the current surveillance and customs 
control  circuit  (CDC)  functionality)  and  Phase  3  (new  reports)  started  in  January  2018, 
covered by a unique software release. The system was successfully deployed on 1 October 
2018 and the data analytics capabilities have been accessible to  users since March 2020, 
allowing the Commission to use IT tools to exploit surveillance data. Currently, automated 
data  analysis  tools  are  under  development  that  allow  users  to  monitor  and  analyse  both 
transactions and trade flows. The full use and benefits of the system will be manifest when 
all  Member  States  will  submit  the  legally  defined  expanded  dataset  from  their  upgraded 
national systems.  

  The common information sharing environment (CISE)8 

In the maritime domain, the development  of a common information  sharing environment 
(CISE) is promoting the exchange of relevant information among the different authorities 
involved  (over  300  authorities  at  Member  States  and  EU  levels  performing  coast  guard 
functions). CISE is currently in a transition phase to operations, managed by the European 
Maritime  Safety  Agency  (EMSA)  in  close  cooperation  with  the  Member  States,  several 
other EU agencies (EFCA, Frontex, European Union Satellite Centre  - SatCen, European 
Defence  Agency  –  EDA) and  the  European  External  Action  Service  (EEAS).  The 
Commission  has  mandated  EMSA  to  coordinate  the  CISE  transitional  phase  for  the 
operational and technical aspects. 

CISE  is  a  voluntary  collaborative  process  across  authorities  and  borders  to  enhance  and 
promote awareness over the European maritime domain. The CISE interconnects existing 
surveillance systems and networks and provides all concerned authorities with an access to 
the  information  needed  for  their  missions  at  sea.  Thanks  to  CISE,  different  systems 
interoperate  to  easily  exchange  data  and  other  relevant  surveillance  information  through 
the use of modern technologies. 

Following the revision of the mandates of the European Border and Coast Guard Agency, 
the  European  Fisheries  Control  Agency  and  the  European  Maritime  Safety  Agency 
(EMSA),  a  tripartite  working  arrangement  was  signed.  The  agreement  sets  out  a 
framework  for  enhanced  coordination  between  the  agencies,  enabling  effective  and  cost-
efficient  support  to  more  than  300  Member  States  civilian  and  military  authorities 
responsible  for  carrying  out  coastguard  functions  in  areas  including  maritime  safety, 

8  

This group was set up based on the Decision C(2015) 2259 final, renewed by the Decision C(2018)  
5921 final. 

15 

 
 
 
                                                 
  
security, search and rescue, border control, fisheries control, customs control, general law 
enforcement and environmental protection. 

The  CISE  will  directly  support  the  cooperation  on  coast  guard  functions  by  improving 
maritime surveillance and mitigate the diverse risks that might have a negative effect the 
security of our seas and shores, such as pollution, illegal and criminal activities (including 
illegal migration), piracy and terrorism. 

  The Digital Transport and Logistics Forum (DTLF) 

The  Digital  Transport  and  Logistics  Forum  (DTLF)9  is  a  group  of  experts  led  by  the 
Commission  that  brings  together  stakeholders  from  different  transport  and  logistics 
communities,  from  both  the  private  and  the  public  sector.  It  aims  at  building  a  common 
vision  and  roadmap  for  digital  transport  and  logistics.  The  DTLF  also  contributes  to 
identifying  needs  for  measures  at  EU  level  and  supporting  their  development  and 
implementation where relevant. During its first mandate (2015–2018), the DTLF has been 
effective in developing measures to stimulate the interoperability in the digital information 
exchange in transport and logistics, and enabling collaboration across sectors, borders and 
modes of transport. 

In  the  transport  sector,  vast  amount  of  data  is  available  that  could  support  new  business 
opportunities, as well as improve the use of existing resources and the daily life of citizens. 
There are numerous potential advantages in better exploiting available data and the use of 
information and communication technologies (ICT) in transport and logistics. Among such 
benefits,  there  is  improved  security.  Through  more  and  better  data  on  the  goods,  on 
vehicles and on security controls already applied to cargo, risk assessments by authorities 
could  further  improve.  This  could  increase  the  efficiency  of  controls  and  the  overall 
security, and reduce the burden on transport service providers. 

In  April  2020,  the  Council  adopted  new  rules10,  which  will  make  it  easier  for  freight 
transport  companies  to  provide  information  to  authorities  in  digital  form.  Increased 
digitalisation  of  freight  transport  and  logistics  will  bring  significant  cost  savings  for 
businesses,  and  make  the  transport  sector  more  efficient  and  sustainable.  The  new  rules 
will  create  a  uniform  legal  framework  for  the  use  of  electronic  freight  transport 
information  for  all  modes  of  transport.  All  relevant  public  authorities  will  be  required  to 
accept  information  provided  electronically  on  certified  platforms  whenever  companies 
choose to use such a format to provide information as proof of compliance with legislative 
requirements.  However,  companies  will  still  be  able  to  present  the  information  in  paper 
format if they prefer. 

9 
10 

https://www.dtlf.eu/ 
Regulation  (EU)  2020/1056  of  the  European  Parliament  and  of  the  Council  of  15 July  2020,  
OJ L 249, 31.7.2020, p. 33–48. 

16 

 
 
 
                                                 
  
  The eManifest pilot project 

The objective of the eManifest pilot project was to test procedures that would simplify the 
submission of information required by different authorities for cargo formalities. It aims at 
facilitating  and  reducing  the  administrative  burden  for  ship  data  providers.  Through  this 
pilot  project,  a  harmonised  eManifest,  which  encompasses  data  required  in  a  number  of 
cargo-related formalities required by maritime and customs authorities, was developed and 
tested. The project also aimed at assessing whether the exchange of the eManifest data via 
SafeSeaNet could minimise reporting obligations for ships trading between EU ports and 
how ship and cargo tracking could be carried out. 

The pilot project ended in 2018. A final report was issued together with other deliverables 
such  as  data  mapping,  system  requirement  specifications  and  business  rules,  etc.  These 
deliverables  have  been  re-used  in  2019  as  a  basis  for  the  Regulation  establishing  the 
European Maritime Single Window environment.11   

A  persisting  challenge  is  the  lack  of  common  implementation  of  legislation  in  maritime 
and  customs.  However,  cooperation  between  maritime  and  customs  authorities  has 
gradually increased during the pilot project. 

  The Trade Control and Expert System (TRACES)  

TRACES12  is  the  European  Commission’s  multilingual  online  management  tool  for  all 
sanitary requirements on intra-EU trade and importation of animals, semen and embryo of 
animals,  food,  feed  and  plants.  Its  main  objective  is  to  digitalise  the  entire  certification 
process  and  linked  procedures.  It  is  in  this  respect  in  line  with  the  Digital  Agenda  for 
Europe13.  

TRACES facilitates the exchange of data, information and documents between all involved 
trading  parties  and  control  authorities  and  therefore  simplifies  and  speeds  up  the 
administrative  procedures.  The  possibility  to  trace  back  all  the  movements  of  animals, 
animal products, food and feed of non-animal origin and plants contributes to the reduction 
of  the  impact  of  disease  outbreaks  and  allows  for  a  quick  response  to  counter  certain 
serious risks along the agri-food chain. 

TRACES has more than 42 000 users from about 85 countries worldwide, is accessible 24 
hours a day, 7 days a week, free of charge and in 34 languages. 

A  new  project  initiated  by  the  Commission  is  the  development  of  an  IT  system  for 
electronic  submission  and  management  of  catch  certificates  under  Regulation  (EC) 
1005/2008  on  establishing  a  Community  system  to  prevent,  deter  and  eliminate  illegal, 

11 
12 
13 

Regulation (EU) 2019/1239, OJ L 198, 25.7.2019, p. 64–87. 
https://ec.europa.eu/food/animals/traces_en 
https://ec.europa.eu/digital-single-market/. 

17 

 
 
 
                                                 
unreported  and  unregulated  fishing.  The  project  will  assist  Member  States’  authorities  in 
carrying out their verification and risk management tasks in relation to imports of fishery 
products into EU.  

The  system  currently  runs  two  platforms:  TRACES  Classic  and  TRACES  New 
Technology (TRACES  NT), pending full  migration  from  Traces Classic  to  Traces  NT in 
2021.  

TRACES  is  interfaced  with  Member  States  national  customs  system  through  the  EU 
Customs  Single  Window  Certificates  Exchange  platform  (EU  CSW-CERTEX)  to  enable 
automated verification at customs clearance of documents stored in TRACES. EU CSW-
CERTEX  is  a  key  module  part  of  the  EU  Single  Window  Environment  for  Customs 
initiative. 

  AFIS - CSM 

A  database  of  maritime  container’s  movements  has  been  established  (AFIS-CSM),  built 
from messages of the type ‘Container Status Messages (CSMs)’, reported by sea carriers, 
as required by Regulation 515/97, amended by Regulation 2015/1525. The information is 
collected  and  processed  based  on  Regulation  (EC)  515/97  and  is  restricted  to  the 
authorised  parties  defined  by  the  Regulation.  The  cooperation  with  the  large  majority  of 
sea carriers, as well as with the major industry representative (WSC), has been good. The 
Commission has brought technical support to sea carriers in order to help them in fulfilling 
their CSM reporting obligations. 

2.3.  Objective 3: Implement the concept of ‘Assess in advance — control where 
required’ to respond adequately to identified EU and national risks while 
maximising  efficiency  in  the  use  of  resources  and  fluidity  of  the  supply 
chain 

This  objective  lies  at  the  heart  of  the  strategy,  in  the  sense  that  all  the  other  objectives 
should ultimately contribute to enabling customs to target their controls better in terms of 
when and where they take place. 

2.3.1.  Methodologies to implement the concept of ‘Assess in advance – 

control where required’ 

A first methodology is the credibility checks. Credibility checks were first introduced via 
TARIC  in  the  Member  States  national  systems  in  2013  and  are  being  continuously 
developed and expanded. They are automated checks introduced at the clearance stage of 
imports.  These  are  measures  that  check  the  compatibility  of  entries  in  the  customs 
declaration against specific parameters and, in case of noncompliance, either block them or 
flag them by creating a warning for Customs authorities.  

A  second  methodology  is  the  Systems-Based  Approach  (SBA).  The  Systems-Based 
Approach  is  a  control  methodology  directed  at  trustworthy  economic  operators,  with  the 
focus  on  whether  the  operator’s  internal  control  systems  enable  it  to  control  its  business 

18 

 
 
 
and mitigate risks related to customs compliance. The work of the SBA Network and the 
respective  project  group  was  completed  with  submission  of  the  SBA  final  report  to  the 
Customs Policy Group (CPG) in December 2017. 

2.3.2. 

Priority Control Area (PCA) 

The  Priority  Control  Area  (PCA)  instrument  is  the  key  mechanism  in  the  Customs  Risk 
Management Framework (CRMF) (see objective 4). It enables the EU to designate specific 
areas to be treated as a priority for customs controls. The identified areas are hence subject 
to reinforced customs controls carried out in a coordinated manner and based on common 
risk assessment criteria and real-time exchange of risk information. The PCA tool has been 
used  to  coordinate  EU  customs  actions  in  most  major  risk  areas  already  since  2007, 
delivering operational results and strategic lessons. While during the period 2018-2020, no 
PCA  has  been  carried  out,  intensive  cooperation  took  place  on  COVID-19  in  2020  (see 
below). In crisis times, PCAs are replaced by crisis management activities.  

2.3.3. 

Safety 

The  Commission  has  drawn  up  factsheets  setting  out  guidelines  for  the  cooperation  of 
customs and sanitary authorities for controls  on  goods regulated by EU law. For product 
safety,  checklists  for  a  selection  of  product  categories  have  been  drafted  together  with 
national  customs  and  market  surveillance  authorities.  These  checklists  are  intended  to 
guide customs officers when they have to carry out product safety controls on goods. 

The Commission has in addition set up an expert group gathering experts from the Member 
States’  customs  authorities  (the  PARCS  Expert  Group)  to  address  issues  related  to 
protection of health, cultural heritage, the environment and nature. The PARCS meetings 
are  a  key  activity  in  cooperation  and  control  of  activities  on  the  protection  of  health, 
cultural  heritage,  the  environment  and  product  safety.  It  contributes  to  the  exchange  of 
experience,  knowledge  and  best  practices  on  coordination  between  customs 
administrations  and  between  customs  administrations  and  competent  national  authorities 
responsible  for  the  different  policy  areas  at  stake.  It  also  contributes  to  developing  risk 
criteria for customs controls to be carried out in these areas.  

2.3.4. 

Financial Risks 

In  May  2018,  the  Commission  has  adopted  a Commission  implementing  decision laying 
down  measures  for  the  uniform  application  of  customs  controls  by  establishing common 
financial risk criteria and standards (FRC)14. The decision is not available to the public and 
is only available for customs risk management experts in the Member States. 

The  FRC  are  a  set  of  rules  that  allow  the  Member  States  customs  clearance  systems  to 
systematically  identify  (or  ‘flag  electronically’)  transactions  that  present  a potential 

14 

C(2018)3293 final. 

19 

 
 
 
                                                 
financial risks and that require further scrutiny and/or control actions. The FRC encompass 
the  majority  of  known  financial  risks  and  contribute  to  a  more  consistent  approach  to 
customs controls. 

The decision enables Member States to address financial risks in an equivalent manner at 
the external border, without placing an undue burden on legitimate trade. It also identifies 
the most opportune time and place of the control depending on the scope and nature of the 
risk and on the availability of data and documentation. The decision sets out the common 
risk criteria that have to be used to address specific types of financial risks, among which 
economic  operators  at  risk,  goods  at  risk,  undervaluation,  and  evasion  of  anti-dumping 
duties. FRC are used in the everyday electronic risk management process to harmonise the 
selection process for customs controls. In line with the UCC, the FRC take into account the 
proportionality of the risk, the urgency of the application of the controls and the probable 
impact on the trade flow.  

A project group on Financial Risk Criteria, financed under the Customs 2020 programme, 
has worked on the drafting of  a  guidance on the implementation  of the  FRC, which  was 
endorsed on 5 December 2019 by the Customs Expert Group, Customs Control and Risk 
Management  Section  (CEG  CRM).  The  document  describes  the  main  principles  under 
which  the  FRC  operate  and  how  they  are  to  be  integrated  into  the  risk  management  and 
control processes. It aims at ensuring a common interpretation of the FRC across the EU 
by  providing  guidance  and  specifying  elements  needed  for  a  harmonised  implementation 
of the measures set up by the FRC Implementing Decision, building up on Member States 
good practices and knowledge in addressing financial risks.  

The group now focuses on the implementation of the FRC Implementing Decision and on 
its  regular  monitoring  to  ensure  that  risk  management  can  respond  promptly  to  the 
constantly evolving financial risks. It aims at addressing specific or new concerns (e.g. e-
commerce) and filling potential gaps in the identification of financial risks.  

2.3.5. 

Intellectual Property Rights (IPR): 

In 2019, the Customs 2020 Working Group ‘Development of strategies on the framework 
of the ‘Belt and Road Initiative’ (BRI) (goods by train)’ was created aiming to examine the 
new challenges related to the impact of the BRI by which more traffic of goods (including 
IPR infringing ones) by rail from China is expected.  

The  Commission  and  five  Member  States  have  participated  in  this  working  group.  The 
working group has made a thorough assessment of the trade flow at stake and the problems 
specifically  linked  to  rail  cargo.  The  general  conclusions  are  that  rail  cargo  is  not 
substantially different from other cargo modes, the clearance procedure is comparable, as 
is  the  information  available  at  the  time  of  clearance.  Therefore,  the  working  group  has 
considered  that  further  risk  assessment  on  rail  cargo  could  be  integrated  in  the  project 
group on risk management in IPR. 

20 

 
 
 
This  latter  project  group  will  analyse  the  existing  instruments  used  in  the  context  of  the 
Common  Risk  Management  Framework  (CRMF)  and  other  sources  of  information  and 
databases  that  are  currently  available.  Its  objective  focuses  on  how  to  enhance  the 
effectiveness  and  efficiency  of  the  risk  management  as  to  come  to  a  better  targeting  of 
conspicuous consignments of IPR infringing goods in the different modes of transport and 
to  achieve  more  successful  control  results.  The  project  group  started  its  activities  in  the 
second half of 2020. 

2.3.6. 

Product safety and compliance 

A major development took place in the area of product safety and compliance, where the 
European  Parliament  and  the  Council  adopted  the  new  Regulation  2019/1020  on  market 
surveillance and compliance of products with EU legislation15. This new legislation, which 
will replace the existing provisions of Regulation (EC) No 765/2008, strengthens the legal 
framework  for  controls  on  products  entering  the  Union.  It  will  significantly  strengthen 
cooperation between customs and market surveillance authorities in view of more effective 
checks on imported products (other than foodstuffs and medicines). The Regulation aligns 
with  the  principles  of  the  Union  Customs  Code  and  provides  for  better  risk  information 
sharing through: 

-  Structural exchange of information and data between customs and market surveillance 
authorities,  facilitated  by  both  the  use  of  the  Customs  Risk  Management  System 
(CRMS) for customs common risk management and controls and the creation of a new 
digital  interface  between  national  customs  systems  and  the  EU  database  for  the 
exchange  of  market  surveillance  information  (ICSMS)  for  the  smooth  treatment  of 
customs declarations in the scope of the product safety and compliance framework;  
-  Comprehensive  national  market  surveillance  strategies  covering  import  and  digital 

supply chains; 

-  The  establishment  of  an  EU  Product  Compliance  Network,  which  will  support 

cooperation with border control authorities; 

-  Provisions  for  the  adoption  of  techniques  and  benchmarks  for  product  compliance 
checks at the Union borders on the basis of common risk analysis on the EU level; and  
-  Regular collection of statistical data on product compliance interventions at the Union 

borders.  

The new regulation on market surveillance will be fully applicable as from 16 July 2021. 
The Commission and the Member States have initiated preparations for its implementation 
and  established  several  project  groups  to  lay  the  groundwork  for  its  timely  entry  into 
application.  In  parallel,  the  cooperation  between  market  surveillance  and  customs 
authorities has been stepped up at EU level.  

15 

Regulation  (EU)  2019/1020  of  the  European  Parliament  and  of  the  Council  of  20 June  2019  on  
market  surveillance  and  compliance  of  products  and  amending  Directive  2004/42/EC  and  
Regulations (EC) No 765/2008 and (EU) No 305/2011. OJ L 169, 25.6.2019, p. 1-44. 

21 

 
 
 
                                                 
  
  
2.4.  Objective  4:  Strengthen  capacities  to  secure  equivalence  in  effective 
implementation  of  the  common  risk  management  framework  and  to 
increase responsiveness to newly identified risks 

The Common Risk  Management  Framework  (CRMF) is  the EU policy  and legal  vehicle 
for  establishing  an  equivalent  level  of  customs  controls  throughout  the  EU.  It  has  been 
created to  support a common approach so that priorities are set  effectively  and resources 
are  allocated  efficiently  with  the  aim  of  maintaining  a  proper  balance  between  customs 
controls and the facilitation of legitimate trade. 

2.4.1. 

The Common Risk criteria (CRC) 

2.4.1.1. Financial Risk Criteria 

The elements are described above in Section 2.3.4 

2.4.1.2. The  evaluation  of  the  existing  Common  Risk  Criteria  (CRC)  on 

Safety and Security  

With a view to  identifying  what  could  be possible shortcomings of the  current  CRC and 
how to improve their implementation, a Customs 2020 project group (Security Risk Rules 
project group) has been set up. Twelve Members States are represented in this group. It has 
prepared a draft detailed report per entry CRC on: 

•             Problems that hinder implementation of the CRC 

•             Problems arising from the implementation of the CRC 

•             Statistics on its efficiency 

•             Suggestions on whether to keep the CRC as it is, amend it or deactivate it. 

and 

As part of the evaluation, the Commission has prepared a detailed analysis on the number 
(with  breakdown  per  
of  automated  hits 
High  Interest  Country  (HIC)  when  relevant)  and  on  the  number  of  controls  and  positive 
results  per  CRC.  This  is  done  per  Member  State  and  at  EU  level  using  data  from  the 
quarterly  statistics  already  sent  by  the  Member  States  for  the  year  2018.  In  addition,  an 
analysis on the individual hits and the hits in combination has been performed. 

final  assessment  per  CRC 

Apart  from  the  evaluation  of  the  current  CRC,  the  group  is  exploring  the  possibility  of 
developing new CRC to address new risks that have arisen, provided they do not require an 
investment from Member States, in view of the development of ICS2, which will replace 
ICS for entry operations. 

2.4.2. 

The Customs Risk Management System (CRMS) 

The CRMS is a common database where forms and messages are stored and that Member 
States  can  consult  in  order  to  identify  which  information  needs  to  be  introduced  in  the 
national risk analysis system or communicate with each other.   

22 

 
 
 
The CRMS is used: 

-  By  all  the  Member  States,  the  UK  (until  the  end  of  the  transition  period)  as  well  as 
Switzerland  and  Norway  (through  the  security  agreement).  By  the  Commission  to 
provide Member States with risk information on any type of risks.  

-  For the daily exchange of information (via RIF, Risk Information Form). In such case, 
only  new  trends  are  mentioned.  The  CRMS  is  indeed  not  a  database  of  seizures  and 
aims  only  at  informing  on  seizures  with  new  interesting  elements  (new  targeting 
element). 

-  When a Priority control area is organised or implemented. 
-  When  a  crisis  arises  (CRMS  is  used  as  the  customs  crisis  management  system).  A 
current  example  is  the  use  of  CRMS  for  the  COVID-19  customs-related  information 
(see below). 

-  To share sensitive documents. 

Since 2005, CRMS has been regularly updated to include new functionalities or more user-
friendly elements. In particular, a COVID-19 crisis alert was opened on 4 February 2020 in 
CRMS/crisis management to allow MS sharing and receiving information and guidance on 
the prioritising of risks for customs controls during the crisis. Moreover, to date, more than 
400  RIFs  have  been  issued  concerning  dangerous  and  non-compliant  COVID-related 
medical products, medical devices and personal protective equipment.  

A  complete  reshape  of  the  system  (‘CRMS2’)  has  also  been  decided.  This  reshape  is 
detailed in two key documents: 

-  The CRMS business case endorsed at the end of 2016. It provides for the main business 
needs based on the experience of 2 years of work carried out with the Member States. 
The business case was adopted by the Member States in the CEG CRM and submitted 
for info in the ECG group (IT). 

-  The vision document endorsed in April 2018. It comprises the main IT aspects for the 

first release of CRMS2 and already foresees several additional releases.  

The elaboration phase of CRMS 2 has now been completed and the construction phase of 
CRMS2  started.  This  will  be  followed  by  a  transition  phase,  which  will  include  various 
testing. The new CRMS2 is planned to go live in Q4 2021 

2.4.3. 

Actions taken by the Member States under Objective 4 

2.4.3.1. Methodology used to collect information from Member States 

On  30 January  2020,  all  Member  States  received  a  questionnaire  asking  them  to  report 
about  the  actions  taken  to  improve  the  implementation  of  the  CRMF  in  their  respective 
country,  as  well  as  the  achievements  made  by  these  actions  so  far.  Twenty-six  Member 
States have responded to the questionnaire.  

23 

 
 
 
 
Member States were invited to consider in particular the following action areas mentioned 
in the strategy: 

  Development  of  possible  further  capacities  and  enhancing  of  cooperation  and 

coordination between customs authorities. 

  Development of further national and EU level customs threat and risk assessments 

for the full range of threats and risks. 

Member States were asked to rate the priority their customs administrations have given to 
improving the implementation of the CRMF in their countries since 2018 and to identify 
the activities and outputs / actions aimed at improving the implementation of the CRMF in 
the areas of analysis, developing capacities, and cooperation / coordination.  

Respondents  were  also  asked  to  rate  the  extent  to  which  the  actions  have  strengthened 
capacities  in  relation  to  the  implementation  of  the  CRMF  (led  to  results),  and  improved 
implementation of the CRMF and enhanced customs risk management (outcomes). Finally, 
Member  States  were  asked  whether  they  have  encountered  any  significant  challenges, 
difficulties  or  barriers  that  have  kept  them  from  implementing  desired  action  or  making 
more progress in the implementation of the CRMF. 

2.4.3.2. Customs  administrations’  level  of  priority  of  improving  CRMF’s 

implementation  

No activity 

Low priority 

Medium 
priority 

High priority 

No reply 

- 

- 

10 

16 

- 

All  twenty-six  (26)  Member  States  that  responded  to  the  questionnaire  indicated  that 
objective  4  –  improving  the  implementation  of  the  CRMF  –  is  a  priority  within  their 
customs  administrations  and  a  high  priority  for  sixteen  (16)  of  these.  The  table  below 
further indicates that all twenty-six (26) Member States are taking some action to improve 
the implementation of the CRMF. 

2.4.3.3. Status  of  actions  aimed  at  improving  the  implementation  of  the 

Action 

CRMF 

No 
planned 

action 

Analysis 

Developing 
capacities 
Cooperation 

- 

- 

/  - 

Action  planned 
but 
yet 
not 
started 
2 

1 

- 

24 

Action  ongoing 
/ completed 

No reply 

22 

24 

25 

2 

1 

1 

 
 
 
 
coordination 

2.4.3.4. Analysis 

 ‘Analysis’ is defined broadly, so that we consider it to include not only formal studies or 
evaluations  but  also  more  informal  work,  e.g.  stock-taking,  feasibility  studies,  problem 
mapping,  gap/needs  analysis,  and  evaluations  related 
to  effective  and  efficient 
implementation of the CRMF.  

The  vast  majority  of  Member  States  (22)  have  either  completed  or  are  in  the  process  of 
carrying out analysis in this area, while nearly all the remaining Member States have some 
planned.  In  many  cases,  several  initiatives  are  running  in  parallel,  some  having  been 
completed and others being currently carried out. 

The analysis  carried out differed substantially between Member States, but  generally  fell 
into four categories, namely relating to:  

1.  IT and data resources;  

2.  Internal systems;  

3.  Strategies and plans; and  

4.  Common risk criteria and the exchange of risk information.  

  IT and data resources 

Half of the responding Member States (13) reported planned, ongoing or completed work 
to analyse and develop their IT systems. These involve various IT systems and capacities. 

The most commonly reported is analysis related to the forthcoming implementation of the 
import control system 2 - ICS2. One Member State reported plans to conduct a preliminary 
analysis  in  view  of  the  changes  that  would  be  required  to  apply  to  their  current  risk 
management system in order to render it compliant with ICS2. Within the national plans, 
one  Member  State  is  currently  in  the  process  of  carrying  out  various  analyses  including 
needs assessment, gap analysis, security analysis, and legal analysis for the implementation 
of ICS2. One Member State has conducted gaps and needs analysis on a broader scale in 
relation  to  the  UCC  IT  changes,  mostly  concerning  ICS2,  the  import  system,  and  e-
commerce. One Member State explained that several national IT systems have to be set up 
new and this demands the development of advanced risk management modules using new 
risk management tools such as predictive analytics, automated validation of profiles, and 
automated real time profiling. One Member State has completed a feasibility study of the 
current state of the national risk management framework, supported by a SWOT analysis 
of possible approaches for improvement of risk management for the forthcoming ICS2 and 
subsequent  customs  procedures  in  the  supply  chain  (such  as  the  national  Import  System, 
New  Computerised  Transit  System  (NCTS),  Export  Control  System  (ECS)  –  Automated 

25 

 
 
 
 
Export System (AES)), and Technical Specifications (TS). In another Member State, there 
are plans of continuation of IT work to ensure the sustainability of the treatment of entry 
summary declarations (ENS). 

  Internal systems 

Other  works  reported  by  Member  States  to  analyse  and  develop  IT  systems  varied  in 
scope.  Examples  include  a  new  customs  clearance  system,  including  a  new  risk  engine 
with  enhanced  features;  exploring  the  use  of  artificial  intelligence  (AI)  to  support  risk 
analysis,  e.g.  on  images,  measurements  of  spectrometers,  and  signals;  a  mapping  of 
necessary IT system changes in order to improve anti-smuggling measures and monitoring; 
needs  analysis  for  the  national  electronic  portal  to  develop  a  coherent  concept  of  using 
rubber-tyred  gantry crane (RTG) scanning devices to  scan means of transport in  order to 
create a basis for building the capability to respond to irregularities in foreign trade. 

Another field where Member States have identified development needs for improved risk 
management  is  data  resources,  which  is  often  intertwined  with  improvements  to  IT 
resources.  Examples  include  ongoing  analysis  on  improvements  of  the  national  risk 
management  system,  which  is  being  complemented  with  automated  analysis  tools  and 
connected to external data sources, or improving risk scoring through a new analytical tool 
for data mining. 

  Systems, strategies and plans 

Analyses  and  assessments  of  various  systems,  strategies  and  plans  have  also  been 
relatively common.  

Examples include actions to ensure the reliability of ENS by increasing the knowledge of 
ENS,  operators’  obligations,  and  required  data  and  control  actions,  and  involves  scoping 
notes to regional offices, training actions for operational services, a full assessment of the 
difficulties encountered,  and the initiation of a sanctions policy in the  event  of breaches; 
thorough  evaluation  of  existing  risk  profiles;  national  strategies  and  action  plans  to  fight 
crime,  fraud  and  smuggling  of  tobacco  products,  dried  tobacco,  novel  products  and/or 
liquid  for  electronic  cigarettes;  annual  reviews  and  updates  of  the  risk  mitigation  plans 
related to performance indicators of external and internal risks; internal reorganisations of 
departments  related  to  risk  management  and  control  activities;  the  organisation  of 
workshops dedicated to risk management, or the revision of existing processes and the set 
up appropriate new processes for performance analysis. 

  Common risk criteria and the exchange of risk information 

Four Member States reported ongoing and completed analysis related to the common risk 
criteria (CRC) and the exchange of risk information.  They in  particular have reported on 
updated internal  procedures concerning the Customs  Risk  Management System (CRMS), 
analysis related to the implementation of the common financial risk criteria and standards 
(FRC) as well as the continuous development of new risk criteria and new risk rules to be 

26 

 
 
 
applied and to become available for data analytics and predictive analysis for customs, tax, 
and company registry data. 

  Other activities 

Member States also referred to activities in analysing the movement of tobacco products to 
detect  irregularities,  non-compliance  and  VAT  fraud.  They  also  referred  to  their 
participation  in  the  Horizon  2020  PROFILE  and  PEN-CP  (Pan-European  Network  of 
Customs Practitioners) research projects. PROFILE relates to the uptake of data analytics 
by  customs and sharing  of results  between participating  countries.  Its  focus is  mainly on 
value  analysis  for  e-commerce,  and  operator  profiling  for  import  declarations  and  ENS. 
PEN-CP  targets  building  communities  of  experts  in  risk  management,  detection 
technologies, and laboratory equipment, to better focus innovation efforts and exchange of 
best practices.  

In  addition,  Member  States  have  mentioned  the  role  of  the  Structural  Reform  Support 
Program  (SRSP)  on  e-commerce,  for  which  they  are  mapping  best  practices  by  other 
customs  in  the  EU  and  third  countries  to  tackle  the  specific  problems  related  to  e-
commerce, including risk analysis, IT systems, and fight against fraud. This includes study 
visits to other Member States to exchange on expertise and experiences. 

Some Member States also provided a more general answer for analysis related to effective 
and  efficient  implementation  of  the  CRMF.  For  instance,  the  informal  evaluation  of 
effectiveness  and  analysis  of  problems  and  gaps  in  relation  to  the  implementation  of  the 
CRMF. 

One Member State’s authorities underlined that their primary focus in the risk management 
area is the improvement of performance and outcome rather than direct actions to support 
individual aspects of the CRMF.  

2.4.3.5. Developing capacities 

‘Developing capacities’ is here defined as any action taken to support capacities related to 
the  effective  and  efficient  implementation  of  the  CRMF,  including  implementing  IT 
solutions, supporting risk management of the supply chain,  and efforts to better integrate 
the CRC and/or Priority Control Areas (PCAs) into the national risk management system.  

There  are  a  considerable  number  of  planned,  ongoing  and  completed  actions  to  support 
capacities  related  to  the  effective  and  efficient  implementation  of  the  CRMF.  Actions 
reported mainly related to developing new or improving existing national risk management 
IT  systems  including  efforts  to  better  integrate  the  CRC  and  FRC  as  well  as  linking 
national  systems  to  the  CRMS  for  sharing  of  Risk  Information  Forms  (RIFs).  Several 
customs authorities also reported preparations for implementation of the ICS2 system. 

  Improving national risk management systems / engines 

27 

 
 
 
Fourteen  MS  specifically  reported  improved  or  continuously  developed  national  risk 
management systems. For instance, a new customs clearance system is being implemented 
in one Member State and will include a new risk engine with enhanced features. This will 
allow efficient risk management in different domains. The main areas of interest are import 
(including  import  declarations  for  low-value  consignments),  ICS2,  export,  NCTS, 
temporary  storage,  and  goods  accounting.  In  order  to  strengthen  the  risk  analysis  and 
control process, new working methods with adopted IT-functions have been conceived and 
are going to be implemented in the future system. 

Another Member State is currently in the final stages of the development of a new national 
import system for customs, scheduled to go live in November 2020. This will incorporate a 
new  electronic  risk  management  system,  which  will  provide  better-quality  risk  profiling 
and reporting functions. 

One  Member  State  reported  on  the  implementation  of  new  features  to  their  risk  engine. 
The new features include operator profiling and behaviour analysis and a large number of 
statistical enrichments. Additional work is ongoing to enable the system to incorporate all 
types  of  declarations  and  messages  including  NCTS,  e-commerce  declarations,  arrival 
notifications (AN), presentation notifications (PN), and temporary storage (TS). 

Actions are also ongoing to implement IT solutions in the national systems for safety and 
security analysis, e.g. for increasing the capacity of analytical tools to process more data as 
well as improving quality of data and reporting. To better identify offenders and improving 
the  quality  of  data  for  risk  analysis,  interconnections  between  databases  are  carried  out. 
One example is the implementation of postal parcels analysis in the national risk profiling 
system as well as making improvements to the national risk profiling system and other IT 
systems to strengthen anti-smuggling measures. Another example is the enhancing of risk 
management  systems  to  enable  users  to  connect  and  search  a  variety  of  data  sources  to 
which  they  have  authorised  access  and  bring  those  results  directly  into  intelligence 
analysis.  Implementing  such  analysis  through  advanced  tools  would  help  customs 
authorities to uncover hidden connections and thus gain actionable intelligence to combat 
illicit trade and mitigate risk. As a result, this will support risk management and reinforce 
efforts to better integrate risk criteria.  

Actions also take place in some Member States to connect all supply chain data and enable 
automatic  and  instant  consideration  of  the  results  of  risk  analysis  and  controls.  One 
Member  State  has  reported  on  several  actions  related  to  the  CRMF,  with  an  interface 
between the risk assessment and control system and the Schengen and  Interpol databases 
for  automated  comparisons  of  vehicle  plate  numbers  and  vehicle  identification  numbers 
(VINs),  indicated  in  import,  export  and  transit  declarations  and  to  cover  ICS2  related 
national  functionalities.  Further,  the  interface  between  this  system  and  X-ray  control 
systems  used  by  the  customs  authorities  was  implemented,  enabling  the  linking  of  risk 
management  results  with  X-ray  control  results.  The  system  is  further  being  improved  to 
enable  automated  risk  assessment  of  persons’  declarations,  the  function  to  use  customs 
clearance  data  in  mobile  devices  and  the  function  to  link  to  external  data  sources.  In the 

28 

 
 
 
same  vein,  one  Member  State  is  supporting  RTG  operators  by  developing  a  system  for 
automatically identifying threats in X-ray images in controlled means of transport. The aim 
is to develop an internet application based on AI. The same Member State is implementing 
a modern IT tool for handling applications from the National Revenue Administration for 
international administrative assistance in customs matters. 

Several  (thirteen)  Member  States  further  reported  ongoing  or  planned  efforts  to  better 
integrate the CRC and FRC into their national IT systems. 

  Preparations for ICS2 

As  part  of  ICS2,  each  Member  State  will  have  to  develop  and  implement  a  national 
interface  with  the  ICS2  common  repository  -  National  entry  system  (NES)  supporting 
necessary  risk  analysis  processes,  process  of  arrival,  presentation  and  exchanges  of  risk 
analysis and control results with the common repository.  

Many (11) Member States reported that they were preparing for the new ICS2 system and 
development of the NES. For instance, alongside ongoing work on the EU level as regards 
to  the  legal  basis  of  ICS2  information  exchange,  one  authority  is  preparing  the 
incorporation  of  the  business-wise  and  technical  specifications  related  to  ICS2  into  the 
national domain and building a risk engine with flexible CRC implementation to cover the 
entire range of security risk analysis (pre-loading and pre-arrival) as well as the different 
responsibilities in the process (first point of entry and subsequent point of entry).  

In another Member State, they are providing advisory support for the development of the 
necessary  systems  in  view  of  the  implementation  of  ICS2  through  meetings  with 
representatives from postal services and the couriers.  

Other  Member  States  referred  to  participating  in  meetings  of  the  Customs  Eastern  and 
South-Eastern  Land  Border  Expert  Team  (CELBET)  Analytics  Subgroup,  which  is 
responsible for development and implementation of analytic tools (CAToolbox) to support 
ICS2. 

  Measures to tackle undervaluation fraud 

Five Member States reported specific measures to mitigate fraud related to under-reporting 
the  customs  value  of  imported  goods.  For  example,  one  Member  State  reported  the 
analysis  of  profiles  and  control  results  on  undervaluation  of  certain  products.  Another 
Member State reported they have modified and extended their system in the field of import 
of textiles from specific countries. 

  Other measures 

In  relation  to  the  logistics  chain,  one  Member  State’s  customs  are  doing  ENS  risk 
management  improvements  to  routines  in  different  areas  to  optimise  risk  management, 

29 

 
 
 
 
areas  including  restrictions,  suspensions,  incorrect  ENS,  and  duplicated  ENS  due  to 
modifications.  Various technical  developments  have been made to  ensure the traceability 
of  the  results  of  risk  management  and  control  proposed  in  ENS  to  the  customs  pre-
declarations.  Techniques  are  being  explored  in  the  use  of  data  mining  to  select  and 
combine  customs  and  tax  information  from  the  system  to  facilitate  risk  management  of 
both ENS and customs declarations.  

One Member State has further developed several analyses  and technical  developments  to 
implement  the  reduction  of  controls  for  EU  Authorised  Economic  Operators  (AEOs), 
including Economic Operators Registration and Identification number (EORI) and customs 
decisions, and the third country AEOs with which there is a mutual recognition agreement. 

Another  Member  State  reported  that  it  will  develop  the  interface  of  core  declaration 
systems  including  the  national  import  system,  the  Automated  Export  System  (AES)  and 
the NCTS including a risk analysis module in  order to  fulfil the obligations arising from 
the legal requirements of the Union Customs Code (UCC) and Multi-Annual Strategic Plan 
(MASP).  Already  completed  actions  include  training  for  risk  analysis  officers  and  a 
workshop on risk analysis for risk and control experts from all regional customs offices. 

Another Member State is finalising a programme to restructure and rearrange the workflow 
of customs national risk analysis procedures. They also reported ongoing preparatory work 
to embrace the revocation of the 22-euro threshold referring to the submission of customs 
declarations through adapting existing procedures to the upcoming situation, both tackling 
the increasing number of declarations and the related business risks. 

One Member State reported that it is  recruiting data analysts to  improve its  risk analysis 
capacity.  In  relation  to  supporting  risk  management  of  the  supply  chain,  the  customs 
authorities  of  the  Member  State  have  participated  in  tools  together  with  commercial 
partners.  They  have  developed  a  dashboard  that  shows  additional  data  from  external 
sources  and  is  used  in  the  risk  assessment  of  manual  declarations.  External  sources  are 
companies that want to make data available for inspection by the supervisory authorities or 
public sources. Their customs also participated in a project, in which one of the working 
packages focused on a port and included: integrating logistics and security requirements in 
the  supply  chain  design  and  planning  phase;  demonstrating  the  benefits  of  coordinated 
border management and taking advantage of commercial controls; improving supply chain 
visibility  for  supervision  in  trade  lanes  with  multiple  border  crossings  and  intentional 
vagueness  to  conceal  criminal  activities.  In  addition,  this  Member  State  will  be 
strengthening the intelligence function in  the passenger traffic by  getting  access  to  travel 
information via a government-wide single window to which airlines supply data once. This 
provides  more  opportunities  for  analysis  and  contributes  to  the  development  of  a  single 
window. 

One  Member  State  reported  ongoing  work  related  to  customs  technical  equipment.  One 
project  involving  centralised  scanning  (centralised  X-ray  scanner  image  analysis  and 
interpretation during customs control process). Another project involves video surveillance 

30 

 
 
 
system installation at customs control points. In addition to technical equipment, they are 
establishing  a Single Customs Control Support  Centre to  ensure implementation  of more 
efficient control measures. 

In another Member State, changes in the legislation have been made, allowing the customs 
administration to become a competent authority in relation to the use of Passenger Name 
Record  (PNR)  data.  The  changes  came  into  force  in  July  2020.  Similarly,  in  another 
Member  State,  they  have  created  a  passenger  information  unit  (PIU),  where  the  customs 
administration  has  a  seconded  customs  officer  deployed  working  in  the  area  of  risk 
analysis for PNR. 

2.4.3.6. Cooperation / coordination 

‘Cooperation  /  coordination’  is  defined  as  action  taken  to  enhance  cooperation  with 
customs  authorities  in  other  Member  States  and  increase  sharing  of  information  or  risk 
analysis  results,  e.g.  through  participation  in  relevant  collaboration  forums,  and  bilateral 
cooperation / coordination with other Member States. 

Nearly all Member States (25) providing responses reported ongoing or completed actions 
taken  to  enhance  cooperation  with  customs  authorities  in  other  Member  States  and  to 
increase sharing of information or risk analysis results. Such actions included exchanging 
information  through  specific  tools  such  as  the  CRMS,  participation  in  relevant 
collaboration  forums,  project  groups,  hosting  and  taking  part  in  seminars  and  workshops 
and other bilateral  and  multilateral  cooperation  between Member  States. Not all Member 
States provided exhaustive lists of activities, such as groups they are involved in, though 
responses suggest that Member States are active in a number of relevant risk forums and 
that  bi-  and  multilateral  cooperation  and  coordination  between  Member  States  is 
continuous. 

  Use of tools for the exchange of customs information 

Member  States  specifically  stated  in  their  replies  that  they  are  using  the  CRMS  for 
exchange  of  risk  information  with  other  Member  States.  For  instance,  one  customs 
authority reported they evaluate and feedback RIFs in CRMS from other Member States on 
a daily basis as well as  create RIFs in order to share relevant risk information with other 
Member States.  

Other tools for information sharing were also noted: 

-  OLAF’s Anti-Fraud Information System (AFIS), notably on Customs Procedure 42 

and excise data 

-  The  Common  Communication  Network  (CCN)  for  exchange  of  information  on 

Customs Procedures 42 and 63 

-  The Surveillance 3 VAT module application for the exchange of customs data for 
Customs  Procedure  42  between  customs  and  tax  administrations  (following  the 
amendment of Regulation 904/2010) 

31 

 
 
 
-  COPIS,  the  EU-wide  anti-Counterfeit  and  anti-Piracy  Information  System,  to 

register counterfeit dossiers 

-  Bayplan/stowage plan occupied and empty locations  message (BAPLIE) to  verify 
the accuracy of data declared in ENS in relation to the containers declared in ICS. 

  Collaboration forums and project groups 

Nearly all Member States participate in one or more contact groups established under the 
Customs  programme  to  increase  the  practical  level  of  cooperation  and  coordination 
between  customs  administrations  at  the  external  frontier  of  the  EU  –  the  European  Land 
Frontier  (Land  Frontier  Contact  Group  (LFCG)),  Ports  and  Airports  contact  groups 
(RALFH, ODYSSUD, ICARUS).  

The LFCG represents all 16 MS with external land borders, whereas not all EU ports and 
airports  are  represented  in  the  respective  groups.    There  are  also  specific  contact  groups 
and subgroups on sniffer dogs, rummage, rail and scanning.  

The objective of these groups is to promote the operational cooperation and coordination 
between  customs  authorisations  with  regard  to  efficient  customs  controls  at  external 
borders and to exchange valuable information to make customs controls on movement of 
various means of transport more efficient. The groups create a network between customs 
officers  working  in  a  specific  traffic  (air,  road,  rail,  sea)  or  specific  field  (scanning, 
rummage,  sniffer  dog).  The  groups  function  also  as  a  network  of  contacts,  with  customs 
helping each other to answer ad hoc questions. 

All groups collect data on resources, traffic and threats (through mapping or comparison) 
which  provides  information  to  the  strategic  management  of  the  national  customs 
administrations  to  use  and  decide  priorities  and  allows  moving  towards  a  more  uniform 
performance at the external borders. Other customs project and expert groups, such as the 
scanner contact  group of Northern and Southern  ports, the Canine Unit  Network and the 
Customs Eastern and South-Eastern Land Border Expert Team (CELBET) use in the scope 
of their activities some of the raw data. 

Several Member States further participate in the Customs Eastern and South-Eastern land 
Border  Expert  Team  CELBET,  which  is  an  initiative  of  eleven  (11)  Member  States 
including  Finland,  Estonia,  Latvia,  Lithuania,  Poland,  Hungary,  Slovakia,  Croatia, 
Romania, Bulgaria and Greece under the Customs 2020 programme. The main objective of 
this  expert  team  is  to  strengthen  and  improve  the  operational  cooperation.    Although 
CELBET is not a legal entity, this expert team coordinates operations, shares information 
and  pools  human  resources  to  enhance  operational  cooperation  –  contributing  to  the 
implementation of common customs legislation and policy. 

The Data Mining Project Group (DMPG) is a Customs 2020 group with the main purpose 
to fight against customs fraud and protect the financial interest of the Member States and 
Commission.  The  group  works  by  gathering  and  sharing  data.  The  group  works  to 
strengthen cooperation. The project group has three main objectives: (i) Gather the list of 

32 

 
 
 
risky  items  for  deeper  analysis  within  the  group,  (ii)  Develop  new  risk  profiles  by 
analysing  the  total  dataset  and  (iii)  Apply  international  practices  by  sharing  standards 
between members. 

Other participation in forums mentioned by Member States included: 

 

INTEL4CUSTAF, an analysis pilot project / expert group run by OLAF and financed 
by HERCULE III programme with the participation of the majority of Member States,  

  MAR-INFO,  a  group  of  partners  from  Northern  and  Southern  regions  (with  the 
participation  of  the  majority  of  Member  States  from  the  Mediterranean  zone  and 
Northern  Europe)  cooperating  and  exchanging  information  to  prevent  smuggle  of 
drugs,  drugs  precursors,  high  tax  goods  (cigarettes,  tobacco  and  alcohol)  and  goods 
related to terrorism and organised crime in the maritime area.  

  Europol’s  European  Multidisciplinary  Platform  against  Criminal  Threats  (EMPACT) 
operational  action  plans  (OAPs).  In  this  context,  one  Member  State  reported  the 
posting of a liaison at Europol to enable smooth cooperation and information exchange. 

  Seminars and workshops of the Customs 2020 programme 

Several  Member  States  reported  taking  part  in  seminars  and  workshops  organised  under 
the Customs 2020 programme.  

For example, the authorities of one Member State have hosted visits from several other MS 
and some third countries to demonstrate their risk engine and datamining capabilities. They 
are  continually  receiving  requests  for  these  visits  and  were  planning  additional.  Three 
Member  States  had  a  common  workshop  in  February  2020  tackling  the  threat  from 
smuggling  of  cigarettes,  counterfeit  tobacco  packaging  and  tobacco  products  by  parcel 
post.  One  customs  authority  stated  they  regularly  take  part  and  host  meetings  and 
workshops with other MS. On the operational level, the authorities have established active 
working  contacts  with  other  MS  risk  analysis  units  and  also  regularly  organise  and  take 
part in work meetings and site visits in other MS. Another customs authority reported they 
attended several OLAF workshops in the area of customs data analysis, and participated in 
CRMS RIF training. A regular national seminar was organised in another Member State on 
international  administrative  assistance  in  customs  matters.  The  topics  of  the  seminar 
included legal and practical aspects of preparing requests for administrative assistance and 
rules  for  the  implementation  of  requests  received  from  foreign  customs  administrations. 
Assessment  of  the  risks  for  the  effective  implementation  of  controls  in  cases  where  it  is 
necessary to use international administrative assistance was carried out.  

  Bilateral  and  multilateral  cooperation  /  coordination  with  other 

Member States 

Several authorities noted bilateral and multilateral cooperation and coordination with other 
Member  States.  The  activities  mentioned  include  a  bilateral  agreement  between  two 

33 

 
 
 
Member  States  related  to  risk  analysis  of  ENS  data,  cooperation  between  two  or  more 
other  Member  States  in  the  area  of  undervaluation,  operational  and  financial  mutual 
assistance  activities  are  in  several  areas  including  in  the  field  of  undervaluation  and 
Regulation 515/1997. Another Member State referred to cooperation centres for Customs, 
Police  and  Border  Guards  on  the  borders  to  neighbouring  Member  States.  Activities 
involve identification and counteracting threats arising from the movement of persons and 
goods  (e.g.  fuel,  tobacco  products,  narcotics,  alcohol,  and  other  goods  subject  to 
restrictions).  The  centres  also  exchange  information  on  cross-border  crime,  customs  and 
tax  inspections,  fiscal  criminal  proceedings,  and  persons,  as  well  as  results  of  RTG 
inspections and data from automatic number plate recognition systems. 

Further  bilateral  and  multilateral  cooperation  included  collaboration,  exchange  of  risk 
information  and  exchange  of  best  practices  between  neighbouring  countries  as  well  as 
Naples II Convention, and participation in Joint Customs Operations (JCOs). 

2.4.3.7. Results – strengthened capacities  

Extent  to  which  above  actions  have  strengthened  capacities  in  relation  to  the 
implementation of the CRMF 

Not at all 

- 

To  a 
extent 

- 

limited 

To some extent  To 

a 

great 

No reply 

14 

extent 

11 

1 

Nearly  all  Member  States  (25)  indicated  that  the  actions  taken  to  improve  the 
implementation  of  the  CRMF  have  resulted  in  strengthened  capacities,  eleven  (11)  to  a 
great  extent and fourteen (14) to  some extent. Several  Member States  reported improved 
national risk analysis processes as described below. Actions have clearly been effective, in 
particular actions related to increasing capacities within administrations such as IT systems 
and their capabilities, and sharing of risk information between Member States. 

  Higher  quality  /  more  comprehensive  /  efficient  /  timelier 

national customs threat and risk assessments.  

One Member State reported that constant revision and upgrade of the national IT systems 
that are instrumental in processing and distributing risk information to the relevant entities 
within  the  customs  administration  have  undoubtedly  strengthened  the  risk  management 
capabilities.  

One  customs’  investments  in  risk  management  innovation  have  provided  better 
understanding of logistical flows and emerging risks and novel techniques such as artificial 
intelligence (AI) help to determine risks on incoming goods.  

34 

 
 
 
 
One Member State reported that international  working  groups have provided information 
and understanding for developing risk management, which has improved the quality of risk 
management.  The  organisation  is  better  prepared  for  the  rapidly  changing  operational 
environment and their capability to react to new emerging threats has increased.  

One administration provided a comprehensive list of the results achieved, including actions 
against undervaluation. Declaration of postal consignments have made it possible to carry 
out control measures for small-value consignments. AI and automation of processes have 
allowed automated information analysis. The establishment of the Single Customs Control 
Support  Centre  has  ensured  more  efficient  and  more  complete  use  of  the  available 
information systems and technical resources. Finally, the installation of video surveillance 
system at customs control points has increased efficiency of customs and border controls, 
ensuring protection of the national economic border.  

Another  Member  State  reported  that  activities  of  the  RALFH  group  are  used  to  improve 
control  and  operational  procedures  in  seaports,  thus  positively  affecting  the  quality  of 
operations carried out by customs officers. Jointly implemented RALFH  projects increase 
the efficiency of controls carried out by means of risk analysis (targeting) and enable the 
detection of e.g. weak points in the goods flow system. 

  Better  risk  management  thanks  to  more  consistent  /  effective 
sharing  and  deployment  of  national  customs  threat  and  risk 
assessments in the CRMF.  

One  Member  State  reported  increased  awareness  of  financial  and  other  risks  through 
CRMS information  sharing. One Member State’s authorities have experienced better  and 
more effective risk management and targeting activities as a result of EU-wide cooperation 
and information  sharing, which have contributed to  raising awareness  of new threats  and 
thereby  the  creation  of  new  national  risk  profiles,  better  risk  assessment  through  fine-
tuning  risk  profiles  already  in  place,  and  controls  planning  including  better  resource 
allocation. Another authority reported that the availability of data allows for more effective 
evaluation  of  risk  mitigation  measures.  All  available  risk  information  (national  and 
international) has been collected in  a single information  system with  flexible data search 
and  selection.  In  addition,  customs  controls  are  carried  out  based  on  the  information 
obtained  from  a  single  data  exchange  network  of  X-ray  control  systems  used  by  the 
customs authorities. One Member State reported that seizures data they receive from some 
other  EU  partners  contains  information,  which  is  very  useful  for  the  national  analytical 
models  and allows for a more precise targeting.  One Member State’s customs noted that 
frequent and timely exchange of risk information and data between Member States, other 
competent authorities and the Commission enables a more efficient and selective selection 
of risk shipments and provides necessary assistance in national threat and risk assessment. 
Another  Member  State  reported  a  bilateral  cooperation  project  with  a  neighbouring 
Member  State  related  to  ENS  declarations.  This  has  served  to  ensure  the  use  of  relevant 
information  from  both  Member  States  in  the  analysis  of  ENS  declarations,  regardless  of 
where the goods are presented, thereby closing gaps that could previously been exploited 

35 

 
 
 
by  illicit  traders.  The  authorities  of  one  Member  State  reported  that  the  activities  of  the 
cooperation centres for customs, police and border guards on the borders have contributed 
to effective controls of illegal cross-border movements of excise goods and other goods, to 
direct  and  quick  exchange  of  information  with  law  enforcement  authorities  allowing 
criminals  and  migrants  to  be  stopped  and  detained,  to  revealing  VAT  fraud  abuse 
(extortion)  i.e.  forgery  of  customs  signatures  and  seals  on  tax  free  documents,  to  the 
disclosure of the use of false vehicle registration numbers, and to uncovering uncompleted 
procedures for export of goods from the EU. 

2.4.3.8. Outcomes  

Extent to which the actions described above have improved implementation of the CRMF 
and enhanced customs risk management 

Not at all 

- 

To  a 
extent 

2 

limited 

To some extent  To 

a 

great 

No reply 

13 

extent 

10 

1 

Respondents  were  asked  to  which  extent  the  implementation  of  the  CRMF  and  customs 
risk management have improved the implementation of the CRMS and enhanced customs 
risk management, and to describe the progress made.  

Ten  Member  States  agreed  that  the  actions  related  to  objective  4  have  improved 
implementation  of  the  CRMF  and  enhanced  customs  risk  management  to  a  great  extent, 
and thirteen (13) Member States agreed to some extent. 

including 

Progress reported mainly related to increased cooperation and sharing of risk  information 
between  Member  States 
through  CRMS,  and  enhanced  financial  risk 
management  –  these  are  key  parts  of  the  CRMF  and  therefore  this  shows  the  significant 
progress  made  by  Member  States  to  implement  it.  Several  Member  States  also  reported 
enhanced risk analysis through new or improved IT systems and recruitment or training of 
staff. 

  Enhanced cooperation and sharing of risk information.  

Four (4) Member States specifically highlighted enhanced cooperation with other Member 
States.  For  example,  one  of  them  stated  that  the  participation  in  ODYSSUD  group 
meetings has helped to increase the level of cooperation and coordination. The exchange of 
information and the sharing of best practices between the major southern ports (member of 
the ODYSSUD group) help to ensure the equivalent level of control and trade facilitation 
for legitimate trade.  

36 

 
 
 
 
Two (2) other Member States pointed to better information sharing and common approach 
to undervaluation issues leading from cooperation with neighbours and with EU Member 
States. 

One  Member  State  highlighted  that  the  use  of  CRMS  RIFs  has  strengthened  the 
implementation of CRMF to a great extent, broadening the scope of risk areas, including 
regular updates of risks and the picture of risks in other Member States, leading to better 
and  more  effective  risk  management.  One  Member  State  reported  that  risk  information 
exchanged through CRMS is exploited to a great extent by creating national risk profiles 
responding to newly identified threats and risks. Another Member State reported progress 
including  evaluation  of  information  shared  via  CRMS  RIFs,  periodic  assessment  of 
national risk profiles based on CRC, and control campaigns (PCA and JCOs) which have 
improved  the  implementation  of  the  CRMF.  One  Member  State  stated  that  all  received 
RIFs through CRMS are transmitted to  the national  register for risk analysis,  where they 
are evaluated and analysed, appropriate measures are implemented to  minimise risks and 
provide feedback on the RIFs through CRMS. They also regularly evaluate and analyse all 
relevant risk information from other available national and international sources and in the 
event of a risk transmits it to CRMS. 

Another example provided by a Member State listed the outcomes of the cooperation in the 
border  centres.  It  includes  more  effective  risk  analysis  in  the  selection  of  vehicles  for 
inspection  during  fuel  transports,  disclosures  of  false  exports,  disclosures  of  VAT  fraud, 
more  effective  supervision  and  control  over  the  movement  of  means  of  transports  and 
goods and disclosure of irregularities, as well as increasing the level of correct application 
of customs procedures, collecting due duties, increasing the ability to  respond to tax free 
irregularities,  identifying  and  limiting  the  activities  of  criminal  environments  and 
uncontrolled movement of people. 

  Enhanced financial risk management.  

Eight (8) countries reported progress in relation to improved handling of financial threats 
and  risks.  For  example,  one  Member  State  reported  that  it  used  the  EU  Automated 
Monitoring  Tool  (AMT/THESEUS)  system.  This  system  is  developed  by  the  Joint 
Research Centre  (JRC) of the European Commission  and is  used by Customs in  the EU, 
OLAF and OLAF’s partners in the EU Member States. The AMT calculates estimates of 
baseline  prices  for  goods  imported  in  the  EU,  for  each  combination  of  product,  third 
country  origin  and Member State destination.  It  also  generates automated alerts  for price 
outliers in trade data.  

One  Member  State  reported  developing  risk  profiles  for  specific  headings  and  importers 
and enhancing customs  controls  as a result. Because of this measure, undervaluation  and 
the activity of EOs initiating undervaluation have been significantly reduced.  

37 

 
 
 
Six (6) Member States finally pointed to the implementation of FRC and the usefulness of 
the rules in supporting a common methodology and method of conducting risk analysis at 
the EU level. 

  Better  risk  analysis  through 

implemented 

/ 

improved  IT 

solutions.  

A  Member  State  reported  that  all  implemented  IT  solutions  at  national  level  have  led  to 
improvements  of  risk  management  processes  and  analysis.  The  advanced  IT  systems 
contribute  to  the  timely  assessment  of  threats  and  risk.  The  new  IT  tool  enables  better 
scoring of import customs declarations, better reporting and provides statistical overviews 
for further strategic decisions.  

In another Member State, the greatest progress has been achieved by the introduction of an 
electronic system of risk analysis for low-value shipment in express couriers at air traffic, 
which enables more efficient risk management in terms of easier identification of risk for 
different risk areas.  

In another Member State, the implementation of the new functions of the risk engine used 
since mid-2018 has led to more risk-oriented selections of declarations.  

In  another  Member  State,  improvements  in  the  national  risk  management  system  were 
introduced  in  order  to  provide  better  information  feed  to  risk  analysts  while  making 
decision  on  control  measures.  In  2018,  new  versions  of  the  NCTS  and  ICS  national 
systems were commissioned, where IT solutions implemented allow for better follow-up of 
control decisions and actions taken. Solutions were also implemented in order to deal with 
the multiple declarations submission phenomenon, which also supported the performance 
of related CRCs. 

  Better risk analysis through recruitment and training of customs 

officers. 

One Member State’s customs reported progress  in  terms  of ramping up risk analysis and 
the targeting service created in 2016 in the risk analysis process, in particular through the 
recruitment of several data miners.  

Another  Member  State  reported  they  have  created  a  more  structured  picture  of  risks  and 
clear  common  guidance  on  how  to  address  risks  and  continued  advanced  training  for 
customs officers on how to identify and target risks.  

A third Member State stated that data analysts enable them to better target large quantities 
of data or use new techniques to enhance the performance of their risk engine by using new 
algorithms. 

38 

 
 
 
2.4.3.9. Encountered challenges, difficulties and barriers 

Have you encountered any significant challenges, difficulties or barriers that have kept you 
from  implementing desired action or making more progress  in  the implementation  of the 
CRMF? 

Yes 

14 

No 

10 

No reply 

2 

Ten  (10)  Member  States  customs  administrations  have  not  encountered  any  significant 
challenges,  difficulties  or  barriers  in  implementing  the  CRMF.  However,  fourteen  (14) 
Member  States  reported  some  barriers  that  have  kept  them  from  implementing  desired 
action  or  making  more  progress.  The  identified  barriers  are  similar  and  can  generally  be 
grouped  by  insufficient  IT  infrastructure,  financial  constraints,  lacking  human 
resources, and data availability i.e. deficient sharing of risk information between MS. 

Budgetary  constraints  were  reported  by  five  (5)  Member  States,  which  for  two  are 
specifically related to development of IT infrastructure.  

Similarly, another barrier to the effective implementation of the CRMF at the national level 
is insufficient IT infrastructure. For instance, one Member State pointed to the increasing 
complexity of some of the EU strategies and tools to challenge individual risks, e.g. FRC, 
which can be a challenge in terms of operationalisation within existing national electronic 
systems. Another Member State reported lacking infrastructure for the use of AI to support 
risk analysis. While another one further mentioned the long-term IT development, taking 
place throughout the entire Customs Union in line with the UCC demand for harmonised 
electronic customs processes. Two Member States reported that current IT systems simply 
do not yet fully support all their needs. 

Lack  of  human  resources  and/or  expertise  as  a  barrier  to  implementing  the  CRMF  was 
reported  by  seven  (7)  Member  States.  For  example,  one  Member  State  reported  that 
increasingly  limited  human  resources  in  combination  with  the  need  to  recruit  new 
personnel  with  specific  data  analytics  skills  prevent  properly  addressing  new  challenges 
arising  from  the  tremendous  increase  in  e-commerce  related  goods  movements.  The 
consequent  ‘data  explosion’,  never  seen  before,  must  be  addressed  with  new  knowledge, 
tools  and  techniques  currently  not  widespread.  Another  Member  State  stated  that 
organisational restructuring and staff training have not been sufficient to address deficient 
capacities  (hiring  practically  froze  due  to  the  recent  financial  crisis  and  recent 
organisational  restructuring  did  not  take  under  consideration  the  increased  needs  in  risk 
management staff). While in another Member State, there are limited human recourses and 
limited  expertise  due  to  the  small  size  of  the  department  and  many  responsibilities  of 
customs  officers  at  the  same  time.  A  Member  State  referred  to  the  significant  human 
resource burden that appropriate action in case of suspected undervaluation involve. 

39 

 
 
 
 
Five  (5)  Member  States  referred  to  problems  relating  to  sharing  of  risk  information 
between Member States. The administration of one Member State explained that normally 
more  than  one  Member  State  is  affected  by  the  same  Organised  Crime  Group  (OCG), 
therefore risk management  needs to  establish a comprehensive approach  to  link financial 
and  non-financial  risk  assessment  between  the  Member  States.  This  demands  closer 
cooperation  and  information  exchange  between  all  involved  agencies  in  the  concerned 
Member States. According to this administration, it is still a big problem to get information 
and data from other Member States for analysis purposes because of lacking legal basis for 
the exchange of data. In addition, Member States do not use the EU legal framework for 
cooperation and information in a harmonised manner.  

One  Member  State  further  noted  that  uniform  access  to  customs  data  in  the  EU  would 
enable a more uniform and effective implementation of analysis and information exchange 
at  EU  level.  Another  Member  State  pointed  out  that  information  and  data  sharing  is  the 
core  principle  of  EU  cooperation  under  CRMF  and  that  General  Data  Protection 
Regulation (GDPR) created a big legal barrier against this core principle. While a Member 
State expressed difficulties in dealing with the uncertainties related to data exchanges and 
the  conditions  behind  it,  they  stated  that  although  Article 46  UCC  and  the  Naples  2 
Convention  are  clear  on  the  use  cases,  the  liability  with  regard  to  personal  data  tends  to 
slow down all requests related to data or information exchange. 

In addition to the barriers reported above, one Member State further reported the problem 
of multi-reporting of the same information via different tools / applications (AFIS, mutual 
assistance  (AM)  communication,  RIFs,  information  in  paper  form).  The  administration 
suggested that clarifications and concrete rules should be established and binding for EU 
Member States customs and EU institutions.  

According to  one Member State, there is  the  risk that the implementation  of FRC would 
lead  to  a  substantial  increase  in  control  recommendations  with  no  increase  of  control 
capacity and, consequently, the impact management has to be considered.  

For another customs the single largest challenge remains changing trade patterns such as e-
commerce,  the  increasingly  larger  volume  of  data  makes  implementing  the  CRMF  a 
challenge. 

2.4.4. 

Other actions taken by the Commission under Objective 4 

2.4.4.1. ICS 2 Context 

In  the  context  of  developing  necessary  risk  management  capacities,  exploiting  EU  level 
data and planned entry into operation of ICS2 Release 2, the Commission and the Member 
States carried out a detailed work and completed all necessary documentation with regard 
to  the  ICS2  Safety  and  Security  Analytics  capability.  They  notably  completed  a  detailed 
in  particular  risk  management/analytics  business 
concept  document  setting  out 
requirements,  operational  and  governance  model,  an  update  of  ICS2  common  repository 
vision document as well as legal and data protection assessment. 

40 

 
 
 
This analytics capabilities to apply on EU level data collected in ICS2 common repository, 
which  will  be  integrated  within  the  common  repository,  have  been  subject  to  Member 
States ‘Go’ Decision in Q4/2020. The ICS2 Safety and Security Analytics (SSA) capability 
will  enable  the  Member  States  collaborative  analysis  (among  each  other  and  with  the 
Commission  in  the  context  of  implementation  of  the  Common  Risk  Management 
Framework) of massive flows of advance cargo data to deliver real-time operational safety 
and security threat signals while goods are moving through the supply chain. As the SSA 
will  be  integrated  to  the  ICS2  communications  workflow  (sending  the  signals  to  the 
Member  States  alongside  the  declaration  concerned),  the  results  of  risk  analysis  and 
controls  will  be  fed  back  systematically  for  each  case,  enabling  the  customs  experts  to 
evaluate and continuously improve targeting. Data governance and data protection will be 
built into the working method by design from the outset.  

A  pilot  exercise  is  currently  under  way  in  2020  with  the  Member  States,  alongside 
preparatory work on establishing an operational Expert Team of Member State that should 
provide a semi-permanent organisational set-up and operational framework bringing in MS 
and the Commission’s data science, analytics, risk management and domain experts for the 
development and exploitation of the capability. 

2.4.4.2. Customs 2020 project group on post-clearance audit  

The group on post-clearance audit has been set up to address the recommendations of the 
European Court of Auditors which highlighted that post release audits and controls do not 
properly cover the situation in which an economic operator lodges customs declarations for 
release for free circulation in a Member State different from the one where its headquarters 
are established. The work of the group has resulted in the drafting of guidance on how to 
address this situation from several points of view (Member States where import operations 
are  made  vs.  Member  States  of  headquarter),  which  has  been  included  into  the  Customs 
Audit  Guide  (CAG).  The  CAG  is  intended  as  a  support  for  the  Member  States  in  the 
organisation and carrying out  of customs audit controls  and provides practical  guidelines 
and  essential  elements  to  foster  more  effective  customs  controls  at  every  point  of  the 
customs territory.   

The group is also addressing the legal implications of dealing with customs debts arisen in 
several Member States and is focused in seeking clarifications on the legal basis to be used, 
with  a  view  to  identify  weakness  and  inconsistencies  in  the  legislation.  The  group  has 
moreover  ensured  the  full  update  of  the  CAG,  to  reflect  the  changes  to  the  customs 
legislation with the introduction of the Union Customs Code (UCC).  

The group operates in two different settings: a subgroup and the full group (all MS).   

A  subgroup  made  up  of  nine  (9)  Member  States  carries  out  an  in-depth  analysis  of  the 
issues to be tackled, identifies practical solutions and develops a common approach which 
is further discussed within the full group before decisions on actions to be carried out are 
made. The subgroup also engaged in voluntarily conducting an analysis, based on common 
and national criteria, to identify the scope of the action, i.e. singling out  potentially risky 

41 

 
 
 
economic operators that carry out import operations in one or several Member States while 
headquartered  in  another  Member  State,  and  which  are  relevant  within  the  scope  of  post 
release  audits  and  controls.  The  findings  have  been  shared  among  the  subgroup  with  a 
view  to  envisage  a  pilot  exercise  extended  to  all  the  Member  States  to  better  frame  and 
organise the identification of relevant economic operators.   

The group will moreover explore the possibility to carry out joint/multilateral audits or to 
set up an ad hoc expert team. 

2.4.4.3. Development of EU common risk criteria under the CRMF. 

Since the previous implementation report, progress has been made in the following areas: 

(a)  Financial risks:  

See above in Section 2.3.4 

(b)  Safety and Security risks: 

  Cash Controls 

Regulation  (EU)  No 2018/1672  on  controls  on  cash  entering  or  leaving  the  European 
Union and repealing Regulation (EC) No 1889/2005 will apply from 3 June 2021.  

The  Commission,  in  order  to  ensure  the  uniform  application  of  controls  on  cash,  will 
adopt,  by  means  of  an  implementing  act,  the  common  cash  movements  risk  criteria  and 
standards (CMRC). The controls on cash should primarily be performed within a common 
risk management framework in accordance with CMRC, priority control areas, and Union 
and international policies and best practices, taking also into account the risk assessments 
established by the Commission and the FIUs under Directive (EU) No 2015/849.    

  Air Cargo Security 

In the context of operationalisation of ICS2 Release 1, the Commission has agreed with the 
Member  States’  customs  authorities  and  in  close  collaboration  with  the  national  internal 
security  and  civil  aviation  security  authorities  on  the  set  of  common  risk  criteria,  risk 
indicators and standards for air cargo security pre-loading risk analysis. The Commission 
implementing  decision  establishing  these  criteria  and  standards,  to  be  supported  by  the 
common operational  guidance, passed a positive vote of the Customs Code Committee  – 
Risk Management and Control Section in October 2020 and will be adopted at the end of 
2020. 

  Drug Precursors  

A Customs 2020 project group pursued its work to support the activities and tasks of the 
customs  authorities  in  the  implementation  of  the  legislation  on  external  trade  in  drug 
precursors  in  order  to  prevent  the  diversion  and  trafficking  of  drug  precursors  entering, 
transiting  and  leaving  the  EU.  The  project  group  promotes  the  use  of  existing  risk 

42 

 
 
 
management  tools  and  is  also  closely  involved  in  the  development  of  future  tools  and 
systems such as the ICS2 Safety and Security Analytics. 

  Cultural goods  

For the import of cultural goods and up to 2019, only restrictions on the import of cultural 
goods from Iraq and Syria were in place. A relevant EU risk profile for imports has been 
created  identifying  the  parameters  of  this  problem  and  establishing  an  appropriate  risk 
management approach in this area. To enforce restrictions on the import of cultural goods 
from  Iraq  and  Syria,  a  RIF  for  imports  has  been  created.  In  2019,  a  new  regulation  has 
expanded the geographical coverage. Under the new regulation (EU) No 2019/880 on the 
introduction  and  the  import  of  cultural  goods,  the  common  risk  management  framework 
laid  down  in  Regulation  (EU)  No 952/2013  will  be  used  and  relevant  risk  information 
should  be  exchanged  between  customs  authorities.  Furthermore,  recommendations  and 
guidance  issued  from  international  organisations  and  bodies  that  are  active  in  cultural 
matters  are  to  be  taken  into  consideration  in  the  common  risk  management  framework 
when identifying risks related to cultural goods. 

  Firearms  

The  Commission  plans  an  impact  assessment  on  Regulation  (EU)  258/201216  in  2021, 
including with provisions to address specific risks, such as the illicit import of convertible 
alarm  and  signal  weapons,  the  illicit  import  of  semi-finished  firearms  parts  (which,  as 
‘blanks’ should be treated from a customs point of view as firearms part according to rule 
2a of the general rules for the interpretation of the harmonised system), or the absence of 
an entry summary declaration for weapons included in the luggage of air passengers. 

  Wildlife trafficking  

Under  priority  2  of  the  Wildlife  Action  Plan  (WAP),  various  actions  focus  on  setting 
enforcement priorities based on common risk-based assessment of EU-wide priorities that 
are agreed in the EU Wildlife Trade Enforcement Group, in cooperation with the MS and 
Europol. Twice a year, the Member States are convened for a meeting dedicated to illegal 
wildlife  trade  (Enforcement  Group),  in  which  updates  are  given  on  high-risk  products, 
which can in turn feed into national actions to organise enforcement actions. Furthermore, 
the EU-Twix database and emailing group, assures close contact between Member States 
so up-to-date information on emerging threats is shared and taken on board when setting 
up risk analysis. 

16 

Regulation  (EU)  No 258/2012  of  the  European  Parliament  and  of  the  Council  of  14 March  2012  
implementing  Article 10  of  the  United  Nations’  Protocol  against  the  illicit  manufacturing  of  and  
trafficking  in  firearms,  their  parts  and  components  and  ammunition,  supplementing  the  United  
Nations  Convention  against  Transnational  Organised  Crime  (UN  Firearms  Protocol),  and  
establishing  export  authorisation,  and  import  and  transit  measures  for  firearms,  their  parts  and  
components and ammunition, OJ L94, 30.3.2012, p. 1-15. 

43 

 
 
 
                                                 
  
  
  
  
  
  Waste  

On  the  control  of  the  illicit  movement  of  waste  shipments,  work  has  taken  place  in  the 
context  of  cooperation  between  the  EU  and  China  to  highlight  the  risks,  enhance 
cooperation  and  coordination  between  the  competent  authorities  and  customs  and  share 
risk  information  through  the  appropriate  channels.  In  the  future,  this  work  will  continue 
inter alia in a multilateral context involving the WCO. 

  F-GAS 

TAXUD  supported  the  creation  of  a  project  group  on  F-gases  under  the  programme 
‘Customs  2020’  on  an  initiative  of  Polish  Customs  Authorities.  The  overall  aim  of  this 
project was to identify best working practices of the customs authorities in supporting the 
F-gas  legislation  implementation.  The  work  of  the  project  group  has  been  extended  until 
31 March  2021,  to  support  coherent  application  and  effective  implementation  of  the  EU 
law as well as to enhance cooperation and coordination between the competent authorities 
and customs. It will also contribute to increase of safety and security, protection of citizens 
and the environment.  

2.5.  Objective  5:  Promoting 

improving 
information sharing between customs and other authorities at the Member 
State and EU level to ensure effective risk management 

interagency  cooperation  and 

Interagency  cooperation  and  information  sharing  between  customs  and  other  competent 
authorities at the Member State and EU level is highlighted in the strategy as an important 
means for ensuring more effective risk management and improving supply chain security.  

2.5.1. 

Actions taken by the Member States under Objective 5 

The questions under Objective 5 asked respondents to consider actions taken in this regard, 
particularly in the following action areas mentioned in the strategy: 

•  Develop  further  cross-sectoral  cooperation  arrangements, 
improve  sharing  and 
accessibility of (risk) information, and customs involvement in risk and threat assessments. 

•  Promote  use  of  good  practices  and  cooperation  methods  between  customs  and  other 
national authorities. 

2.5.1.1. Activities and outputs 

Customs administrations’ level of priority of improving cooperation with other competent 
authorities at the Member States and EU level with the aim to enhance information sharing 

No activity 

Low priority 

Medium 
priority 

High priority 

No reply 

- 

- 

7 

19 

- 

44 

 
 
 
 
The  priority  granted  to  Objective  5  is  high.  Before  going  into  the  activities,  respondents 
were  asked  to  provide  the  total  number  of  formal  agreements  since  2018  between  their 
national customs administration and other competent authorities at Member States and EU 
level,  such  as  e.g.  Memorandum  of  Understanding  (MOU)  for  cooperation  /  information 
sharing  and/or  based  on  sustained  and  structured  cooperation  between  two  or  more 
authorities.  

As seen in the figure below, the number of formal agreements varied considerably across 
respondents,  with  one  Member  State  reporting  29  agreements  since  2018  while  five 
Member  States  reported  no  new  agreements.  This  does  not  necessarily  imply  that  some 
customs authorities have not been cooperating with other authorities. Relevant agreements 
could indeed already have been in place before 2018, and/or the question could have been 
interpreted in different ways.  

Number of agreements between customs administrations and other competent authorities at 
the MS and EU level 

5 

6

5

4

3

2

1

0

s
e
t
a
t
S

r
e
b
m
e
M

f
o

.
o
N

4 

3 

2 

3 

2 

1 

1 

1 

1 

1 

1 

1 

0

1

2

3

4

6

10

14

20

>20

29 Unclear No

No. of agreements 

reply

Member States were asked to report on actions taken by their administrations since 2018 
aimed at improving cooperation with other authorities in their countries or at the EU level, 
in  particular  with  those  authorities  that  work  in  one  or  more  of  11  main  areas  for  multi-
agency cooperation identified in the table below. 

Status of actions aimed at improving cooperation with other national authorities or at the 
EU level 

45 

 
 
 
 
 
 
 
 
 
 
 
No  action 
planned 

Action 
planned 
but not  yet 
started 

Action 
ongoing 
/ 
completed 

No reply 

Other  law  enforcement,  including 
intelligence 

Intellectual property rights 

Transport  
(maritime and aviation security) 
Animal,  food,  feed  and  plant  health 
and safety 

Product safety and compliance 

Health protection 

Environment 

Tax 

Non-proliferation  and  conventional 
weapons 

Cultural goods 

Interagency  cooperation  with  border 
guards 

1 

3 

2 

2 

2 

3 

3 

2 

2 

4 

2 

2 

2 

5 

2 

- 

- 

- 

- 

2 

3 

1 

20 

17 

16 

20 

22 

18 

18 

21 

19 

15 

19 

3 

4 

3 

2 

2 

5 

5 

3 

3 

4 

4 

Respondents were then asked to describe the main actions referred to above. If there had 
been a large number of initiatives or activities, respondents were asked to focus on the five 
deemed most significant. Responses show a significant number of activities related to all 
11  areas.  Specific  actions  are  described  below  under  the  11  main  areas  for  multi-agency 
cooperation, though there is some overlap between areas. 

  Other law enforcement, including intelligence 

Ongoing or completed activities to improve cooperation with law enforcement authorities 
were indicated by twenty (20) Member States and two (2) Member States have activities 
planned. The activities described included taking part in projects and joint operations with 
Europol  and national  law enforcement  agencies,  cooperation agreements and information 
sharing, and cooperation in preparation for the implementation of ICS2. 

Participation in projects and joint operations was mentioned by eight (8) MS. For instance, 
one customs authority reported they have participated in several operations that stimulate 
interagency  cooperation  at  both  the  Member  States  and  the  EU  level,  with  for  example 
OLAF and Europol.  

46 

 
 
 
 
 
At the Member States level, joint operations with other authorities are being organised in 
the  areas  of  cash  and  narcotics.  For  example,  one  operation  had  the  aim  to  improve 
capabilities in detecting illicit cash movements, especially undeclared cash, in identifying 
currency  declarations  that  present  anomalous  elements,  in  linking  illicit  cash  movements 
with  predicate offences,  improving  capabilities to detect money laundering  and terrorism 
financing.  

The possibilities to cooperate at the EU level are also explored by participating in expert 
and project groups e.g. in the areas of drug precursors – the Customs 2020 Drug Precursors 
subgroup on the use of risk management. One Member State in addition referred to taking 
part in working groups with EU MS counter-terrorism experts.  

Another  Member  State  reported  that  due  to  the  Operational  Coordination  Centre  (OCC), 
customs  and  a  number  of  other  law  enforcement  authorities  and  agencies  (including  the 
Police,  Coast  Guard,  Financial  and  Economic  Crime  Unit)  involved  in  the  fight  of 
smuggling of alcohol, tobacco and mineral oil products, carry out joint operations.  

A  series  of  Member  States  referred  to  cooperation  with  Europol  through  involvement  in 
EMPACT,  in  particular  the  EMPACT  priority  excise  fraud,  involving  joint  actions  and 
exchange of information. 

In  2018,  the  customs  of  one  Member  State  –  together  with  Frontex  –  co-led  an 
international  Joint  Action  Day  (JAD)  in  the  areas  of  fighting  the  facilitation  of  illegal 
immigration,  excise  fraud  and  document  fraud  at  the  EU  external  land  borders.  In  2019, 
they took  part in  an international  operation with border  guards of another Member State, 
customs  from  another  one  and  Frontex  fighting  excise  fraud  (especially  tobacco 
smuggling), document fraud and migrant smuggling at EU’s Eastern external land border. 
They  further  reported  that  exchange  of  good  practices  and  interagency  cooperation  have 
been promoted via participation in the activities of the 9th Customs Cooperation Working 
Party  (CCWP)  Action  Plan  2018-2019.  This  includes  illegal  cigarette  production  sites 
within  the  EU  and  proliferation  of  cigarette  production  machines  and  tobacco  precursors 
imported legally, smuggling and illegal handling of mineral oils, customs against internet 
crime,  fight  against  illicit  cash  movements,  fight  against  IPR  infringements,  and  better 
integration of Customs in EU Serious Organised Crime Threat Assessment (SOCTA). 

One  customs  authority  reported  participation  in  international  operations  organised  by  the 
World Customs Organisation (WCO), Europol and OLAF, including operations aiming at 
combating  smuggling  of  tobacco  products  and  other  excise  goods.  The  CELBET  joint 
customs operation focused on revealing cigarette smuggling in trucks and vans, as well as 
controlling  shipments  containing  devices  and  materials  used  for  cigarette  production.  In 
addition, they participate in the work of the Baltic Sea Task Force (BSTF) for Combating 
Organised Crime, with 11 countries in the Baltic Sea Region. 

Six (6) Member States referred to cooperation agreements and information sharing. For 
instance,  one  customs  authority  has  a  Memorandum  of  Understanding  (MOU)  with  its 

47 

 
 
 
national  Interpol  Office,  and  another  customs  has  an  agreement  on  cooperation  with  the 
police  for  sharing  data  relating  to  security  issues  at  its  main  Airport.  While  another 
customs authority reported that they are responsible for drafting an intelligence picture in 
the area of excise fraud based on a cooperation agreement between the Police Department, 
Customs  Department,  State  Border  Guard  Service  and  Financial  Crimes  Investigation 
Service to establish a Joint Criminal Intelligence Information Analysis Centre.  

The  administration  of  one  Member  State  reported  they  have  renewed  the  protocol  with 
their  national  anti-Mafia  directorate  according  to  which  customs  provides  data  and 
information  about  transnational  fraud  and  criminal  networks.  They  also  take  part  in  the 
National  Observatory  for  Copper  Theft,  under  the  Ministry  of  Interior.  This  observatory 
comprises 
railways, 
telecommunications, and confederations of industries, in which the customs administration 
shares analysis to detect high-risk customs declarations of copper movements including for 
import,  export  and  intracommunity  transit  or  trade.  This  customs  further  referred  to 
cooperation with the National Counter-Terrorism Department.  

enforcement 

companies 

including 

private 

law 

and 

A  Member  State’s  customs  reported  they  have  enhanced  cooperation  and  information 
sharing in the last few years including several official permanent and ad hoc structures for 
comprehensive  cooperation  with  a  wide  range  of  different  authorities  including  law 
enforcement,  licensing  and  market  surveillance  authorities  and  intelligence  /  security 
services. Regular information exchange takes place and a robust legal framework ensures 
that there are no major obstacles for cooperation.  

Another  Member  State’s  customs  reported  they  have  a  network  of  technical  experts  / 
liaison officers in several organisations and other national administrations such as Europol 
and the Financial Intelligence Unit. 

One  Member  State  reported  participation  in  the  deliberations  of  a  transnational  working 
group with two neighbours. Cooperation focuses on combating narcotics crime related to 
the  production  and  trade  of  methamphetamine.  Cooperation  between  the  services  of  the 
participating  countries  i.e.  Police  and  Customs  Services  has  a  working  dimension, 
involving primarily exchange of information and experience. Moreover, the authorities of 
another  Member  State  referred  to  international  exchange  of  information  on  persons 
involved  in  smuggling  narcotics  between  the  National  Revenue  Administration  and 
Customs Liaison Officers in two other countries. 

Two  (2)  Member  States  mentioned  cooperation  initiatives  with  law  enforcement  in 
preparation  for  ICS2.  One  reported  they  have  designated  contact  points  with  the  Police, 
Intelligence Services and Aviation Security in view of the implementation of ICS2 CRCs 
based on pre-loading information. The second one referred to an initiative on cooperation 
and  exchange  of  information  between  customs  and  other  authorities  including  the  Police 
and Intelligence Service related to ICS2. 

48 

 
 
 
 
  Environment 

Eighteen  (18)  Member  States  mentioned  ongoing  or  completed  actions  related  to 
cooperation and information exchange with authorities working in the area of environment 
protection.  The  actions  described  varied,  but  mainly  related  to  cooperating  with  relevant 
national authorities, and participating in various projects, committees and operations. 

One  customs  authority  referred  to  close  cooperation  with  other  government  authorities 
including the Ministry for Environment, Land and Sea Protection for the development of a 
‘single  window’  (SW)  integration  system,  aiming  at  improving  risk  management  in 
specific related areas.  

Another  Member  State  reported  a  Memorandum  of  Agreement  (MOA)  with  the  State 
Environmental  Service  regarding  the  control  of  waste  shipments  and  participation  in  a 
project group on the control of F-gases.  

In the context of nuclear, one customs authority reported they act as the radiation detection 
supervisor in close cooperation with the Radiation and Nuclear Safety Authority. A third 
Member State reported that the Customs and Excise Department in cooperation with other 
competent  authorities  have  initiated  the  development  of  a  national  threat  assessment 
document on chemical, biological, radiological and nuclear defence. 

One  Member  State  reported  taking  part  in  a  project  with  the  State  Forestry  Corps  and  a 
non-profit organisation. The aim of the project was to map the trade chains in three main 
areas (waste trafficking, agricultural and food products, flora and fauna protection) in order 
to prevent and combat environmental crime.  

Another Member State reported participation in the international operation DEMETER V 
on illegal waste materials with the Department of Environment. Participation in operation 
DEMETER was reported by another Member State, which in addition referred to a current 
pilot  project  on waste coordinated by OLAF on fraud related to  container transhipments. 
This  pilot  project  aims  to  build  and  share  knowledge  about  the  illegal  business  of 
smuggling goods by abusing customs rules and legitimate activities such as transhipment.  

One  Member  State  reported  participation  in  operations  involving  different  DGs.  For 
instance,  the  Forum  enforcement  project  of  the  European  Chemicals  Agency  (ECHA) 
REACH-EN-FORCE-7 ‘Enforcement of Registration obligations after the last registration 
deadline  in  cooperation  with  customs  authorities  including  the  verification  of  the  strictly 
control conditions applicable to the substances registered as intermediates’. This customs 
authority also participates in a pilot project on cooperation with customs in enforcement of 
REACH and CLP, and organises training lessons provided by relevant agencies related to 
REACH, CLP, and biocides. They also participate in an inter-ministerial committee related 
to the Convention on International Trade in Endangered Species of Wild Fauna and Flora 
(CITES). 

49 

 
 
 
Several other Member States mentioned participating in committees and operations related 
to  CITES.  In  one  Member  State,  a  protocol  of  cooperation  related  to  CITES  and  waste 
between  the  National  Environmental  Guard  and  General  Directorate  of  Customs  is  in 
force. It covers the exchange of information as far as the infringement of the EU legislation 
in  the  field  is  concerned  and  the  joint  operations  for  preventing,  detecting,  finding  and 
sanctioning  of  any  violations,  in  accordance  with  the  competencies  of  each  institution 
involved. The authorities of another Member State reported their participation in national 
expert  groups  relating  to  environmental  crime  and  CITES  involving  regular  meetings  of 
experts  across  different  sectors  with  the  aim  to  share  information  and  to  implement 
common agreed action plans at the national and EU level. They also reported cooperating 
with selected authorities at the national and international level in the area of environment 
protection. 

  Transport 

In  the  context  of  preparing  for  ICS2  Release  1  implementation,  DG  TAXUD  actively 
promoted,  and  worked  closely  with  national  customs  (risk  management  community)  in 
their  activities  of  establishing  operational  collaboration  with  the  national  civil  aviation 
security  and  national  internal  security  authorities.  DG  TAXUD  emphasised  the  critical 
importance  and  critical  success  criteria  of  having  all  national  customs  risk  management 
units established operational cooperation with those authorities before ICS2 Release goes 
live in March 2021. To this end, this matter was brought to attention of the CPG at several 
meetings  in  2019  and  2020,  in  order  to  seek  the  highest-level  management  support  to 
national risk management teams. In the area of transport (maritime and aviation security), 
sixteen  (16)  customs  authorities  have  ongoing  or  completed  cooperation  initiatives,  and 
five (5) customs authorities are planning activities in this area. Actions reported commonly 
involved cooperation with other national authorities as required by the implementation of 
ICS2.  

One Member State reported they have an agreement with the Antiterrorism Agency to put 
in practice the AVSEC Decision for ICS2 Phase I - Security area. Customs authorities of 
another  Member  State  reported  there  has  been  communication  with  the  National  Civil 
Aviation  Authority  in  the  context  of  ICS2,  where  they  also  have  a  network  of  technical 
experts / liaison officers. 

Based on the new protection layer implemented by ICS2, which will gradually enter into 
force from 2021, one Member State’s customs authorities has started cooperation with the 
National  Counter-Terrorism  Department  and  Civil  Aviation  focused  on  the  detection  of 
immediate and severe security risks to aviation transportation. 

The  customs  administration  of  one  Member  State  is  currently  intensifying  the  contacts  / 
liaising  with  the  Federal  Aviation  Office  in  the  context  of  incorporating  the  pre-loading 
advanced cargo information  (PLACI) dataset  into the  ICS2 national  interface. They have 
started the process of taking part in aviation security as required for ICS2 air pre-loading 
the  new  capabilities  and 
analysis.  Established  contacts  have  been 

informed  of 

50 

 
 
 
responsibilities  and  working  relationships  have  been  formed  to  discuss  operational 
processes  and  coordination  /  cooperation  in  this  field  before  ICS2  becomes  operational. 
This administration further reported they have actively taken part in discussing topics and 
drafting  guidelines  on  the  EU  level  in  various  working  groups  with  EU  MS  AVSEC 
authorities, EU MS counter-terrorism experts, and the Commission. 

In  another  Member  State  there  has  been  an  initiative  on  cooperation  and  exchange  of 
information  between  customs  and  other  authorities  related  to  ICS2  including  the  Civil 
Aviation Agency. In addition, within the Strategy for Integrated Border Management there 
is  a  protocol  of  data  exchange  and  communication  between  several  national  authorities 
including the Ministry of Sea, Transport and Infrastructure. 

In one Member State, an agreement with  the national  Naval  Authority for data exchange 
between  the  National  Single  Window  (NSW)  (Directive  2010/65/EU)  and  the  national 
ICS2 was signed. Meetings were held between representatives of the customs authority and 
the  Naval  Authority  in  order  to  find  technical  solutions  for  viewing  data  sets  by  experts 
from the Traffic Services Information and Management System and for linking with NSW 
ENS. 

One  Member  State  referred  to  a  first  meeting  to  commence  cooperation  with  the  Anti-
terrorism  Centre  of  Internal  Security  Agency,  the  Border  Guard,  and  Civil  Aviation 
Authority,  dealing  with  –  among  others  –  combating  terrorism  and  air  safety.  The 
authorities  explained  that  establishing  cooperation  in  this  area  aims  to  strengthen  risk 
analysis  through  participation  and  contribution  to  e-screening  conducted  for  the  needs  of 
the  ICS2  system.  In  addition  to  individual  meetings  with  the  respective  services,  it  is 
planned to hold talks in this regard at meetings of the Interdepartmental Team for Terrorist 
Threats. 

Other cooperation in the area of transport included: an MOU between Customs, the Coast 
Guard, and the Ministry of Maritime Affairs in one Member State as well as the customs 
cooperation with the Police and border guards on air passengers’ data PNR. 

  Interagency cooperation with border guards 

Nineteen  (19)  Member  States  reported  on  interagency  cooperation  with  border  guards, 
though there is some overlap with other areas of cooperation. Activities described in this 
context  varied.  For  example,  some  authorities  referred  to  their  participation  in  a 
coordination  centre  for  border  controls,  immigration  and  asylum  for  common  risk 
management at Border Control Points (BCPs) with other competent authorities.  

The  authorities  of  one  Member  State  reported  on  enhanced  activities  of  a  Regional 
Cooperation  Group  consisting  of  the  State  Border  Guard,  State  Police,  State  Revenue 
Service, Food and Veterinary Service and State Environmental Service meeting quarterly 
to plan and coordinate cooperation and discuss current events.  

51 

 
 
 
At  the  EU  level,  three  (3)  Member  States  coordinate  their  activities  according  to  the  9th 
Action  Plan  of  the  Customs  Cooperation  Working  Party  (CCWP)  for  the  period  2018-
2019, which includes inter alia issues on risk management, control, and exchange of good 
practice.  One  Member  State  reported  systematic  data  and  strategic  information  sharing 
with  other  national  enforcement  agencies  to  ensure  effective  and  immediate  reaction  to 
security  threats,  as  well  as  systematic  cooperation  with  Border  Police  at  the  external 
border. 

One  Member  State  referred  to  the  ongoing  implementation  of  two  agreements,  which 
entered into force in 2017, between the revenue administration and the border guards: (1) 
performance  of  tasks  specified  in  the  cooperation  plan,  and  (2)  editing  a  common 
communication channel service and mobile applications. It further reported participating in 
meetings with officers of the Border Guard involving mainly cooperation with officers of 
the  Department  for  Analysis,  Information  and  International  Cooperation  aimed  at 
exchanging  information  and  developing  good  practices  in  the  field  of  cooperation  and 
coordination of joint activities in terms of combating drug crime. 

Another Member State stated that a consultation platform between the customs and excise 
administration on the one hand and all the other governmental agencies on the other hand 
has  officially  been  set  up  at  national  level  to  optimise  further  communication  and 
cooperation  with  other  agencies.  This  platform  is  the  instrument  used  to  discuss  the 
activities carried out at the border by both the customs and excise administration and the 
other  public  organisations  in  order  to  increase  efficiency  and  to  formalise  the  contacts  / 
cooperation  that  existed  previously  in  an  informal  way.  Several  working  groups  already 
exist,  each  focusing  on  a  specific  theme:  policymaking,  training,  policy  about  dual  use  / 
embargoed  goods.  A  working  group  on  risk  management  is  one  of  the  priorities  for  the 
future,  though  the  customs  and  excise  administration  already  cooperate  regularly  with 
other governmental authorities on risk management, albeit in a less formal manner. 

  Animal, food, feed and plant health and safety 

Ongoing or completed cooperation in the area of ‘animal, food, feed and plant health and 
safety’  was  reported  by  twenty  (20)  Member  States.  Initiatives  in  this  area  include 
participation  in  joint  operations,  and  cooperation  including  agreements  with  national 
authorities.  

Several  customs  authorities  participated  in  joint  operations  organised  at  the  EU  and 
international  level  with  authorities  such  as  the  Federal  Agency  for  Safety  of  the  Food 
Chain. Operations include in particular OPSON, Silver Axe, Thunderball, and OLAF JCOs 
relating to CITES.  

Other cooperation in the area of ‘animal, food, feed and plant health and safety’ involved 
agreements  with  other  national  authorities.  For  instance,  the  customs  authorities  of  a 
Member  State  noted  an  interdepartmental  agreement  with  the  border  inspectors  and  the 
food and veterinary service including cooperation at border crossing points, agreement on 

52 

 
 
 
cooperation in customs clearance and customs control with postal and rail operators. They 
also  carry  out  training  seminars  for  customs  officers  in  cooperation  with  the  food  and 
veterinary service.  

One  administration  referred  to  a  new  agreement  regarding  cooperation  between  Customs 
and the Agriculture and Food Inspection Authority including the exchange of information 
about  dangerous  foodstuffs,  which  can  be  used  to  create  new  risk  profiles.  Another 
customs  authority  noted  they  have  a  protocol,  within  the  Strategy  for  Integrated  Border 
Management,  relating  to  data  exchange  and  communication  between  several  national 
authorities including the Ministry of Agriculture.  

Another  Member  State  reported  on  cooperation  mechanisms  such  as  different  national 
plans and programmes  to improve the  efficiency of official controls performed to  ensure 
the verification of compliance with  feed and food law, animal  health and animal  welfare 
rules, for example a national programme of surveillance, prevention and control of African 
swine  fever  –  defining  the  roles  and  competencies  of  different  authorities  involving  the 
National  Sanitary  Veterinary  and  Food  Safety  Authority,  and  National  Phytosanitary 
Authority.  

One Member State cited close cooperation with other government authorities including the 
Ministry  of  Agriculture  for  the  development  of  a  ‘single  window’  integration  system, 
aiming at improving risk management in specific related areas.  

Finally,  in  the  area  of  ‘animal,  food,  feed  and  plant  health  and  safety’  the  authorities  of 
another Member State reported participation in national expert groups including on CITES 
and ongoing cooperation with selected Member States authorities. 

  Product safety and compliance 

Nearly  all  customs  authorities  (22)  reported  completed  or  ongoing  initiatives  to  enhance 
cooperation  with  other  authorities  and  other  Member  States  in  the  area  of  product  safety 
and  compliance.  In  this  context,  respondents  referred  to  cooperation  with  Market 
Surveillance  Authorities  (MSAs)  and  participating  in  project  groups  and  national 
committees. 

For  instance,  one  Member  State  reported  that  the  Department  of  Customs  and  Excise 
carried out joint actions with MSAs such as joint operations, joint trainings and the use of 
new  technologies  for  chemical  detection.  Relevant  guidelines  for  customs  officers  have 
been uploaded to the Department’s intranet, which furthermore in cooperation with MSAs 
is  in  the  process  of  developing  a  national  legislation  based  on  Regulation  2019/1020  on 
market surveillance and compliance of products.  

The customs authority of another Member State reported they cooperate well with national 
MSAs in  the area of product  safety based on the national  legislation and formal bilateral 
protocols, but even without protocols, exchange of control and risk information is ensured.  

53 

 
 
 
The authorities of a third Member State reported that information exchange with national 
MSAs  has  been  stimulated  as  a  result  of  quarterly  meetings.  In  addition,  in  the  area  of 
product  safety,  a  Framework  Agreement  with  the  Ministry  of  Economics  has  been 
negotiated at the national level.  

One  Member  State  reported  ongoing  cooperation  with  MSAs  in  the  area  of  prohibitions 
and  restrictions.  While  another  one  referred  to  meetings  with  MSAs  for  better 
understanding of threats and combining powers for tackling risks. 

Two  authorities  reported  participating  in  several  expert  and  project  groups  including 
PARCS. The authorities referred to a project group on statistical data and risk analysis in 
the  area  of  product  safety  to  prepare  the  entry  into  application  of  the  new  Regulation 
2019/1020 on market surveillance and product compliance. 

Two other countries referred to participation in national committees. One of these customs 
authorities  participates  in  a  national  committee  on  market  surveillance  representing  all 
relevant authorities in the areas of product safety and compliance and health protection. In 
addition, they organise training lessons provided by the relevant agency related to product 
safety.  The  other  authority  stated  that  the  exchange  of  information  is  secured  in  national 
inter-ministry committees, the base for communication is mostly in the legislation and in 
agreements with all agencies involved. 

Finally, one Member State reported they have an MOA with  the State Technical  Control 
Agency regarding controls of agricultural and forestry machinery. 

  Intellectual property rights (IPR) 

Cooperation with other national authorities in the area of intellectual property rights (IPR) 
is ongoing or completed in seventeen (17) of the surveyed Member States. The initiatives 
described  by  Member  States  in  this  area  mainly  related  to  formal  agreements  and 
participation  in  joint  operations.  Note  that  some  initiatives  are  described  under  ‘other’ 
headings as there is overlap between initiatives in IPR and other areas. 

In the context of IPR, one Member State’s customs have an MOA with the national Patent 
Office,  who  they  also  carry  out  training  seminars  for  customs  officers  with.  In  addition, 
they participate in project groups relating to IPR and organise public awareness campaigns 
on the topic. Another Member State’s customs reported they have carried out joint actions 
in the area of IPR with the Police, based on the MOU signed between the two authorities. 
A  third  Member  State’s  customs  reported  participating  in  joint  operations  in  the  area  of 
IPR, one led by OLAF. Similarly, a Member State reported participation in JCO HYGIEA 
related to counterfeit goods. 

One  Member  State  described  activities  in  the  area  of  IPR,  although  these  related  to 
protocols  signed  pre-2018,  in  2016  –  the  Protocol  on  the  prevention  and  combating  of 
traffic  of  counterfeiting  medicines  between  the  General  Directorate  of  Customs  and  the 
Public  Ministry,  Ministry  of  Internal  Affairs,  the  National  Drug  and  Medical  Devices 

54 

 
 
 
Agency, National Sanitary Veterinary and Food Safety Authority, Association of Generic 
Medicines  Manufacturers,  Association  of  International  Producers  of  Medicines.  The 
purpose of this protocol is to create a single point network contact (SPOC) at the level of 
the  public  and  private  partners  involved  in  combating  the  counterfeiting  of  medicinal 
products  in  accordance  with  the  specific  attributions  and  competencies  provided  by  the 
national legislation. In addition, a Protocol has been signed between a General Directorate 
of Customs and a car manufacturer to cooperate in specific actions in order to prevent and 
combat violations of the customs legislation regarding the enforcement of the intellectual 
property rights (counterfeit auto parts). 

  Tax 

Twenty-one (21) Member States reported cooperation with other authorities and Member 
States in the area of tax, though relatively few mentioned cooperation in this area as one of 
the  main  initiatives.  Reported  initiatives  included:  an  agreement  on  cooperation  and  data 
exchange  between  a  Member  State’s  customs  and  tax  administration;  close  cooperation 
with  tax authorities and other EU Member States in  connection to  the VAT and customs 
procedure 42; and a joint operation aiming at preventing abuse arising from the application 
of  customs  procedure  42  with  five  other  Member  States.  One  Member  State’s  customs 
authorities reported that a cooperation group between the VAT administration and customs 
is  provided  for  in  national  law.  In  another  Member  State,  links  to  internal  tax  databases 
have  been  improved  (links  to  obtain  information  on  EOs,  national  taxes,  sanctions, 
activities,  etc.),  while  other  authorities  stated  they  have  a  network  of  technical  experts  / 
liaison  officers  in  several  organisations  and  other  national  administrations  including  the 
National Tax Authority. 

In  addition,  the  authorities  of  one  Member  State  referred  to  counteracting  unjustified 
reimbursement  of  VAT  to  travellers  under  the  tax-free  system.  Integration  of  the  ‘VAT 
refund  for  travellers’  system  of  the  National  Revenue  Administration  with  the  system 
administered  by  the  Head  of  the  Office  for  Foreigners  and  the  Integrated  Archive  of 
Checks  and  ID  Checks  system  administered  by  the  Border  Guard  –  integration  of  these 
systems makes it possible to verify actual stay of foreigners on EU territory applying for a 
tax refund. 

  Non-proliferation and conventional weapons 

Nineteen  (19)  of  the  surveyed  Member  States  reported  cooperation  in  the  area  of  non-
proliferation and conventional weapons and two (2) Member States stated that actions are 
planned for the future. However, only four (4) Member States describe these as one of their 
main initiatives, largely relating to information sharing.  

One  of  these  customs  authorities  has  a  multi-agency  working  group  aimed  at  non-
proliferation,  dual  use  goods,  and  conventional  weapons.  Information  shared  in  this 
working  group  enables  creation  of  risk  profiles.  One  Member  State  reported  that  the 
customs  administration  participates  in  the  national  Financial  Security  Committee  to 

55 

 
 
 
coordinate  the  fight  against  terrorist  financing  and  includes  exchange  of  information 
regarding non-proliferation and conventional  weapons.  In another Member State, there is 
cooperation  with  the  National  Security  Analysis  Centre  including  data  and  information 
sharing  in  the  area  of  non-proliferation,  conventional  weapons  and  the  fight  against 
terrorism.  One  Member  State’s  customs  authority  referred  to  structural  forms  of 
cooperation such as meetings, organisation of joint actions, exchange of risk information, 
and training between the customs and relevant authorities at the MS level. 

  Cultural goods 

This was the area where the fewest countries reported actions. 

Fifteen  (15)  Member  States  reported  completed  or  ongoing  cooperation  with  authorities 
that work in the area of cultural goods. Only three (3) countries reported this as one of their 
main  initiatives.  One  Member  State  stated  that  close  cooperation  with  the  Antiquities 
Department  has  been  achieved  by  providing  their  technical  advice  and  expertise  upon 
request  on  suspicious  cargo  consignments.  Another  Member  State  reported  that  they 
participate  in  a  national  expert  group  related  to  cultural  goods,  which  involves  regular 
meetings  of  experts  across  relevant  sectors  with  the  aim  to  share  information  and  to 
implement  common  agreed  action  plans  at  the  national  and  EU  level.  A  third  Member 
State referred to an agreement, entered in 2020, between the Head of the National Revenue 
Administration,  the  Minister  of  Culture,  the  Commander-in-Chief  of  the  Police  and  the 
Commander-in-Chief of the Border Guard on cooperation in combating illegal export and 
import  of  cultural  goods.  This  agreement  provides  the  National  Revenue  Administration 
access  to  the  data  of  a  system  processing  of  data  contained  in  administrative  decisions-
permits for the export of cultural goods abroad. Moreover, it concerns mutual assistance in 
the  fields  of  control  activities,  exchange  of  information,  training  and  exchange  of 
experience  and  offers  a  quick  possibility  of  verifying  the  object  in  databases  run  by  the 
Ministry of Culture in terms of legality of origin (whether object was stolen or is not a war 
loss). 

  Health protection 

Customs  administrations  highlighted  several  initiatives  in  the  area  of  health  protection. 
Although some of these initiatives have been mentioned elsewhere, since there is overlap 
between areas. Reported initiatives included for  example participation in an international 
joint  operation  with  relevant  authorities  including  Police  and  pharmaceutical  services  on 
falsified  pharmaceutical  products.  One  Member  State’s  customs  authority  reported  they 
have  an  MOA  with  the  Health  Inspectorate  regarding  the  control  of  medical  goods  and 
cosmetics.  Similarly,  another  customs  authority  has  a  protocol  within  the  Strategy  for 
Integrated  Border  Management  relating  to  data  exchange  and  communication  between 
several national authorities including the Ministry of Health. 

56 

 
 
 
 
 
  Other 

Respondents  were  further  able  to  provide  examples  of  actions  taken  to  improve 
cooperation  and  information  sharing  that  did  not  fit  into  the  11  areas  described  above. 
Examples of these and some more general responses are described in this section. 

For example, in the area of products and strategic technologies, one Member State referred 
to a protocol signed between the General Directorate of Customs and the National Agency 
of Controls of Exports (a specialised body of the central public administration, with legal 
personality, subordinated to the Ministry Foreign Affairs). The protocol aims at increasing 
the  effectiveness  of  export  and  import  control  systems  for  products  and  strategic 
technologies as well as preventing, detecting and combating violations of legal provisions 
on export control regimes and the import of strategic products. This customs authority also 
referred  to  agreements  with  the  main  international  express  couriers  for  the  exchange  of 
information  and  an  agreement  between  the  fiscal  administration  and  the  national  post 
company on combating violations of customs legislation. In addition, it informed about a 
cooperation  plan  with  the  Customs  service  of  a  neighbouring  non-EU  country  on  the 
intensification of collaboration on combating customs fraud and trade facilitation. 

The authorities of one Member State referred to cooperation with the General Inspector of 
Financial  Information  involving  providing  customs  authorities  with  (1)  information 
referred to in Article 5 of Regulation (EC) No 1889/2005 of the European Parliament and 
of the Council on controls of cash entering or leaving the community and (2) information 
contained in the declarations of import into and export abroad of foreign exchange values 
or  national  means  of  payment  (as  defined  in  national  legislation).  In  addition,  related  to 
road transport security, these authorities are cooperating with the General Inspectorate of 
Road  Transport  including  access  to  its  system  for  Electronic  Authorisation  Control.  The 
system  enables  effective  control  of  international  road  hauliers  transiting  through  the 
territory on the basis of authorisations. 

Another  customs  authority  reported  that  in  the  framework  of  their  EU  presidency,  they 
carried out an exercise on the review of the legal framework of international cooperation 
covering the legal basis of nine regulations, conventions, decisions, and directives. On the 
EU  level,  priorities  of  this  Member  State’s  presidency  included  enhancing  international 
cooperation  between  customs  authorities,  the  Commission,  Europol,  and  the  European 
Border  and  Coast  Guard  Agency  Frontex.  While  in  terms  of  national  cooperation,  this 
administration noted that they have had structured procedures with relevant authorities for 
cooperation and information exchange. 

Similarly, another customs authority reported about active cooperation between regulatory 
agencies  and  equally  cooperation  with  similar  authorities  in  other  MS  significantly 
predates the CRMF.  

The  administration  of  one  Member  State  provided  a  more  general  response,  stating  that 
national  authorities  are  instructed  by  the  government  in  a  legislative  Act  to  seek 

57 

 
 
 
cooperation with each other for the benefit of society. For a number of the areas mentioned 
above,  the  national  legislation  prescribes  how  the  cooperation  and  information  sharing 
shall  be  carried  out.  In  some  cases,  there  are  written  agreements  between  two  or  several 
agencies with more detailed forms for their cooperation and customs is a partner in several 
such agreements and networks.  

Another Member State stated that its main actions related to  improving cooperation with 
other  authorities  cover  two  main  areas:  exchange  of  information  and  in  some  cases, 
customs  data;  and  development  of  joint  operational  actions,  with  focus  on  transnational 
movement of goods. 

2.5.1.2. Results – Improved integration/utilisation of risk information 

Extent to  which above actions have improved integration /  utilisation of risk  information 
from other competent authorities at the MS or EU level in risk management practices 

Not at all 

1 

To  a 
extent 

- 

limited 

To some extent  To 

a 

great 

No reply 

18 

extent 

6 

1 

Several  Member  States  (6)  indicated  that  the  actions  have  led  to  major  improvements, 
while  nearly  all  the  rest  (18  Member  States)  noted  improvements  ‘to  some  extent’. 
Respondents were then asked to describe the improved integration / utilisation and how it 
came about.  Responses  here varied significantly. Some respondents  were able to  provide 
clear indications of improvements achieved through specific actions. However, others had 
trouble distinguishing between activities and the results of activities, leading them to repeat 
previously  made  points.  More  importantly,  others  noted  the  difficulty  in  attributing 
improvements  to  specific  activities,  leading  them  to  mention  improvements  only  in  the 
general sense.  

Similarly,  two  (2)  Member  States  pointed  out  that  cooperation  as  described  has  been  in 
place for a long time, with progress taking place incrementally.   

The  main  examples  of  improved  integration  /  utilisation  of  risk  information  consisted  of 
improved awareness / understanding of existing and emerging risks, increased numbers of 
seizures, and the creation of new and adaptation of existing risk profiles. 

  Improved  awareness  /  understanding  of  existing  and  emerging 

risks.  

One  Member  State  reported  that  in  the  area  of  cash,  information  received  from  other 
Member  States  was  taken  into  account  in  order  to  perform  checks  in  the  framework  of 
DAPHNE, which enabled them to discover a new route. This Member State reported that 
exchange with other Member States concerning risk analysis within the framework of cash 

58 

 
 
 
 
allows  them  to  better  understand  the  particularities  and  common  risks  and  that  the  Cash 
Controls  Expert  Group  Subgroup  II  set  up  by  the  Commission  is  a  useful  exchange 
platform  in  this  context.  Another  example  is  in  the  area  of  precious  metals,  where  this 
authority  stated  that  the  information  they  receive  from  Ministry  of  Economy  about 
suspicious  firms,  illegal  activities  and  withdrawn  permits,  allow  them  to  adapt  risk 
reduction instruments.  

Another  Member  State  stated  that  areas  of  EU  interest  or  competence  are  generally 
underpinned  by  electronic  or  other  systems  for  the  identification  and  exchange  of  risk 
information. This has improved information sharing and has led to an increasing focus on 
electronic  risk  analysis  as  a  control  tool  that  is  gradually  delivering  an  improved 
understanding of both existing and emerging risks. 

  Increased numbers of seizures  

The  authorities  of  one  Member  State  reported  that,  as  a  result  of  the  OCC’s  operations, 
there have been increased numbers of seizures of excise duties products and an increase in 
illicit drug trafficking  identification. Another one reported increased numbers of seizures 
of tobacco products, while in the area of IPR, activities have led to increasing numbers of 
seizures and discovering illegal movements of waste containers. Other authorities reported 
increased  seizures  thanks  to  the  exchange  of  operational  information  with  other  Member 
States.  

The  authorities  of  another  Member  State  stated  that  participation  in  joint  operations, 
involving efficient and effective exchange of information and consistent action, resulted in 
the  detention  of  goods  including  cigarettes,  amber,  raw  resin  stone,  counterfeit  clothing, 
and  alcohol.  The  authorities  also  stated  that  the  integration  of  the  IT  systems  for 
counteracting  unjustified  reimbursement  of  VAT  to  travellers  related  to  tax  free,  has 
significantly  reduced  the  activity  of  organised  criminal  groups  shipping  out  wholesale 
quantities of goods (divided into individual travellers) with the aim of VAT refund fraud.   

  Creation of new and adaptation of existing risk profiles.  

One  Member  State  reported  that  cooperation  including  information  sharing  with  other 
authorities and Member  States has enabled them  to  create new risk profiles and to adapt 
existing ones in several areas.  

Another  Member  State  reported  that  cooperation  with  national  law  enforcement  has 
allowed sharing of risk information, including goods flows, modus operandi, and company 
data,  which  have  helped  to  create  new  and  more  effective  risk  criteria  and  new 
investigation cases. 

The administration of one Member State explained that improved integration / utilisation 
of risk information was a result of recent developments such as the automatic link between 
certificates issued  and the customs declaration (web services), the one-stop-shop in  ports 
(information of all physical controls in the single window to organise them), and common 

59 

 
 
 
repository  of  documents  (where  the  EO  can  include  the  information  required  for  issuing 
the certificates and all the authorities have access). 

2.5.1.3. Outcomes 

Extent to which the actions described above have improved risk management practices 

Not at all 

- 

To  a 
extent 

1 

limited 

To some extent  To 

a 

great 

No reply 

18 

extent 

7 

- 

  Improved risk management practices 

Seven (7) respondents  indicated that the actions taken to  improve  cooperation with  other 
authorities at the Member States and EU level have improved risk management practices in 
their  countries  to  a  great  extent,  while  nearly  all  the  rest  (17  Member  States)  noted 
improvements ‘to some extent’. Respondents were asked to describe the progress made in 
this context and how it came about. Some answers were general and without much detail, 
while other answers varied significantly – some examples are provided below. 

One  customs  authority  reported  that  their  risk  management  practices  have  improved  to  a 
great extent. Progress includes a fully operational system for exchanging certificate data in 
the  frame  of  the  national  customs  single  window  –  a  one-stop-shop  to  coordinate  the 
physical controls on goods. The project is currently in the end of its pilot phase. The hope 
is  to  adopt  a  new  approach,  based  on  the  customs  pre-declaration,  that  allows  the 
coordination of controls and risk analysis 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 
single window to coordinate all necessary controls. 

The authorities of another Member State noted that in most areas they reported cooperation 
there  has  been  an  improvement  in  risk  management  practices,  arising  in  particular  from 
systematic cooperation between competent national authorities. In most cases, the platform 
for  cooperation  is  created  by  online  access  to  the  IT  systems  administered  by  the 
cooperating authorities and the possibility to use the data contained in these systems during 
control  activities.  Cooperation  with  law  enforcement,  border  guards  and  other  Member 
States  has  led  to  more  effective  actions  in  combating  crime,  revealing  and  combating 
smuggling  and  distribution  of  precursors,  pre-precursors,  new  psychoactive  substances 
(NPS), synthetic drugs from Asian countries and other countries to the EU. Participation in 
joint operations has increased effectiveness of detecting irregularities through the use and 
application  of  acquired  knowledge  and  exchange  of  experience  on  the  methods  of  risk 
analysis  used  and  the  most  effective  methods  and  tools  used  to  reveal  smuggling  at  the 
external EU border, places of illegal tobacco production and irregularities in trade of dried 
tobacco. 

60 

 
 
 
 
The  authorities  of  one  Member  State  reported  that  in  the  area  of  food  safety,  the 
aforementioned activities have led to a strengthened customs supervision of imported and 
exported dangerous foodstuffs. In the area of non-proliferation, activities have resulted in 
better targeting of customs controls for some exporting entities and, in the area of border 
security  (airport),  data  received  from  other  authorities  have  made  tracking  suspected 
persons easier. 

Another  administration  referred  to  its  presence  at  the  Passenger  Information  Unit  (PIU) 
which have resulted in the capability to carry out risk-based controls on air passengers. It 
further  reported  that  in  all  other  areas,  the  cooperation  and  the  exchange  of  information 
with competent authorities have been used for implementation of risk-based controls. 

In  the  area  of  enforcement,  border  cooperation  and  security,  one  Member  State  reported 
that close and systematic cooperation with  other enforcement  agencies has led to  new or 
adjusted  processes,  which  have  increased  the  effectiveness  and  response  of  executive 
bodies  in  the  area  of  customs  crime  and  smuggling.  The  administration  further  reported 
that coordination with authorities in the area of product safety, including setting up internal 
processes for communication of risk information, contributed to the increasing number of 
RIFs communicated via the CRMS in this area.  

One  Member  State  reported  that  risk  management  practices  have  improved  to  a  great 
extent as a result of awareness  raising of information sharing via  IT systems  such as the 
Rapid  Alert  System  for  Non-Food  Products  (RAPEX)  and  the  Rapid  Alert  System  for 
Food  and  Feed  (RASFF),  Enforcement  Groups  such  as  FORUM,  information  sharing 
platforms  such  as  the  WCO  Archeo  platform  relating  to  cultural  goods,  and  the  national 
customs risk engine. 

A  Member  State  noted  that  the  customs  administration  has  succeeded  in  getting  other 
national agencies to share risk-relevant information and data. This has in turn improved the 
quality and robustness of risk criteria and analysis.  

Examples of the more general responses include responses from three (3) Member States. 
The first one stated that utilisation of risk information from other competent authorities has 
strengthened  management  of  customs  risks  and  supply  chain  security  and  that  active 
exchange of information, projects and operations allow for more targeted control measures. 
The  second  one  reported  that  among  other  benefits,  information  gathered  from  other 
authorities  and  MS  supplements  the  picture  Risk  Management  is  assembling  based  on 
intelligence retrieved from its own sources. The third one stated that overall, the measures 
taken to enhance cooperation have strengthened management and organisation of customs 
risk,  improved  the  speed  of  information  flow  and  enhanced  cooperation  with  several 
parties. 

61 

 
 
 
2.5.1.4. Encountered challenges, difficulties and barriers 

Have you encountered any significant challenges, difficulties or barriers that have kept you 
from implementing desired actions or making more progress in the cooperation with other 
non-customs competent authorities at the Member State and EU level? 

Yes 

15 

No 

8 

No reply 

2 

Fifteen (15) Member States reported they have encountered difficulties that have kept them 
from implementing desired actions or making more progress in the cooperation with other 
authorities at the Member States and EU level. Eight (8) Member States stated they have 
not encountered significant challenges in this regard. Of the Member States that did report 
difficulties,  the  themes  that  emerged  included  legal  challenges,  insufficient  human  and 
financial resources, and lacking IT developments. 

Nine  (9)  Member  States  reported  legal  challenges.  For  instance,  two  Member  States 
referred  to  limitations  to  multi-agency  cooperation  and  information  sharing  created  by 
GDPR.  One  Member  State  suggested  that  in  linking  GDPR  legislation  and  the  Union 
Customs  Code  (UCC)  it  should  be  made  clear  which  information  can  and  cannot  be 
exchanged  (not  only  via  mutual  assistance).  This  administration  stated  that  the  extent  of 
Article 46 UCC needs a more detailed clarification to provide Member States with a clear 
legal  basis to  exchange information.  One Member State referred to  obstacles in  the PNR 
directive  related  to  numerous  limitations  in  availability  and  analysis  of  passenger  data. 
Another one pointed to insufficient legal frameworks and processes to promote and support 
ongoing  actionable  cooperation  leading  to  a  lack  of  coordination  and  common  priorities. 
While  another  Member  State  reported  that  the  legal  instruments  for  administrative 
cooperation  purposes  (e.g.  for  proper  assessment  of  VAT  and  customs  duties)  are 
occasionally  incorrectly  applied  for  criminal  investigative  purposes  and  vice  versa.  They 
further  noted  that  sometimes  multiple  legal  bases  are  indicated  in  one  request  for 
assistance,  thus  leaving  it  to  the  requested  authority  to  select  the  appropriate  legal  basis. 
Additionally,  this  Member  State  noted  that  legally  stipulated  channels  of  transmission  of 
mutual assistance requests were not always respected: the Central Liaison Office regarding 
Council  Regulation  (EU)  904/2010,  the  central  excise  liaison  office  (ELO)  regarding 
Council Regulation (EU) 389/2012, and CCU17 regarding Naples II. One Member State’s 
customs  reported  that  different  interpretation  and  definition  of  legislation  language 
between customs and other agencies is a challenge, e.g. for the terms ‘import’ and ‘transit’. 

17 

The  Central  Coordinating  Unit  (CCU)  was  designed  to  provide  a  forum  for  cooperation  between  
central  customs  units  and  also  with  judicial  authorities  regarding  the  application  of  the  Naples  II  
Convention. 

62 

 
 
 
 
                                                 
  
  
To note that the Commission sent already in December 2016 a ‘Toolbox’ document to its 
services prescribing the use of the correct terminology and definitions of customs. 

Insufficient human and financial resources were reported by three (3) Member States. For 
instance, one Member State stated that there is a lack of experienced staff in specific areas 
such as intelligence and there are insufficient  resources in terms of funding, facilities, IT 
systems,  and  means  of  control.  Another  Member  State’s  customs  reported  insufficient 
capacity  of  human  resources  and  funding  in  relation  to  the  lengthy  and  bureaucratic 
process  of  developing  cooperation  agreements  and  interdepartmental  arrangements. 
Another  Member  State  stated  that  initiatives  between  customs  and  other  authorities  have 
been launched but are now in pending status due to lack of human resources on both sides. 
Therefore, major improvements related to direct exchange (electronic) of information with 
police and intelligence services had been put on hold.  

Lacking  IT  developments  was  mentioned  by  three  Member  States.  For  example,  one 
Member State stated that the customs department lack the IT facilities to assess the results 
of  risk  management  activities  specifically  for  AEO  companies.  Another  Member  State 
reported  they  have  encountered  difficulties  since  partner  competent  authorities  (PCAs) 
have  different  levels  of  IT  development,  however,  they  are  still  working  to  integrate  as 
much PCAs as possible in the single window. 

2.5.2. 

Other actions taken by the Commission under Objective 5 

  Product safety and compliance 

Under  the  current  Consumer  Programme,  EUR 15  million  is  budgeted  for  Coordinated 
Activities  on  the  Safety  of  Products  (CASP)  for  the  period  2019/2022.  The  framework 
contract  set  up  for  this  activity  includes  specific  actions  focused  at  enhancing  the 
coordination of product safety enforcement authorities, including customs.  

In the context of new Regulation (EU) 2019/1020 on market surveillance and compliance 
of  products  with  EU  legislation,  the  Commission  organised  a  joint  meeting  of  market 
surveillance  and  customs  authorities  at  EU  level  in  February  2019.  The  objective  was  to 
discuss practices and challenges in cooperation between customs and market surveillance 
in view of ensuring that unsafe or non-compliant products are more effectively identified 
and  kept  out  of  the  EU  market.  Follow-up  meetings  are  foreseen  to  support  the 
implementation of the new market surveillance framework. The launch of the EU Product 
Compliance  Network  in  January  2021  will  provide  a  new  framework  for  cooperation 
between  the  numerous  market  surveillance  authorities  in  the  EU  and  their  customs 
counterparts. 

  Wildlife 

Together  with  Interpol  and  Europol,  different  coordinated  actions  were  set  up  to  tackle 
illegal wildlife trafficking, including joint police and customs operations such as Operation 
Blizzard  in  April-May  2019,  which  targeted  the  illegal  trade  in  reptiles.  The  European 

63 

 
 
 
Commission is also developing an EU-wide database system, which will allow easy access 
for  Member  States’  customs,  and  potentially  other  enforcement  authorities,  to  permits 
issued under the EU Wildlife Trade Regulation, allowing better tracking of legal trade and 
intercepting illegal trade. 

  Forest Law Enforcement Governance and Trade (FLEGT) 

On  Forest  Law  Enforcement  Governance  and  Trade  (FLEGT),  the  Commission  updated 
the  2014  ‘Customs  and  FLEGT  implementation  Guidelines’.  The  updated  document 
‘Customs  and  FLEGT  Implementation  Guidance’18  was  published  in  January  2020  and 
also  explicitly  refers  to  the  use  of  risk  management  in  profiling  and  controls  regarding 
timber and timber products under FLEGT licensing scheme.  

Furthermore, The European Commission developed an IT system —FLEGIT/TRACES — 
for the electronic management of FLEGT licences by Member State competent authorities 
and customs authorities. 

The  EU  Timber  Regulation  (EUTR)  is  the  key  instrument  for  the  implementation  of  the 
FLEGT  action  plan,  the  aim  being  to  address  the  problem  from  the  demand  side.  EUTR 
prohibits the placing by operators (i.e. any (natural or legal) person first placing timber on 
the EU market) of illegally harvested timber on the EU market. Although the EUTR does 
not stipulate measures for border control measures, better access to customs data regarding 
the  identification  of  operators  and  relevant  import  data  from  competent  authorities  is 
essential.  This  information  exchange  will  facilitate  checks  using  a  risk-based  approach 
supporting a more effective enforcement of the EUTR.  

  IPR 

With  regard  to  IPR  infringements,  there  has  been  a  continuation  of  cooperation  and 
coordination between enforcement authorities at EU level, which has led to the seizure of 
millions  of  IPR  infringing  goods  imported  in  the  EU.  In  order  to  strengthen  customs 
enforcement of IPR, the Council adopted in November 2018 a new EU customs action plan 
to combat IPR infringements for the years 2018-2022, encompassing many actions, which 
the  Commission  is  implementing  together  with  the  national  customs  administrations  and 
which aim to tackle new challenges such as the massive flow of small consignments due to 
e-commerce. Another main objective of this action plan is to enhance risk management. A 
Customs 2020 Working Group is set up to gather IPR and risk experts from Member States 
to  enhance  the  use  of  existing  customs  risk  management  tools  and  to  strengthen  the  risk 
assessment process. 

18 

CUSTOMS  &  FLEGT  Implementation  guidance  Public  summary2020/C  20/01  C/2020/112;  
OJ C 20, 21.1.2020, p. 1–14. 

64 

 
 
 
                                                 
  
Enhanced cooperation between competent authorities is another important objective of this 
action plan, as tackling the whole supply chain  requires almost  always intervention from 
other Law Enforcement Authorities (both at the source and at the end of the supply chain). 
As data gathering and analysis is key to feed the risk management tools, the Commission is 
cooperating with the Member States and the European Union Intellectual Property Office 
(EUIPO), OLAF and Europol to see what data are available at Union level to identify those 
data  that  could  be  useful  for  IPR  risk  profiling.  The  Intellectual  Property  Crime 
Coordinated  Coalition  (IPC3),  set  up  within  the  structure  of  Europol  and  co-funded  by 
EUIPO, provides operational and technical support to law enforcement agencies and other 
partners  in  the  EU.  The  Commission  also  supports  the  EUIPO  blockchain-based  project 
‘Blockathon’19,  which  aims  to  build  a  common  blockchain  infrastructure  where 
intermediaries,  right  holders  and  law  enforcement  authorities,  in  particular  customs 
authorities, can connect  and share data to  protect the supply chains  against  infiltration of 
counterfeit goods. 

The Commission remains also focused on the dialogue with China and Hong Kong, China, 
which remain the main sources of IPR infringing goods. The spearhead in that cooperation 
remains the action plans that are established with China and Hong Kong, China.  

In  addition,  with  the  current  COVID-19  crisis,  actions  into  COVID-19  related  products 
have  emerged.  OLAF,  Europol,  the  competent  Commission  Services  (using  the  CRMS) 
and national customs administrations continue to work together to prevent goods entering 
the EU, which are sometimes infringing IPR but often worse, are substandard and thus not 
providing the required protection to the citizens. 

Finally,  in  November  2020,  the  Commission  adopted  the  IP  Action  Plan20,  which  aims, 
among  others,  to  improve  the  enforcement  of  IPR.  The  Commission  underlined  that  the 
capacity  of  law  enforcement  authorities  has  to  be  substantially  strengthened.  It  also 
recalled its support for Member States’ customs authorities in improving risk management 
and  anti-fraud  actions,  in  particular  through  the  establishment  of  an  EU  layer  of  data 
analytics capabilities, as announced in the Action Plan “Taking the Customs Union to the 
next  level”  adopted  on  28  September  202021.  The  Commission  will  establish  an  EU 
Toolbox against counterfeiting to: 

i. 

clarify  roles  and  responsibilities  of  right  holders,  suppliers,  various  sets  of 
intermediaries  (e.g.  online  platforms,  social  media,  the  advertising  industry, 
payment  services,  domain  name  registrars/registries,  and  transport  and  logistics 
companies)  and  public  enforcement  authorities  (including  customs  authorities)  to 
curb piracy and counterfeiting, and  

19  
20  
21  

https://euipo.europa.eu/ohimportal/en/web/observatory/blockathon. 
COM(2020)760. 
COM(2020) 581 final. 

65 

 
 
 
                                                 
ii. 

identify ways to reinforce cooperation between all involved players, in particular on 
sharing of relevant data on goods and traders. 

  Traditional own resources 

The  Commission  undertakes  every  year  traditional  own  resources  (TOR)  inspections  to 
Member States, in order to ensure proper and timely collection of TOR and the protection 
of  the  EU  financial  interests.  In  the  course  of  the  inspections,  the  Commission  also 
examines the structure and the functioning of the risk management system of the Member 
States in relation to the inspection theme and assesses if Member States undertake effective 
customs  controls,  following  a  risk-based  approach  and  taking  into  consideration  risk 
information provided by the Commission through RIF and AM communications.  

TOR  reports22,  describing  the  findings  of  each  inspection,  are  communicated  to  the 
Member States with relevant recommendations for specific actions. At the same time, TOR 
reports provide substantial feedback for the relevant Commission services on the actual use 
of  risk  information  by  the  Member  States  and  the  shortcomings  in  effective  risk 
management identified per Member State.  

In  particular,  TOR  inspections  in  2018  and  2019  focussed,  inter  alia,  on  the  control 
strategy  regarding  customs  value  and  the  correct  application  of  Anti-dumping  and 
Countervailing duties (ADD/CVD) concerning solar panels.  

Substantial shortcomings were identified during these TOR inspections as regards the risk 
management  of  customs  valuation  and  the  correct  application  of  ADD/CVD  for  solar 
panels and were taken into consideration by the Commission within the CRMF. The TOR 
inspections actively contributed to raise the awareness of the Member States on the topics 
inspected and according to the findings included in the TOR reports Member States were 
requested  to  take  measures  in  order  to  enhance  the  quality  and  the  effectiveness  of  the 
related  risk  profiles.  Moreover,  TOR  inspections  highlighted  the  loopholes  in  the 
implementation of relevant RIF and AM communications and cases where member States 
failed to respond effectively to the risk indicated by these communications.  

In  addition,  TOR  inspections  examined  how  Member  States  implement  risk  analysis  as 
regards  trusted  operators  and  noted  that  in  many  cases  AEOs  benefit  from  preferential 
treatment that goes beyond the relevant legislation. According to relevant TOR reports, in 
some  Member  States  AEOs  are  even  excluded  from  the  risk  analysis  system  by  way  of 
derogation, due to their status as trusted operator. These findings were also presented and 
discussed with  Member States in  a Joint Meeting of AEO network and risk  management 
experts held on 17 June 2019. 

22 

COM(2019)  601  final.  26.11.2019:  Ninth  report  from  the  Commission  on  the  operation  of  the 
inspection  arrangements  for  traditional  own  resources  (2016-2018)  Article 6(3)  of  Council  
Regulation (EC, Euratom) No 608/2014 of 26 May 2014, (OJ L 168, 7.6.2014, p. 29–38). 

66 

 
 
 
                                                 
  
  
  VAT 

In  2018,  with  the  modification  of  the  Council  Regulation  (EU)  No 904/2010  on 
administrative cooperation in the field of VAT, the cooperation between tax and customs 
authorities on VAT exempt importations (CP42 and 63) has been significantly enhanced. 
Customs  authorities  have  now  access  to  the  VAT  Information  Exchange  System  for 
validating VAT numbers at the moment of the importation and for controlling the correct 
reporting  of  these  transactions  for  customs  and  VAT  purposes.  At  the  same  time,  tax 
authorities were granted access to Surveillance 3 to identify unreported transactions. Once 
the  practice  in  using  these  tools  will  be  established,  the  communication  between  tax  and 
customs on this issue will be streamlined and fraud detection will be more efficient. 

  Waste 

See above in Section 2.4.4.3.  

  F-GAS 

See above in Section 2.4.4.3.  

  Cash controls  

Under  the  new  Cash  Controls  Regulation,  controls  will  primarily  be  carried  out  in 
accordance with the common cash movements risk criteria & standards (CMRC), and will 
take into consideration the risk assessments established by the Financial Intelligence Units 
(FIUs).  The  implementation  of  the  WCO  Customs  -  FIU  Cooperation  Handbook  is 
expected  to  further  enhance  this  cooperation  in  particular  by  ensuring  more  information 
exchange with the FIUs allowing therefore for a more targeted risk analysis.  

  Health and safety  

Health  and  safety  are  addressed  in  the  Council/EP  Regulation  on  Official  Controls.  The 
Commission  developed  delegated  acts  and  implementing  acts  for  that  Regulation.  The 
delegated acts and implementing acts have applied since 14 December 2019. 

  Official Control Regulation (OCR) 

Official controls in the area of agri-food are carried out by the competent authorities in the 
EU  countries  to  verify  business  compliance  with  the  requirements  set  out  in  agri-food 
chain legislation. 

The  agri-food  chain  encompasses  activities  preceding  and  comprising  the  production  of 
food, i.e. from farm to fork, stable to table). It ranges from plants and animal production, to 
food manufacturing  and  supply;  including activities that take place  at  the  farm level,  but 
also processing and distribution to the consumer. Agri-food chain rules therefore cover the 
safety  and  quality  of  food  and  feed,  plant  health,  animal  health  and  welfare.  They  also 

67 

 
 
 
cover  import  controls  on  animals  and  goods  entering  the  EU  from  third  countries  (i.e. 
countries outside the EU). 

The  Member  States  are  responsible  for  the  enforcement  of  agri-food  chain  legislation. 
Competent  authorities  organise  official  controls  systems  on  their  territory  to  verify  that 
operators’ activities and goods placed on the EU market (either EU produced or imported 
from  non-EU  countries)  comply  with  relevant  standards  and  requirements.  All  business 
operators  must  ensure  compliance  with  EU  agri-food  chain  requirements  in  their  daily 
activities. They are subject to official controls irrespective of their size, depending on the 
risk posed by different activities to the safety of the agri-food chain. 

The role of the EU is to assure that the control systems at national level are effective. 

The  OCR  gradually  became  applicable  with  14 December  2019  having  been  the  main 
application  date.  In  total  thirty-three  delegated  and  implementing  acts  were  developed  to 
supplement the OCR and were adopted prior to  14 December 2019. Twenty-one of those 
delegated and implementing acts are directly related to the official controls of the animals 
and goods entering the Union23. 

The OCR and supplementing delegated acts and implementing acts establish an integrated 
approach to import controls by eliminating previously fragmented requirements. Common 
rules  apply  to  official  controls  carried  out  at  borders  on  animals  and  goods,  the  latter  of 
which must be checked by the competent authorities before they enter the EU. To be noted 
that  these  ‘goods’  cover  all  products  of  the  competent  Commission  Services’  interest, 
which  include  animal  by-products,  plant  product,  food  and  feed  of  non-animal  origin, 
plastic kitchen equipment, organic products to name a few. 

New  provisions  within  the  OCR  require close  cooperation  among  competent  authorities, 
customs  authorities  and  other  authorities involved  in  the  controls  of  animals  and  goods 
entering the Union to ensure timely exchange of relevant information.  

The  OCR  requires  the  Commission,  in  collaboration  with  Member  States,  to  set  up  and 
manage  a  computerised  information  system  for  official  controls  (IMSOC)  to  manage, 
handle and automatically exchange data, information and documents in relation to official 
controls.  The import  control  system  is  more  risk-based and  targeted.  All  consignments 
presented at border control posts must undergo documentary checks. Identity and physical 
checks are  carried  out  at  a frequency  that  depends  on  the  risk  posed  by  each  category  of 
animals or goods to human, animal or plant health.  

The  IMSOC  is  to  integrate  the  four  existing  information  systems  managed  by  the 
Commission, namely the Rapid Alert System for Food and Feed (RASFF - established by 
General  Food  law),  the  Animal  Diseases  Information  System  (ADIS  -  to  be  established 

23 

https://ec.europa.eu/food/sites/food/files/oc_qa_ocregulation_20191212_delegated_implemented_acts_en.pdf 

68 

 
 
 
                                                 
pursuant to the Animal Health Law), the system for notifying and reporting pests’ presence 
(EUROPHYT - to be established by the Plant Health Law) and the TRACES platform24. 

The  OCR has  also  clarified  and  strengthened  rules  on  Member  States  cooperation  and 
administrative  assistance to  enable  Competent  Authorities  to  deal  efficiently  with  cross-
border  non-compliance.  Member  States are  now  able  to  facilitate  the exchange  of 
information  between Competent  Authorities and  other  enforcement  authorities  such  as 
public prosecutors on possible cases of non-compliance.  

The  Commission  has  started  to  tighten  the  work  and  collaboration  in  view  of  imports  of 
non-animal  origin,  to  trace those products  and uncover possible fraud and non-compliant 
products. Furthermore, through presentations in the relevant expert groups, information on 
the  Food  Fraud  Network  and  its  activities  is  made  visible  to  border  control  posts  to 
increase  the  knowledge  and  possibilities  of  exchanges  for  suspicious  foodstuffs  at  the 
relevant control points.  

2.5.3. 

The European agenda on security 

As gatekeeper for the flow of goods of the external EU borders, EU customs play a crucial 
role in protecting the EU and its citizens, as well as protecting international supply chains 
from criminal activities and terrorist attacks. By implementing the EU Strategy and Action 
Plan for customs risk management, the Commission contributes to the implementation of 
the European agenda on security, a central component of the general objective to create an 
area  of  justice  and  fundamental  rights.  The  new  EU  Security  Union  Strategy  2020-2025 
adopted  on  27 July  2020  refers  to  the  importance  of  the  security  of  external  border  and 
states that ‘Customs activities in detecting safety and security risks in all goods before they 
arrive in the EU and in controlling goods when they arrive are crucial in the fight against 
cross-border  crime  and  terrorism’  and  refers  to  the Action  Plan  on  the  Customs  Union 
which  announces  ‘actions  to  also  strengthen  risk  management  and  to  enhance  internal 
security,  including  in  particular  by  assessing  the  feasibility  of  a  link  between  relevant 
information systems for security risk analysis.’   

In addition, the Commission has undertaken a number of legislative initiatives the previous 
years with the same aim to deprive terrorist from financing sources. At the customs level, 
the following two regulations were adopted in the period 2018-2019: 

24 
As mentioned earlier, TRACES allows the monitoring of consignments of live animals and animal  
products  but  also  of  plants  and  plant  products  checked  at  the  BCPs.  It  automatically  exchanges  data  on 
import  controls  with  customs  authorities.  Together  with  the  iRASFF/AAC  and  AAC-FF,  it  allows  for 
exchanging  information  with  the  Member  States  on  possible  fraudulent  and  non-compliant  foodstuffs  and 
enabled  the  Commission  to  develop  the  EU  Single  Window  project.  The  enlargement  of  the  scope  of 
TRACES  with  regard  to  performance  of  documentary  controls  at  border  for  sanitary  and  phyto-sanitary 
reasons will result in a very high quality and quantity of information in the relevant databases, which will be 
used to perform predictive analysis on consignments to determine  the risk and streamline the  frequency of 
controls. 

69 

 
 
 
                                                 
-  Regulation (EU) No 2018/1672 of the European Parliament and of the Council on 
controls on cash  entering or leaving the European Union and repealing regulation 
(EC)  1889/2005.  It  will  enter  into  application  on  3 June  2021.  Until  then,  the 
relevant implementing acts are to be adopted.    

-  Regulation  (EU)  No 2019/880  of  the  European  Parliament  and  of  the  Council  on 
the  introduction  and  the  import  of  cultural  goods:  The  general  prohibition  rule 
prohibiting  the  introduction  into  the  customs  territory  of  the  Union  of  cultural 
goods  illicitly  exported  from  the  country,  where  they  were  created  or  discovered 
will  apply  from  28 December  2020.  From  28 June  2025,  the  import  of  certain 
categories of cultural goods will be subject to an import licence (for archaeological 
objects  and  dismembered  parts  of  monuments)  or  an  importer  statement  (for  less 
sensitive  categories).  The  adoption  of  the  relevant  implementing  act  and  the 
development of the supporting electronic system is ongoing. 

  Firearms 

In  December  2017,  the  Commission  published  an  evaluation  of  the  application  of 
Regulation (EU) No 258/2012 on import and export of civilian firearms25. This evaluation 
was  followed  in  April  2018  by  a  Recommendation  calling  for  strengthening  EU  rules  to 
improve traceability and the security of export and import control procedures of firearms 
and  the  cooperation  between  authorities  in  the  fight  against  firearms  trafficking26.  The 
evaluation identified difficulties linked to lack of exchange of information between export 
licensing  authorities,  and  between  export  licensing  authorities  and  law  enforcement 
authorities, including customs. Exports (and even more imports) of firearms are not subject 
to  sufficient  customs  supervision,  notably  during  transit.  Finally,  there  are  different 
approaches as to the notion of ‘simplified procedure’ and to the possibility to use a ‘single 
procedure’ for weapons which are also part of the EU common military list and therefore 
subject to the Council Common Position 2008/944/CFSP. 

  Interagency cooperation with border guards 

The  Commission  issued  new  guidelines  on  further  development  of  the  cooperation 
between Customs and Border Guards in December 2018. The guidelines aim to strengthen 
the importance and strategic dimension of cooperation, identify innovative and sustainable 
solutions for joined-up border management and ensure that close cooperation takes place at 
all  levels  in  both  authorities.  The  areas  covered  include  synchronised  checks  and  joint 
operations, training, information exchange, risk analysis and investigations.  

The  Commission  prepared  and  communicated  to  the  Council  Presidency  in  November 
2019 a paper on the background to the development of the guidelines and the state of play 

25 
26 

COM(2017) 737 final, 12 December 2017. 
C(2018) 2197 final, 17 April 2018. 

70 

 
 
 
                                                 
of  implementation  to  encourage  debate  and  exchange  of  views  on  implementation  issues 
among Member States. 

  Strengthening  the  EU  Authorised  Economic  Operator  (AEO) 

programme  

This shall be done through its broader  recognition by other government authorities in the 
relevant  existing  or  future  partnership  programmes  or  in  the  control  regimes  stemming 
from  other  policies.  Trade  partnership  programmes  have  been  established  by  various 
government  authorities  further  streamlining  such  programmes  with  the  AEO  programme 
potentially  allows  to  close  possible  security  gaps,  while  avoiding  duplication  of 
administrative efforts for both authorities and the operators.   

One example are the EU ICP guidelines for dual use goods.  The Technical Expert Group 
established  to  draft  EU  ICP  guidelines  for  dual-use  trade  controls,  finished  its  job  at  the 
end  of  2018.  The  final  draft  of  the  EU  ICP  guidelines  was  endorsed  by  the  Dual  Use 
Coordination  Group  in  March  2019.  Those  guidelines  were  adopted  by  the  Commission 
and  published  as  a  Commission  Recommendation  in  August  201927.  In  May  2019,  the 
Dual-Use Coordination Group mandated a new Technical Expert Group, to draft EU ICP 
guidelines  for  research  organisations  operating  in  the  field  of  dual-use  items.  The 
Technical  Expert  Group  is  expected  to  deliver  these  ICP  guidelines  for  research 
organisations by the end of 2020. 

Further  possibilities  could  be  explored  for  more  convergence  of  Authorised  Economic 
Operator (AEO) programmes and internal compliance programmes (ICPs) at Member State 
and EU level to avoid duplication of administrative efforts, while closing potential security 
gaps. 

  The  EU  Policy  Cycle  /  EMPACT  –  involvement  of  the  customs 

authorities – cooperation 

In  May  2017,  the  EU  adopted  new  crime  priorities  for  the  EU  Policy  Cycle  for  serious 
international  and  organised  crime  for  the  period  2018-2021,  better  known  under  the 
acronym ‘EMPACT’ (European Multidisciplinary Platform Against Criminal Threats). It is 
the  very  nature  of  EMPACT  to  associate  different  stakeholders  (multidisciplinary 
approach)  and  Customs  authorities’  involvement  in  its  implementation  is  still  increasing. 
One  can  note  the  participation  of  Customs  in  several  EU  Crime  Priorities  (Excise/MTIC 
fraud, Firearms trafficking, Environmental Crime, Criminal Finances, Fight against Child 
sexual abuse (CSA), etc.).  

27 

Commission  Recommendation  (EU)  2019/1318  of  30 July  2019  on 
trade  controls  under  Council  Regulation 
programmes 
OJ L 205, 5.8.2019, p. 15. 

for  dual-use 

internal  compliance  
(EC)  No 428/2009,  

71 

 
 
 
                                                 
  
  
It  is  also  important  to  take  note  of  innovative  joint  approaches,  e.g.  by  mentioning  the 
EMPACT Operational Action Plan (OAP) on “Criminal Finances, Money Laundering and 
Asset Recovery” (CFMLAR), which was jointly driven on behalf of one Member State by 
Customs and Police in 2018 and 2019 (followed by another Member State which took over 
in 2020). 

As  noted  in  the  comprehensive  assessment  of  EU  security  policy,  it  is  essential  to 
strengthen operational cooperation in the area of criminal finances by reinforcing synergies 
between customs and police. In this respect, due to their capability to detect and investigate 
suspicious  or  illicit  cross-border  transportation  of  cash,  customs  authorities  are  an 
important stakeholder for the purposes of the ‘CFMLAR’ priority.  

Some  actions,  for  example  on  developing  an  intelligence  picture  on  the  use  of  precious 
metals  and  stones  for  money  laundering  purposes  (discontinued  in  the  2020  OAP)  or  on 
cash  movements  or  on  enhancing  the  intelligence  picture  on  money  laundering  activities 
related to the trade of cultural goods, need a solid contribution from customs authorities. 

In the report on the implementation of the 2019 OAPs, it was highlighted that one of the 
aims of the CFMLAR priority should be to provide a closer cohesion between customs and 
police authorities in money laundering matters. In the same document, Europol noted that 
more  synergies  between  the  EMPACT  platform  and  the  customs-cooperation  working 
party are needed. 

Encouraging the exchange of good working practices and cooperation methods is done in 
the context of the OAPs on cannabis, cocaine and heroin as well as on synthetic drugs/ new 
psychoactive  substances.  In  addition,  cooperation  between  the  Horizontal  Working  Party 
on  Drugs  (HDG)  and  the  Customs  Cooperation  Working  Party  (CCWP)  has  been 
strengthened  over  the  last  months  as  the  latest  Presidencies  ensured  participation  and/or 
information exchange from HDG in CCWP on a more regular basis. 

The OAP for Environmental crime has made contacts and use of customs authorities. The 
OAP  has  targeted  the  increased  involvement  of  customs  authorities  as  part  of  the 
multidisciplinary  and  multi-agency  approach  involving  all  competent  authorities  such  as 
police,  customs  and  administrative  regulatory  bodies  is  crucial.  Emphasis  on  the 
prevention  and  detection  of  cross-border  crime  related  to  illegal  fisheries  and  marine 
pollution,  such  as  illegal  discharges  from  vessels,  has  required  cooperation  with  various 
authorities such as customs and maritime authorities.  

Besides  this,  in  the  area  of  combating  illegal,  unreported  and  unregulated  (IUU)  fishing 
there are challenges in information sharing, communication and reporting between customs 
authorities  and  other  stakeholders  within  a  country,  as  well  as  internationally.  The 
improvement  of  coordination  and  standardisation  of 
intelligence  sharing  among 
government agencies and other relevant stakeholders at national, regional and global levels 
is key in tackling this type of illegal activities. 

72 

 
 
 
On  Organised  Property  Crime,  the  World  Customs  Organisation  (WCO)  was  actively 
involved in at least one Operational Action (Operation Pandora for OAP 2019). The action 
addressed  trafficking  in  cultural  goods  and  heavily  relied  on  customs  cooperation.  The 
WCO also gave a presentation during an OAP drafting meeting to explain its move into the 
security  domain,  explaining  that  its  contribution  can  mainly  be  on  the  intelligence  side 
(improved intelligence picture to direct cargo controls).  

Customs  also  actively  participated  in  the  Joint  Action  Day  (JAD)  Mobile  (Organised 
Property  Crime)  in  the  2018  EMPACT  OAP  Organised  Property  Crime  (OPC).  The 
operation  can  be  described  as  follows:  ‘preparation  of  the  Joint  Action  Day  at  the  EU 
external  land  borders  and  within  the  territory  of  EU  based  on  a  joint  risk  assessment, 
targeting  various  modalities  of  motor  vehicle  crime,  including  smuggling  of  stolen 
vehicles, parts of vehicles via the EU external border and document fraud associated to the 
phenomena.  Prevention  and  detection  of  cross-border  crime,  with  focus  on  migrant 
smuggling  and  bridging  the  operational  activities  of  border  guards,  police  and  customs. 
Linking  the  detection  of  smuggled  vehicles  and  parts,  at  the  EU  external  borders,  with 
ongoing  investigations.  Additional  deployments  of  forensic  experts  and  document  fraud 
specialists at the border crossing points.’  

The  JAD  allowed  for  intelligence  collection,  intensified  control  measures  at  borders  but 
also  in-land  activities, quick queries in  the national  databases of the officers deployed in 
the Coordination Centre, set  up for the first  time at  Frontex HQ. The operation has been 
supported by the customs authorities from several countries, especially from CELBET.  

More generally, Customs are always active partners in EMPACT JADs 

Regarding  firearms,  cooperation  was  encouraged  in  the  context  of  the  Firearms  Exports 
Coordination Group and within EMPACT Firearms, where four Customs authorities from 
Member States have an active role, with other Customs authorities from third parties. Most 
national  customs  administration  remain  inactive  within  EMPACT  Firearms.  Customs  are 
also insufficiently represented in trainings on firearms provided by CEPOL.  

The level of cooperation with CCWP is good, as the EMPACT OAP Firearms driver was 
invited several  times to  share the OAPs  and pointing out  activities of special interest  for 
CCWP. Based on that the new action plan of CCWP related to firearms precisely reflected 
the  different  activities  where  the  action  plan  will  jointly  develop  it  with  the  EMPACT 
Firearms. 

In the area of firearms customs involvement is particularly relevant for several operational 
actions, notably to address the risk of trafficking of firearms through fast parcels, the threat 
of  trafficking  on  maritime  vessels  (link  with  the  WCO/UNODC  container  control 
programme)  and  for  the  development  of  a  Frontex  Handbook  for  border  guards  and 
customs officers. In the 2021 operational action plan, the Commission suggested to add a 
key  performance  indicator,  the  number  of  CRMS  messages  exchanged  in  relation  to 
firearms, in order to raise awareness about this system. 

73 

 
 
 
Funding  under  the  Internal  Security  Fund-Police  has  also  been  geared  to  support  the  EU 
Policy Cycle / EMPACT activities, with a focus on ensuring a multidisciplinary approach, 
which includes cooperation with customs authorities. 

For instance, for the field of environmental crime substantial funding has been allocated to 
actions that aim to enhance the operational activities and capacities of authorities involved 
in  tackling  waste  trafficking.  Police,  customs,  environmental  authorities  and  prosecutors 
will  benefit  from  new  methodologies  and  tools,  and  training  materials  produced. 
Cooperation  and  information  sharing  will  also  be  reinforced  through  joint  capacity-
building  activities  in  addressing  illegal  trade  and  management  of  problematic  waste 
streams. Other projects aim to boost the operational activities and capacities of authorities 
involved  in  the  fight  against  illegal  trade  and  management  of  waste,  including  customs 
authorities.  

  The Customs Cooperation Working Party (CCWP) Action Plan 

Focus on the policy area of IPR infringements has continued within the mandate for action 
in the CCWP 9th Action Plan (2018-19), under point 9.5 Fight against IPR infringements. 
Activities in this domain will continue under the subsequent action plan. 

Similarly,  CCWP  actions  have  been  developed  for  environmental  crime.  The  2020-2021 
10th  Action  Plan  includes  actions  focused  on  the  transboundary  movement  of  hazardous 
and other waste, illegal trafficking in ozone-depleting substance and on trade restrictions in 
the interest of environmental sustainability. 

Customs  authorities  have  also  been  integrated  into  the  SOCTA  reporting  mechanism 
through the dedicated action on the ‘Better integration of customs in the EU Serious and 
Organised Crime Threat Assessment (EU SOCTA)’. As a result, meetings of the SOCTA 
Advisory  Group  see  increased  customs  authorities  participation.  It  is  also  expected  that 
customs  authorities  will  provide  substantial  data  on  the  organised  crime  threats  at  their 
disposal through respective EU Member State contributions.  

Furthermore,  there  is  a  follow-up  action  in  the  10th  CCWP  Action  Plan,  which  will 
continue working on integrating indicators of importance to customs authorities, with the 
action on ‘Europol/Customs cooperation’. Its objectives include amongst others: increased 
and  improved  cooperation  between  Customs  and  other  law  enforcement  authorities  and 
ensure mutual benefit for all parties involved. 

  Modernisation of EU export control system  

The legislative process for a modernisation of EU export control system, in the form of the 
recast of the dual-use regulation, is based on the Commission proposal for a Regulation of 

74 

 
 
 
the European Parliament and of the Council, setting up a Union regime for the control of 
exports, transfer, brokering, technical assistance and transit of dual-use items28. 

In  this  proposal,  several  elements  for  enhancing  cooperation  and  information  exchange 
between customs authorities and the competent authorities of the Member States in charge 
of issuing the authorisations to export dual-use items are proposed. Further possibilities of 
cooperation  and  information  exchange  with  other  enforcement  agencies  are  envisaged  as 
well, in the form of an Enforcement Coordination Mechanism. The characteristics of such 
an Enforcement Coordination Mechanism has been furtherly discussed in the Council and 
with the European Parliament. 

Furthermore,  in  the  Council  negotiating  mandate  for  this  legislative  process,  a  provision 
has been introduced for an EU licensing and enforcement capacity-building programme, to 
be supported by the Commission and including common training programme for officials 
of the Member States. 

A joint statement on capacity-building is currently under preparation, and could be a good 
opportunity  to  develop  a  more  strength  cooperation  between  customs  and  licensing 
authorities  for  a  common  capacity-building  programme  on  dual-use  topics  (including 
information exchange and sharing of best practices at MS and EU level). 

In November 2019, during the Finnish presidency of the Council, a joint meeting between 
Customs Cooperation Working Party (CCWP) and Dual Use Working Party (DUWP) took 
place. During this meeting, some opportunities and possibility for enhancing cooperation 
between customs authorities and licensing authorities were discussed in order to integrate 
and  to  strengthen  the  information  exchange  and  the  enforcement  capacities  on  dual-use 
items. This could be a first step in view of the introduction of the envisaged Enforcement 
Coordination Mechanism not yet present in the EU dual-use legislation. 

DG TRADE is  in charge of the development  of the Dual  Use Export system with  joined 
activities with DG TAXUD to interface that system with Member States national customs 
through  the  EU  Customs  Single  Window  Certificates  Exchange  (EU  CSW-CERTEX) 
platform.  This  cooperation  is  part  of  the  establishment  of  the  EU  Single  Window 
Environment  for  Customs,  which  aims  at  facilitating  the  digital  cooperation  between 
customs and partner competent authorities at the times of customs clearance. 

28 

COM(2016) 616 final. 

75 

 
 
 
 
                                                 
2.6.  Objective  6:  Develop  cooperation  with  trade  to  secure  and  facilitate 

legitimate trade 

Improved cooperation between customs and trade is highlighted in the strategy as a mean 
for ensuring more effective risk management and facilitation of legitimate supply chains. 
Trade  cooperation  is  defined  in  the  strategy  as  including  (1)  the  customs-to-business 
concept as part of the AEO programme, which aims to achieve supply chain security to the 
benefit  of  customs  and  trustworthy  traders;  and  (2)  cooperation  with  trade  organisations 
and EOs through partnerships and other joint initiatives. 

Graph (1) AEO involvement in supply chain in 2019 per customs procedure 

100%

80%

60%

40%

20%

0%

76% 

24% 

IMPORT

83% 

17% 

EXPORT

non AEO

AEO

62% 

38% 

TRANSIT

Graph (2) Total number of valid AEO authorisations in EU 2011-2019 

76 

 
 
 
 
 
 
 
2.6.1. 

Actions taken by the Member States under Objective 6 

2.6.1.1. Activities and outputs 

Customs  administrations’  level  of  priority  of  cooperating  with  trade,  with  the  aim  to 
exploit relevant data on Economic Operators (EOs) for risk management purposes 

No activity 

Low priority 

Medium 
priority 

High priority 

No reply 

- 

2 

9 

13 

2 

Of  the  twenty-six  (26)  Member  States  that  answered  the  questionnaire,  thirteen  (13) 
Member States indicated that cooperating with trade with the aim to exploit relevant data 
on  EOs  was  given  high  priority  in  their  customs  administrations,  and  nine  (9)  Member 
States  indicated  it  was  a  medium  priority.  In  relation  to  Objective  4  and  5,  the  priority 
given to Objective 6 was slightly lower. 

Respondents were further asked to indicate the status of undertaken actions in relation to 
Objective 6 in terms of: 

  Cooperation:  including  initiatives  /  actions  taken  to  formalise  cooperation  (e.g. 
partnerships,  joint  projects)  with  trade  organisations  and/or  other  relevant 
organisations representing and/or working with EOs at the MS and EU levels. 

  Strengthening the AEO concept: 

  Efforts to raise awareness among AEOs about the benefits of AEO 
status,  e.g.  setting  up  easily  accessible  contact  points  for  AEOs  or 
other  ways  of  facilitating  communication;  or  the  introduction  of 
additional benefits relating to customs procedures. 

  Developing concepts for measuring / monitoring the implementation 
of the AEO programme, in particular with regard to its benefits for 
risk  management;  continuous  analyses  of  recorded  AEO  cases;  or 
addressing weaknesses and difficulties in the implementation of the 
programme 

As shown in the table below, nearly all Member States had ongoing or completed actions 
in all three areas. 

77 

 
 
 
 
 
 
 
 
Status of actions aimed at improving cooperation with trade in terms of the following areas 

No action 
planned 

Action 
planned 
but not yet 
started 

Action 
ongoing / 
completed 

No reply 

Cooperation 

Strengthening the AEO concept 
Efforts to raise awareness among AEOs 
about the benefits of AEO status 

Strengthening the AEO concept 
Developing  concepts  for  measuring  / 
monitoring  the  implementation  of  the 
AEO programme 

3 

2 

3 

  Cooperation 

- 

2 

2 

20 

20 

19 

3 

2 

2 

Twenty  (20)  MS  reported  ongoing  or  completed  actions  to  formalise  cooperation  with 
trade  organisations  or  other  relevant  organisations  representing  or  working  with  EOs. 
These  related  to  engaging  with  trade  and  increasing  knowledge  of  supply  chain  security, 
cooperation with postal services, agreements with trade including information sharing, and 
raising awareness of the AEO programme. 

Engaging  with  trade  to  increase  the  knowledge  of  supply  chain  security  was  reported  by 
several  Member  States.  For  instance,  in  one  Member  State,  the  National  Forum  is  a 
permanent  consultative  body within the Customs and Excise administration.  Its  members 
are  representatives  from  the  private  sector  and  representatives  of  the  administration.  The 
administration  reported  that  within  this  forum,  partnership  and  consultation  are  central. 
Actions have included improving the knowledge of supply chains, promoting compliance 
management by  customs services in  close cooperation with  the business  community, and 
promoting  the  re-use  of  customs  data  submitted  electronically  by  EOs  to  streamline 
customs procedures. One country referred to the Trade Contact Group (TCG) for customs 
established  in  2002.  It  is  a  forum  to  exchange  views,  good  practice  and  relevant 
information in the fields of customs between Customs and the private sector on a regular 
basis.  Within  this  group  joint  meetings,  training  and  seminars  are  organised.  Another 
Member State reported that customs is constantly engaging with its trader base, whether as 
a whole or at specific sub-sector level, with a view to developing and improving a shared 
understanding of and  response to  supply chain  risks.  One Member State  reported that its 
administration holds regular meetings with  trade representatives with  the aim to  improve 
cooperation, they further organise training for main stakeholders after major changes in EU 
legislation and address  Departmental Circulars to EOs informing them of new legislation 

78 

 
 
 
 
 
and  procedures.  Another  customs  authority  reported  that  in  the  preparation  of  ICS2  they 
have  established  working  contacts  with  the  EOs  concerned  in  order  to  inform  about  the 
requirements  and  coordinate  the  activities  and  timelines.  In  another  Member  State, 
consultation between customs and the business community with an international, national 
or  customs  office-transcending  character  takes  place  under  the  umbrella  of  the  national 
trade  facilitation  committee.  In  addition,  customs  participates  in  other  public-private 
partnerships  for  ports  and  airports.  Three  Member  States  reported  participation  in  the 
Smart  and Secure Trade  Lanes (SSTL) pilot  project  between EU and Asia, which allows 
testing  end-to-end  supply  chain  security  instruments  and  mechanisms  in  line  with  WCO 
SAFE Framework of Standards (FOS). 

Turning to  cooperation  with  postal  operators, one customs authority reported an ongoing 
organisational and operational cooperation project between the Ministry of Finance and the 
postal  service  to  prepare  processes  and  risk  management  for  the  implementation  of  e-
commerce and ICS2. Another Member State reported intense cooperation with the national 
postal operator and the national representative of the European Express Association (EEA) 
focused on compliance also relating to the new ICS2 requirements for safety and security, 
and the new requirements for low-value consignments (VAT package). One Member State 
reported  cooperation  with  postal  services  for  the  development  of  a  clearance  system  for 
parcel  post, the  cooperation  with  couriers has been enhanced  – providing information  on 
high-risk  consignments  at  the  time  of  importation  and  for  post  control  purposes, 
particularly  as  regards  financial  risks.  Finally,  two  other  administrations  also  reported 
cooperation  with  national  postal  services  related  to  consignment  declarations.  Several 
Member States also reported agreements with trade for access to information. One Member 
State  reported  that  in  2018  the  Customs  and  Excise  Administration  sealed  a  cooperation 
agreement with a platform of enterprises and professional associations within one port and 
within  the  setting  of  a  regional  Chamber  of  Commerce.  This  agreement  has  set  the 
framework  for  the  development  of  several  MOU  with  different  professional  associations 
representing amongst other shippers and forwarders, independent  and shipping company-
bound  shipping  agencies,  freight  handlers,  etc.  One  Member  State  referred  to  an  MOU 
with  trade  representatives  (associations,  federations,  chambers  etc.)  including  general 
issues about cooperation, and the development of a new access point for authorisation of 
traders called ‘cPortal’ for the purpose of data submitting. One Member State stated that in 
cooperation  with  the  Railways  company,  the  National  Customs  Board  now  has  access  to 
the documentation of rail freights in customs information systems. Moreover, one Member 
State  reported  they  have  formalised  cooperation  in  place  including  partnerships,  joint 
projects,  and  MOU  with  trade.  While  another  Member  State  stated  that  they  have 
cooperation  agreements  with  trade  to  strengthen  business  confidence,  and  to  promote 
compliance of EOs and facilitate administrative work. One Member State reported that  a 
national  agreement  was  signed  for  the  recognition  of  programmes  between  the  AEO 
programme and the authorities responsible for the control of chemical drug precursors, and 
a national programme agreement between the customs administration and the civil aviation 
directorate.  One  Member  State  referred  to  an  agreement  with  EOs  to  provide  relevant 

79 

 
 
 
supply chain information concerning low-value consignments by electronic means instead 
of ‘declaration by any other act’. 

  Strengthening  the  AEO  Programme  via  efforts  to  raise 

awareness among AEOs about AEO benefits  

Those  were  mentioned  by  most  Member  States.  For  example,  one  customs  authority 
reported  they  hold  regular  meetings  with  trade  aiming  at  raising  the  awareness  and 
clarifying the requirements and procedures in order to support and facilitate the application 
and  granting of AEO status.  It reported they  have held  information sessions for business 
operators in which the AEO programme and benefits were presented.  

The authorities of  another Member State reported that they  hold  meetings and talks with 
applicant  companies  and  business  associations,  in  addition  to  organising  courses  for 
officials.  In  another  Member  State,  the  customs  administration  has  organised  special 
seminars  for  business  representatives  on  obtaining  AEO  status  for  traders  at  several 
Chambers  of  Commerce,  Industry  and  Crafts  on  dual-use  goods  and  AEO,  and  freight 
forwarders / carriers on the implementation of AEO.  

One Member State’s customs have provided training for EOs in the context of Article 39 
of  UCC  (granting  of  AEO  status)  in  collaboration  with  the  Chamber  of  Commerce,  they 
have also held several meetings on demand of EOs for information purposes relating to the 
AEO programme. 

One Member State reported that in consultation with the Commission and other MS it was 
agreed that action needed to be commenced in raising awareness of the AEO programme 
amongst  traders.  As  a  result,  a  group  was  established  to  examine  communication  and 
cooperation with AEOs and awareness raising. The Member State reported contributing to 
this  work  which  is  ongoing  at  present.  The  outcomes  from  this  group  will  guide  future 
interactions  with  traders  in  relation  to  the  AEO  programme.  The  Member  State  also 
reported taking part in Trader Outreach and seminars, which assist in transmitting the AEO 
message to EOs. 

  Strengthening  the  AEO  Programme  via  concepts  for  measuring 

and monitoring its implementation  

Developing  concepts  for  measuring  /  monitoring  the  implementation  of  the  AEO 
programme  with  regard  to  its  benefits  for  risk  management  was  indicated  as  ongoing  or 
complete  by  nineteen  (19)  Member  States  and  an  additional  two  (2)  noted  that  they  are 
planning activities in the future. Activities mentioned included monitoring and analysis of 
implementation  of  the  AEO  programme  including  addressing  weaknesses  –  several 
Member States referred to monitoring and action plans including tests / monitoring visits.  

One  Member  State  mentioned  the  implementation  of  the  AEO  action  plan  developed  by 
the Commission. While another one reported that customs offices are obliged to follow an 
annual monitoring and evaluation process for all AEO authorisations. One Member State 

80 

 
 
 
reported  that  the  AEO  process  is  interlinked  with  the  risk  management  process  through 
determination in national instruction for the AEO programme and national instruction on 
the  risk  management  analysis  system.  To  facilitate  continuous  analysis,  after  an  AEO 
authorisation  is  issued,  a  monitoring  plan  is  prepared  as  determined  in  the  national 
instruction for AEO. Within the monitoring plan, the issuing authority collects information 
on  potential  risks  related  to  the  AEO’s  conditions  and  criteria  during  the  year.  This 
monitoring plan is amended annually. 

One Member State reported that the AEO area is establishing an IT monitoring plan for all 
authorisations prior to May 2016 as well as those granted after that date. The AEO area has 
re-evaluated  the  maintenance  in  compliance  with  AEO  requirements  of  all  of  the 
authorisations issued prior to May 2016. An IT monitoring plan for these and subsequent 
authorisations is being established. The processes of results of risk management measures 
applied  to  EOs,  including  AEOs,  are  reviewed  on  a  continuous  basis.  Similarly,  one 
Member State reported they are reassessing all AEO authorisations. 

Another  Member  State  reported  some  activities  in  this  regard  scheduled  for  2020:  a 
meeting  to  discuss  how  holders  of  AEO  status  should  implement  annual  monitoring 
activities  (in  relation  to  ICS2,  regularity,  documentation,  reporting);  two  internal 
monitoring activities planned specifically for AEO postal operators and express couriers to 
verify  their  internal  control  systems  to  control  low-value  consignments  entering  the 
customs territory of the Union; a joint meeting between AEO and risk management experts 
with  special  focus  on  improving  implementation  of  AEO  benefits  (the  identification  of 
risks and reduction of controls level), and reviewing the monitoring process involving risk 
management experts. 

Most respondents stated that addressing weaknesses and difficulties in the implementation 
of the AEO programme is a continuous process.  

In  one  Member  State,  there  is  continuous  monitoring  of  AEO  authorisation  procedures 
performed by local and regional offices, and periodical assessment of AEO facilitations in 
terms of risk profiles impact (numbers, type and assessed positivity of controls performed). 
Another  Member  State  mentioned  that  monitoring  the  implementation  of  the  AEO 
programme  by  the  Customs  Authorities  is  regular  and  cooperation  with  experts  (AEO, 
Risk  Management,  audit  etc.)  is  encouraged  in  order  to  deal  with  issues  that  may  arise. 
This Member State informed that a team has been established with the aim to develop and 
study several KPIs for AEOs including the proportion of declarations submitted by AEOs 
and the proportion of controls performed on them, in order to detect if problems arise.  

Similarly,  another  Member  State  reported  they  have  regular  internal  meetings  on  AEO 
issues (joint meetings between AEO, Risk Management and post-control audit teams) and 
that  regular  monitoring  visits  on  AEOs  are  completed  every  three  years  according  to  the 
EU AEO Guidelines. Another Member State reported they do regular verification checks 
of AEO holders twice per year, involving reliability tests, the results of which are also used 
for additional risk analysis. 

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The  authorities  of  one  Member  State  reported  that  their  AEO  monitoring  /  compliance 
process  is  critical  to  the  continued  success  and  functioning  of  the  programme.  This  is 
especially important for risk management and data gathering in relation to risk. New AEOs 
are monitored intensively during the first 12 months and thereafter reviews are carried out 
every  three  years,  once  the  first  12  months  of  intensive  monitoring  indicate  appropriate 
compliance.  To  ensure  compliance  with  AEO  authorisation  the  following  risk  areas  are 
included in an examination during monitoring: 

-  A physical walk through for safety and security checks 
-  Check of risks identified during the evaluation stage 
-  Selection  of  a  random  sample  of  Single  Administrative  Documents  (SAD)  for 

quality and accuracy 

-  Check of operator’s general tax compliance 
-  Reports  of  any  audits,  assurance  checks  or  aspect  queries  are  checked  for  issues 

affecting the AEO status. 

This  Member  State  informed  that  all  monitoring  actions  are  recorded  in  a  national 
database. The administration has devised a reporting template / monitoring plan for AEOs, 
which acts  as a guide to Control Officers in identifying any potential risk areas that may 
require  closer scrutiny than others. This reporting template /  monitoring  plan will evolve 
on an ongoing basis as the situation changes with the AEO. It helps identify weaknesses, 
which can be addressed at an early stage thus ensuring that they do not become a serious 
risk. This reporting / template has been identified by the Commission as best practice and 
has been recommended for use throughout the EU. 

One  Member  State  reported  that  the  implementation  of  the  AEO  programme  is 
continuously monitored by the supervision of customs offices (on-the-spot checks). There 
is  also  an  annual  workshop  for  AEO  inspectors  where  practical  experiences  and  best 
practice  can  be  shared.  At  the  national  level,  it  has  announced  a  reform  of  the  AEO 
programme, which aims to address some of the weaknesses identified by the Commission 
in  MS  practice  and  to  create  more  detailed  internal  regulations  for  more  efficient  and 
consistent regulatory work. 

Other  Member  States  reported  participation  in  project  groups  related  to  the  AEO 
programme.  

  Other 

Respondents  were  able  to  provide  examples  of  action  taken  related  to  improving 
cooperation  with  trade  that  was  not  captured  in  the  above  categories.  For  instance,  one 
Member  State  pointed  to  ongoing  analysis  in  the  form  of  a  feasibility  study  and  stock-
taking  of  requirements  concerning  the  implementation  of  a  Cargo  Community  System 
(CCS)  used  by  different  stakeholders  in  the  air  cargo  sector.  Another  Member  State 
referred  to  use  of  data  from  commercial  databases  in  the  process  of  risk  analysis  and 
management,  particularly  integrating  systems  in  the  area  of  maritime  transport.  One 

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Member  State  noted  ongoing  collaboration  with  port  authorities  and  concessionaires  of 
cargo terminals,  with  the objective of increasing the visibility of the supply chain  and to 
guarantee  its  integrity.  Some  noteworthy  examples  were  provided  by  another  Member 
State. This Member State referred to an application to face the challenge of the very fast 
increase of e-commerce shipments and to allow operators to have a level playing field with 
regard  to  customs  simplification  and  facilitation,  the  customs  developed  the  application 
which allows certified operators to upload full datasets about shipments in advance, and to 
receive  direct  notifications  when  the  goods  are  released  by  customs.  The  application  is 
only  available  for  certified  operators  with  restrictions  on  the  type  of  goods  and  range 
values.  This  customs  administration  further  referred  to  publishing  a  vision  document  for 
the promotion and use of Port Community systems as a unique interface for the exchange 
of  additional  data  and  information  with  economic  operators.  Developments  of  particular 
platforms are ongoing.  

2.6.1.2. Results 

Extent to which actions described have improved the integration / utilisation of data from 
EOs in risk management practices 

Not at all 

2 

To  a 
extent 

1 

limited 

To some extent  To 

a 

great 

No reply 

11 

extent 

7 

5 

Nearly half of respondents (11) indicated that the actions described above have improved 
the  integration  /  utilisation  of  data  from  EOs  in  risk  management  practices  in  their 
countries  to  some  extent,  and  seven  (7)  respondents  noted  a  great  improvement.  Results 
described  related  to  increased  access  to  data,  including  specifically  postal  consignments 
data, as well as increased awareness of the AEO programme and enhanced cooperation and 
communication with trade. 

2.6.1.3. Outcomes 

  Improved risk management practices 

Extent to which the actions described above have improved risk management practices 

Not at all 

2 

To  a 
extent 

2 

limited 

To some extent  To 

a 

great 

No reply 

13 

extent 

5 

4 

Half (13) of the customs administrations that responded to the questionnaire stated that the 
actions  described  under  objective  6  have  improved  risk  management  practices  in  their 

83 

 
 
 
 
 
countries to some extent, and five (5) Member States reported actions have improved risk 
management practices to a great extent. In terms of the explanations of these improved risk 
management  practices,  there  was  considerable  overlap  with  responses  to  the  previous 
question relating to results.  

In  general,  respondents  expressed  that  the  results  –  including  increased  access  to  and 
quality  of  data,  and  the  increased  awareness  of  the  AEO  programme  and  enhanced 
cooperation  and  communication with  trade  – have led to  better  focused  control activities 
and  the  facilitation  of  legitimate  trade.  For  instance,  one  Member  State  reported  that  the 
enhanced  cooperation  and  exchange  of  risk  information  between  AEO  and  risk  experts 
have helped the customs department, through risk management, to implement measures to 
avoid  unnecessary  disruption  to  legitimate  business  and  deploy  resources  efficiently  in 
areas posing the highest risks. The enhanced cooperation with trade and particularly with 
couriers has helped the department to receive information on high-risk consignments and 
perform controls at the time of importation and post controls, with good results.  

One  Member  State  reported  that  the  AEO  programme  has  strengthened  the  cooperation 
between  Risk  Management  and  the  other  units  involved  in  supply  chain  security  and 
facilitated the movement of legitimate trade.  

Another  one  stated  that  the  improvements  made  to  the  risk  profiling  system  led  to  more 
focused and less customs controls for AEOs - which supports legitimate trade and ensures 
the  protection  of  financial  interests.  Similarly,  one  Member  State  stated  that  their  work 
with AEOs has enabled them to focus control activities on high-risk areas.  

Yet again, another Member State stated that enhanced quality of data has implied effective 
targeting  and  risk  management  activities  also  in  terms  of  trade  facilitation  including  fast 
lanes and less disruptive customs controls.  

One  Member  State  reported  that  strengthened  risk  analysis  processes  at  the  notification 
stage in maritime transport have resulted in more effective control activities of the National 
Revenue Administration while supporting the activities of low-risk entities by reducing the 
burden  of  control.  This  Member  State  further  reported  that  the  legal  and  substantive 
awareness  of  enterprises  with  AEO  status  has  undoubtedly  improved  and  that  access  to 
information and regulations results in the right quality of customs operations carried out by 
the  AEO.  Because  the  knowledge  of  AEO  entities  is  constantly  updated,  the  risk  of 
irregularities involving AEO is lower compared to entities without AEO status. In addition, 
the  knowledge  of  officers  responsible  for  granting  AEO  status  has  improved,  regular 
meetings of auditors organised at central level and trainings have resulted in raising their 
knowledge  and  ensuring  uniformity  of  operations.  The  development  of  monitoring  rules 
ensures a uniform approach of customs authorities to check whether the holder of the AEO 
status  fulfils its customs duties properly  and whether internal  procedures in  the company 
that were the basis for granting the status are still observed. The above-mentioned actions 
allow for maintaining a sufficiently low level of risk of irregularities being committed by 
holders of AEO status. The lower risk level of AEO entities affects the way and criteria of 

84 

 
 
 
creating directives related to the selection of shipments for inspection. Control activities at 
AEOs also play a preventive role – the entity is and must be aware that it may lose these 
rights and privileges granted to AEOs if it violates the law. Compliant entrepreneurs also 
reduce the risk level in the supply chain. 

Another Member State again referred to  the agreement from  which they  receive relevant 
supply chain information concerning low-value consignments by electronic means instead 
of  ‘declaration  by  any  other  act’.  The  data  is  processed  by  a  dedicated  system  for  risk 
analysis  purposes.  Hence,  this  is  expanding  the  application  of  electronic  risk  analysis  to 
low-value consignments that still could be declared ‘by any other act’. By doing so, they 
contribute to  secure  and facilitate legitimate supply chains  and  at  the same time enhance 
data availability and quality. 

2.6.1.4. Encountered challenges, difficulties and barriers 

Have you encountered any significant challenges, difficulties or barriers that have kept you 
from implementing desired actions or making more progress in the cooperation with EOs? 

Yes 

11 

No 

12 

No reply 

3 

Positively,  less  than  half  (11)  of  the  customs  administrations  that  answered  the 
questionnaire  indicated  that  they  have  encountered  significant  challenges,  difficulties  or 
barriers that have kept them from implementing desired actions or making more progress 
in the cooperation with EOs. The few challenges reported varied but broadly related to IT 
systems, lack of human capacity and expertise, and legislation including GDPR. 

Challenges  related  to  IT  systems  were  reported  by  five  (5)  customs  administrations.  For 
example,  one  Member  State  stated  that  their  current  customs  clearance  system  does  not 
support  the  AEO  concept  in  a  satisfactory  way  from  an  IT-perspective.  The  customs 
department of another Member State explained that there is a weakness in the department’s 
IT  system  to  recognise  AEOs  of  third  countries  under  MRAs.  One  Member  State  also 
reported difficulties in relation to MRAs, they explained that the main difficulty arises for 
import declarations, when the depositor of the ENS who is in charge of inputting the data 
in ICS, does not use either the third party AEO MRA code or its own AEO / MRA code. 
This  Member  State  also  reported  challenges  relating  to  ICS,  including  implementing  the 
notification  of  safety  /  security  controls  for  AEO  operators  in  the  system  and  supporting 
the development of ICS2. 

The authorities of one Member State referred to the significant financial resources required 
to make changes to IT systems. While the authorities of another Member State reported no 
significant  challenges,  they  commented  that  as  the  number  of  AEOs  increases,  it  has 
become  difficult  to  monitor  them  individually,  which  requires  the  development  of  data 
processing tools that facilitate adequate monitoring. 

85 

 
 
 
 
Lack  of  human  capacity  and  expertise  was  reported  by  three  (3)  Member  States.  One 
administration stated that they have limited staff resources due to difficulties in recruiting 
qualified  staff,  and  the  training  process  for  new  staff  is  lengthy.  Another  one  referred  to 
lack of expertise in specific areas such as financial auditing and IT Security audits, while a 
third administration simply stated that they have limited human capacity. 

Challenges  related  to  legislation  including  General  Data  Protection  Regulation  (GDPR) 
was  pointed  by  two  (2)  Member  States.  One  referred  to  GDPR  as  a  barrier,  especially 
related  to  personal  data.  Since  the  e-commerce  business  model  is  business-to-consumer 
(B2C), GDPR creates a big legal barrier against cooperation and data sharing in order to 
properly  address  common  threats  at  EU  level.  While  the  second  one  reported  that  most 
challenges are related to the time needed to implement the legislation. 

Other challenges reported included for example issues related to data formats, which often 
are  not  readable  to  the  extent  desired,  as  reported  by  one  administration.  While  one 
Member  State  reported  that  inputting  information  from  EOs  in  the  risk  management 
process has low priority due to high number of ICT projects related to the UCC. 

2.6.2. 

Actions taken by the Commission under Objective 6 

2.6.2.1. e-AEO direct trader access  

The  EU  Customs  Trader  Portal  provides  a  single  point-of-access  to  the  AEO  and  BTI 
systems. The aim of this portal is to harmonise the access to different EU customs systems. 
It is expected that in the near future all other EU customs systems will be connected to this 
portal.  

The  AEO  module  (e-AEO)  of  the  EU  Customs  Trader  Portal  has  been  designed  by  the 
Commission together with the Member States and started its operation on 1 October 2019 
(for  the  first  phase)  and  16 December  2019  (for  the  second  phase).  In  the  context  of  a 
their 
paperless  environment, 
authorisations electronically via e-AEO. The e-AEO trader portal facilitates and speeds up 
the  exchange  of  information,  communications  and  notifications  related  to  AEO 
applications, authorisations and their management processes as set out in in the UCC and 
related UCC DA and UCC IA. 

their  AEO  application  and  receive 

traders  submit 

2.6.2.2. Strengthening  the  robust  implementation  and  awareness  raising  of 

the AEO programme 

The  Commission  and  the  Member  States  have  agreed  on  a  comprehensive  strategy  and 
methodology  to  improve  the  robust  implementation  of  the  programme,  including  by 
strengthening the links to customs risk management. It is also foreseen to further increase 
the  understanding  of  the  programme  through  awareness  raising  strategies  to  be  jointly 
developed with traders.    

The agreed activities include in particular fact-finding/field visits by the Commission to all 
Member  States  to  assess  how  the  AEO  programme  is  implemented,  to  identify  best 
practices that could  be used by  all Member States and to  detect  possible problems in  the 

86 

 
 
 
implementation and propose remedies. In addition, the fact-finding visits have the purpose 
to  address  the  recommendations  by  the  European  Court  of  Auditors  (ECA)  (see  ECA 
special reports n. 19/2017 and n. 12/2019). The visits started in July 2019, but have been 
disrupted  in  2020  due  to  the  COVID-19  situation  so  that  the  finalisation  originally 
scheduled by summer 2020 had to be delayed. 

First  findings  include  a  number  of  best  practices,  which  will  be  made  available  to  all 
Member  States.   Moreover,  there  are  a  number  of  weaknesses,  which  have  also  been 
identified  by  the  ECA,  and  which  relate  in  particular  to  internal  controls,  monitoring, 
cooperation between AEO and risk management services as well as the specific situation 
of  express  couriers/postal  services.  These  topics  will  be  need  to  addressed  through  inter 
alia an amendment of the AEO Guidelines and, where necessary, legal provisions. 

2.6.2.3. Detection technologies 

Any  new  emerging  technology  should  have  a  positive  impact  on  the  SMART  borders 
principle:  Secure,  Measurable,  Automated,  Risk-management  based  and  Technology 
Driven.  Under H2020 there are two important projects currently running: 

  PROFILE  

This project leverages state-of-the-art data analytics and incorporation of new data sources 
for  effective  customs  risk  management.  The  project  customises  solutions  that  build  on 
machine learning, graph-based analytics, and natural language processing, to help targeting 
officers  and  strategic  analysts  identify  high-risk  cross-border  movements.  PROFILE  also 
connects customs risk management systems to logistics Big Data and provides customs an 
improved  access  to  online  data,  especially  valuation-relevant  data  of  e-commerce  sites. 
PROFILE  also  strengthens  cooperation  and  data  exchange  among  customs  and  other 
competent authorities: PROFILE enables customs-to-customs systematic sharing of Entry 
Summary Declarations and other risk-relevant information through the EU-wide PROFILE 
Risk Data Sharing Architecture.  

  PEN-CP (Pan-European Network of Customs Practitioners) 

PEN-CP  contributes  to  the  future  of  customs  security  innovation.  PEN-CP29  collects  and 
analyses ideas and needs coming from customs security users, across six PEN-CP customs 
security  themes.  It  also  monitors  and  categorises  security  innovations  and  innovators  – 
projects,  products,  prototypes,  patents,  companies,  research  institutions,  university  labs 
etc.,  seeking  innovation  ideas  even  outside  of  customs  domain  (e.g.  police  or  forensics). 
The outcomes  are shared on the PEN-CP platform. Customs  partners can also  share user 
experiences between each other.  

29 

https://www.pen-cp.net/ 

87 

 
 
 
                                                 
The  platform  generates  matches  and  analyses  gaps  between  the  security  innovations  and 
innovators  versus,  security  user  need  ideas.  This  process  takes  place  in  the  PEN-CP 
Innovation  Funnel.  PEN-CP  facilitates  matchmaking  between  user  needs  and  existing 
solutions.  When  it  comes  to  high-priority  user  need  ideas,  PEN-CP  can  opt  to  develop 
tailored content.  

2.7.  Objective  7:  Tap  the  potential  of  international  cooperation,  to  improve 
risk  management  of  the  supply  chain,  for  better  identification  of  risks, 
more  effective  risk  mitigation  and  cost  reduction  for  operators  and 
authorities 

As  mentioned  in  the  previous  implementation  report,  cooperation  and  exchange  of 
customs-related information with third countries play an important role in the area of the 
Customs  Union and common  trade policy. Cooperation and exchange of information  can 
improve customs risk management and may make legitimate trade faster and less costly by 
targeting  customs  controls  and  simplifying  customs  procedures.  Along  with  mandatory 
pre-arrival declarations, it contributes to the security and safety of the EU by strengthening 
controls to block the entry of hazardous goods, arms, explosives and dual-use goods and to 
prevent IPR infringements and the entry and trafficking of drug precursors. The objective 
consists  in  the  development  of  international  cooperation  models  in  the  area  of  risk 
management  and  supply  chain  security,  including  AEO  mutual  recognition  schemes, 
development of trusted and fluid trade lanes and necessary exchanges of information 

2.7.1. 

SSTL  

The EU – China Smart and Secure Trade Lanes (SSTL) is a pilot project launched in 2006 
between the EU and China to  allow testing  end-to-end supply chain  security instruments 
and  mechanisms  in  line  with  the  WCO  SAFE  Framework  of  Standards30.  SSTL  aims  at 
testing  specific  safety  and  security-related  recommendations  of  the  WCO  SAFE 
Framework  of  Standards  as  regards  security  measures  applied  to  containers,  facilitating 
‘Customs-to-Customs’ data exchange, risk management cooperation, mutual recognition of 
customs controls and trade partnership programmes. The number of operators, SSTL ports 
and  trade  lanes  have  increased  over  the  years  under  the  ‘EU-China  Strategic  Framework 
for Customs Cooperation’. SSTL was expanded to other transport modes under the current 
data exchange conditions. In particular, the number of rail lanes between the EU and China 
has increased and several Member States have started air lanes. Both rail and air lanes are 
mostly operated in the e-Commerce context. Two e-Commerce platforms have also joined 
SSTL, thereby facilitating tackling high volume items. 

30 

In June 2005, the WCO Council adopted the SAFE Framework of Standards to Secure and Facilitate  
Global  Trade  (SAFE  Framework)  that  has  the  objective  to  deter  international  terrorism,  secure  
revenue collections and promote trade facilitation worldwide.  

88 

 
 
 
                                                 
  
  
 
Eight (8) Member States are currently actively participating in SSTL to introduce ways to 
facilitate  and  speed  up  the  entry  processes  of  consignments  moved  by  trusted  traders 
allowing them to enhance the security, while facilitating and accelerating the Customs exit 
and entry processes.   

SSTL cooperation is on a voluntary basis and one-third of the MS participate with different 
levels of commitment.  

SSTL  is  an  example  of  the  kind  of  customs-to-customs  information  exchanges  that  is 
interesting in implementing on a broader basis. A current  challenge is the lack of a legal 
basis  for  SSTL  with  China  and  Hong  Kong,  meaning  it  cannot  be  scaled  beyond  the 
current pilot project status.  

2.7.2. 

Bilateral relations 

  Exchanges of information 

The lack of a legal basis for systematic exchanges of customs information between the EU 
and  third  countries  can  be  an  obstacle  to  potential  risk  management  cooperation.  In 
general,  the  EU  takes  a  more  cautious  approach  compared  to  other  trading  partners  over 
data  exchange,  data  mining  and  processing.  For  example,  difficulties  may  arise  in  the 
organisation of AEO data exchange with third countries because of the need to be in line 
with EU data protection. The EU therefore currently uses the opportunity of ongoing Free 
Trade Agreement negotiations with third countries to introduce a legal basis allowing for 
bilateral exchanges of information. 

  Customs security agreements 

Since  2016,  the  Commission,  together  with  Switzerland  and  Norway,  has  conducted 
preliminary  discussions  in  view  of  updating  the  legislation  of  the  customs  security 
agreement on the simplification of inspections and formalities in respect of the carriage of 
goods and on customs security measures, which entered into force on 1 July 2009. 

These Agreements are based on the principle that both Switzerland and Norway, together 
with the EU, set up and apply the same security measures to the carriage of goods to and 
from third countries as the EU, thus ensuring an equivalent level of security at the external 
borders. By integrating these two Parties in the future participation in the Import Control 
System 2 (ICS2), the AEP programme and the update risk management framework, there 
will  be  an  equivalence  of  security  and  safety  measures  fully  complied  at  the  external 
borders.  

  EU - Norway dialogue on dual use. 

A dialogue with Norwegian Ministry of Foreign Affairs, the competent authority for dual-
use  items,  is  currently  in  place.  In  this  agreement,  an  information  exchange  on  the 

89 

 
 
 
 
implementation  of  dual-use  export  controls,  on  licensing  data  and  denials  issued  both  in 
EU  and  in  Norway  is  foreseen.  Within  the  framework  of  this  agreement,  the  EU  has 
granted  access  to  Norwegian  competent  authorities  to  the  Dual  Use  electronic  System 
(DUeS)  in  order  to  enhance  the  information  exchange  on  denials  and  the  bilateral 
consultations between Norway and EU Member States. 

Similar  initiatives  could  be  envisaged  in  order  to  enhance  cooperation  with  Norwegian 
authorities (licensing and customs) on dual-use topics. 

  Belarus 

An EU-Belarus project group – Customs Dialogue, has implemented its action plan up to 
2020 and has also agreed on a new action plan from 2020 to 2023. The next major step will 
be  the  start  of  the  negotiations  on  an  Agreement  on  Customs  Cooperation  and  Mutual 
Administrative Assistance.     

  Ukraine 

An Association  Customs Subcommittee led the work for the  approximation of Ukrainian 
legislation  in  the  fields  of  transit,  Intellectual  Property  Rights,  Authorised  Economic 
Operators  (AEO).  Cooperation  continues  to  implement  the  approximated  legislation  and 
assisting  Ukraine  joining  Common  Transit  Convention  (CTC)  and  NCTS.  Ukraine  is 
interested to have mutual recognition of AEOs, which could be assessed in one year time 
after the start of the implementation of Ukrainian AEO programme 

  Russia 

The  strategic  framework  for  EU  —  Russia  customs  cooperation  includes  the  following 
objectives:  (i)  trade  facilitation  on  the  basis  of  operator  reliability:  (ii)  identify  the 
possibility  of  creating  an  EU-Russia  expedited  lines  initiative  on  a  voluntary  basis  for 
Member States;  

 A  meeting  of  the  EU-RU  Working  Group  on  border  issues  was  held  in  Brussels  on 
15 November  2018.    The  last  bilateral  meeting  took  place  on  24-26 October  2019  in 
Moscow in  the framework of the  International  Customs Forum  organised by the Russian 
Customs. The next meeting of the Working Group is not foreseen in near future due to the 
COVID-19 situation and broader context of bilateral EU-RU cooperation.  

The Commission plans to organise a meeting with Member States to discuss their current 
positions on a possible future customs cooperation with Russia (postponed due to COVID-
19 travel restrictions). 

  Moldova 

In March 2020, the EU and Moldova have updated and agreed on the action plan for EU - 
Moldova MRA.  

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The last Customs Subcommittees took place on 21 November 2019 and on 25 November 
2020. The EU has verified the Moldovan legislation and has sent its recommendations to 
the  Moldovan  Customs  service.  The  EU  has  also  prepared  and  sent  to  Moldova  an 
Interface Control Document (ICD) explaining the data specification and platform that need 
to be in place for MRA AEO. Moldova and Romania are continuing an AEO pilot project 
on unilateral recognition of EU AEOs.   

  Georgia  

The Customs Subcommittee took place on 5 June 2020.  

Georgia has adopted a national customs code fully in line with the UCC and is currently 
working  on  the  implementation  of  this  code.  Georgia  has  started  working  on  the 
deployment of NCTS 5, which is a necessary step for its accession to the Common Transit 
Convention. Georgia has expressed its interest in an AEO MRA with the EU.  

  United States 

The  cooperation  with  the  US  is  wide  in  scope,  ranging  from  the  mutual  recognition  of 
AEOs to dialogues under the Joint Customs Cooperation Committee ('JCCC'), responsible 
for overseeing the implementation  and ensuring the proper functioning of the agreement. 
Recent work conducted under the 2016 JCCC cooperation agenda included exchanges on 
the  development  of  single  window  systems.  IT  exchanges  related  to  AEO  mutual 
recognition have encountered some technical difficulties. 

  Canada 

Cooperation  is  based  on  the  1998  Agreement  on  Customs  Cooperation  and  Mutual 
Administrative Assistance in Customs Matters. Recent focus has been on the conclusion of 
work  on  the  mutual  recognition  of  the  EU  and  Canada  AEO  programmes,  expected  in 
2021.  Previous  exchanges  in  the  Joint  Customs  Cooperation  Committee  also  include  air 
cargo security.  

  China 

Cooperation  is  based  on  the  2004  EU-China  Agreement  on  Cooperation  and  Mutual 
Administrative  Assistance  in  Customs  Matters  and  the  2018  Strategic  Framework  for 
Customs  Cooperation,  soon  to  be  renewed.  It  is  managed  by  the  Joint  Customs 
Cooperation  Committee  and  its  Steering  Group.  Cooperation  areas  include  SSTL,  AEO 
mutual recognition, IPR enforcement, fight against fraud and risk management. 

  Japan 

During  the  9th  Joint  Customs  Cooperation  Committee  in  June  2019,  the  EU  and  Japan 
discussed the need to move towards a more operational phase and concrete results on risk 
management. To this end, a meeting of AEO and risk management experts was scheduled 
for  March  2020,  but  was  postponed  due  to  COVID-19.  On  AEO  MRA  with  Japan,  it  is 

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essential to ensure the compatibility of IT systems and or data models to ensure continued 
exchange of data. 

3.  INPUT  FROM  MEMBER  STATES  TO  SUPPORT  FUTURE 

DEVELOPMENTS FOR THE POST-2020 PERIOD  

3.1.  Main  achievements  through  the  current  Risk  Management  Strategy, 

according to the Member States 

Extent  to  which  the  current  strategy  is  used  to  guide  action  taken  to  improve  the 
management of customs risks 

Not at all 

1 

To  a 
extent 

2 

limited 

To some extent  To 

a 

great 

No reply 

12 

extent 

11 

- 

Nearly all respondents indicated they use the strategy to guide action taken to improve the 
management of customs risks - 10 customs administrations indicated they use it to a great 
extent and 12 to some extent. 

Respondents  were  then  asked  to  comment  on  the  role  and  main  achievements  of  the 
strategy since its adoption in 2014 and if or how this has changed over its duration. They 
were  asked  to  describe  the  strategy’s  role  and  main  achievements  in:  (1)  improving  the 
management of customs risk on a national  level; and (2) improving the coordination and 
harmonisation of customs risk management at the EU-wide level. 

3.1.1. 

At the national level 

Respondents varied in their views of the strategy’s role and achievements at national level. 
Nonetheless, several themes emerged. Respondents attributed certain achievements to the 
strategy.  For  example:  increasing  awareness  of  risk  management  within  national 
administrations  and  galvanising  support  for  making  risk  management  a  bigger 
priority.  

Member  States  also  mentioned  several  of  the  main  progress  areas  under  objectives  4,  5 
and 6.  These  included  enhanced  IT  systems  and  risk  engines  resulting  in  better  risk 
management,  and increased cooperation and sharing of risk information  leading to  better 
targeted controls and facilitation of legitimate trade.  

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However,  respondents  rarely  gave  details  on  the  relative  importance  of  the  strategy 
compared  to  other  factors  such  as  EU  interventions,  tools  such  as  ICS  and  CRMS,  and 
national priorities or initiatives.  

On the role of the strategy at national level, most Member States noted that it is integrated 
in and in line with national risk management strategies. However, some considered it more 
as a background document. 

Increased  awareness  of  risk  management  within customs administrations and  galvanising 
support  for  making  risk  management  a  bigger  priority  was  highlighted  as  one  of  the 
strategy’s main achievements by five Member States.  

One national customs administration stated that the strategy has changed its understanding  
of  the  role  of  risk  management  and  its  importance  in  customs  activities.  As  a  result,  the 
administration was able to employ more staff and received funding to strengthen the risk 
management  division  and  make  improvements  to  the  national  risk  engine.  The  risk 
management  division  has  become  involved  in  changing  and  modernising  all  the  main 
customs working processes.  

One  Member  State  mentioned  that  the  strategy  had  led  to  funding  for  the  further 
development of the risk management IT system, and another one said that it had increased 
awareness  of  common  risk  areas  and  improved  risk  management  capacities  in  general. 
Another  Member  State  mentioned  that  the  strategy’s  primary  benefit  is  that  it  brings 
together  the  vast  range  of  individual  risk  management-related  programmes  and  activities 
into  a  single  structure.  This  has  improved  visibility  and  helped  illustrate  the  all-
encompassing  nature  of  the  risk  management  agenda.  The  strategy  can  also  help  to 
prioritise related initiatives. 

On the role of the strategy at national level, the authorities of one Member State reported 
that  it  has  provided  their  customs  administration  with  a  tool  for  reviewing  risk 
management procedures and processes to achieve a higher level of performance. Another 
Member State said that priorities and key issues included in the Strategy were integrated at 
national  level  in  the  strategy  of  its  State  Revenue  Service.  Under  this  national  strategy, 
tasks were defined to achieve the EU Strategy goals. 

Achievements which were mentioned previously as progress under the objectives included: 

  Enhanced  IT  systems  and  risk  engines  resulting  in  better  risk  management 
(mentioned  by  eight  Member  States).  For  instance,  one  national  customs 
administration said that thanks to the strategy it had improved its risk management 
system  by:  (i)  adding  new  data  sources  for  automated  data  comparison;  (ii) 
adopting new and more sophisticated methods for the creation of risk profiles; and 
(iii) assessing the risks of new types of declarations. 

  Enhanced cooperation (reported by four Member States). For instance, one referred 
to strengthened interagency cooperation and strengthened cooperation with trade. 

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 

Increased  exchange  of  risk  information  (mentioned  by  five  Member  States).  For 
instance,  a  key  achievement  highlighted  by  one  of  them  was  the  systematic 
approach  to  the  regular  exchange  of  risk  information  through  the  CRMS  and 
subsequent evaluation, implementation of measures, and regular monitoring of the 
results of the implemented measures. 

  Enhanced  cooperation  and  information  sharing,  which  has  resulted  in  better 
targeted controls and the facilitation of legitimate trade (mentioned by five Member 
States).  For  instance,  one  Member  State  stated  that  one  of  the  strategy’s  main 
achievements  has  been  to  promote  a  balance  between  legal  trade  facilitation  and 
effective customs controls, and that better targeted controls have improved revenue 
collection and the tackling of risks. 

A minority of Member States noted that the strategy had had a less prominent role in their 
customs administrations. For instance, one administration stated that their national annual 
enforcement planning is based on the input received from the principal ministries and that 
this input is not necessarily in line with the EU strategy.  

One  Member  State  noted  that  initiatives,  developments,  and  projects  to  improve  risk 
management are driven by legal obligations (e.g. the UCC) and the need to solve problems 
related  to  new  realities  (e.g.  e-commerce),  but  that  the  strategy  as  such  is  not  taken  into 
account when setting priorities.  

Similarly, another Member State explained that the strategy serves as an internal exercise 
for  the  customs  administration  to  implement  its  principles,  but  that  it  has  not  received 
much visibility or prioritisation at national level. 

3.1.2. 

At the EU level 

Generally, Member States reported that the strategy has improved the coordination and 
harmonisation  of  customs  risk  management  at  EU  level,  but  they  had  difficulties  in 
distinguishing between the strategy  and other EU-level  initiatives  mentioned therein.  For 
example,  several  Member  States  mentioned  the  CRMF  (the  CRMS  and  common  risk 
criteria) and the upcoming implementation of ICS2 as the main achievements. 

On  improving  the  coordination  and  harmonisation  of  customs  risk  management  at 
EU level, according to the authorities of one Member State, the strategy’s role has been to 
help  develop  common  work  procedures  and  a  common  approach  to  risk,  and  to  increase 
efficiency  and  efficacy  by  enabling  the  fast  exchange  of  information.  These  common 
work procedures and the common approach to risk management were mentioned by 
six other Member States.  

For instance, one of them stated that the Strategy is a useful tool where for the first time all 
relevant  activities  connected  to  or  interlinked  with  risk  management  are  concentrated  in 
one place – the seven main objectives and more than 50 sub-actions show the complexity 
and comprehensiveness of the risk management agenda and its intersections into almost all 
customs  areas.  The  authorities  of  another  Member  State  mentioned  the  strategy’s  central 

94 

 
 
 
role in improving the coordination and harmonisation of customs risk management at EU 
level, as it provides national customs authorities with a common and coordinated approach 
to  risk  management  activities  and  ensures  more  effective  cooperation  between  Member 
States. A third Member State mentioned its key role in aligning efforts to improve customs 
risk management at EU level. A fourth noted that, although the strategy has brought about 
a great improvement, it should have been given more attention and visibility. 

Under the CRMF, CRMS and the common risk criteria were highlighted as being among 
the  great  achievements  by  11  Member  States.  One  of  them  explained  that  as  organised 
crime  switches  between  fraud  schemes  and  Member  States  very  fast,  common  rules  and 
guidance to identify and tackle all kind of customs risks are needed. Another stated that it 
is  essential  to  have  a  commonly-agreed  strategy  to  follow  in  a  matter  of  such  scale,  and 
referred  to  the  decision  on  financial  risk  criteria  and  the  related  guidance  aiming  at 
equivalent controls at EU-level as key CRMF milestones. 

The upcoming implementation of ICS2 was also mentioned by seven Member States as an 
aspect  that  will  considerably  improve  risk  management  in  the  EU  and  nationally.  For 
example, one Member State stated that developing a common EU entry system (ICS2) and 
common  risk  analysis  system  with  all  the  planned  functionalities  will  be  the  biggest 
achievement.  Another  one  stated  that  the  ICS2  project  can  be  considered  as  an 
‘embodiment of the strategy in the IT dimension’.  

3.2.  Key challenges currently faced in customs risk management 

Under  this  question,  respondents  were  asked  about  the  main  customs  risk  management 
challenges (both internal and external) currently faced by their administration. Challenges 
were defined as issues that affect administrations’ ability to achieve effective customs risk 
management, strengthened supply chain security and/or the facilitation of legitimate trade.  

3.2.1. 

Internal challenges 

The internal challenges mentioned related to: 

 
 

 

IT, e.g. outdated equipment and the high costs of setting up new IT systems; 
lack  of  human  resources  and  expertise,  e.g.  an  ageing  customs  workforce  and 
limited ability to attract new staff; 
lack of financial resources, e.g. related to both IT systems and staff. 

3.2.2. 

External challenges 

The  external  challenges  mentioned  were  due  to  constraints  and  barriers  outside  of  the 
customs  administrations’  control,  such  as  wider  political  developments,  economic  and 
trade trends, and new security threats - the main ones being: 

 
the increased volume of trade;  
  dealing with new security threats;  
  data protection requirements / poor-quality data. 

95 

 
 
 
Eight Member States reported an increasing volume of trade as one of the main external 
challenges faced by their customs administrations. For instance, one Member State noted 
that  the  ongoing  growth  in  world  trade,  particularly  the  increase  in  small  consignments, 
can  challenge  even  the  capacities  of  electronic  systems.  One  Member  State  specifically 
mentioned  e-commerce,  whose  increased  share  could  hamper  the  effectiveness  of  risk 
management. 

One  Member  State  considered  the  main  challenge  to  be  the  fast  emergence  of  new 
business models, which affect the speed, demand and characteristics of international trade. 
The switch between business-to-business (B2B) models with big cargo loads, to business-
to-consumer  (B2C)  and  consumer-to-consumer  (C2C)  models  is  a  huge  challenge  for 
customs administrations.  

The  dividing  up  of  cargo  into  small  packages  and  the  diversification  of  consignments 
(from millions to billions) - many of which customs have never dealt with before - requires 
new  approaches,  strategies  and  operational  and  technological  skills  (including  AI,  the 
internet  of  things  (IoT),  and  machine  learning)  by  customs  authorities  and  their  risk 
management systems. One customs administration noted that these challenges need to be 
dealt  with  at  EU  level,  swiftly  and  with  a  top  down  approach,  in  order  to  achieve 
equivalent  levels  of  control  and  integrity  of  the  supply  chain  along  the  EU’s  external 
borders. 

Dealing  with  new  security  threats  was  mentioned  as  a  challenge  by  six  customs 
administrations. In this regard, one Member State mentioned the increase in illegal online 
trade,  related  to  fraud,  economic  and  narcotic  offences  and  identity  theft.  Another 
mentioned new security threats, such as terrorism, hazardous substances and ensuring the 
safety of the population. A third mentioned the very rapid spread of new information and 
communication  technologies  which  implies  quick  changes  of  threats  and  reactions  to 
countermeasures implemented by customs. These threats are often linked to the activities 
of criminal networks that master technology increasingly well – customs authorities must 
therefore  constantly  reinvent 
that  appear.  One 
administration pointed to the threat of COVID-19. 

to  face  new 

themselves 

threats 

Data  protection  requirements  or  poor-quality  data,  sometimes  due  to  a  lack  of 
cooperation,  was  highlighted  as  a  challenge  by  four  Member  States.  One  noted  that  the 
efficiency  of  risk  management  and  controls  related  to  other  non-customs  policy  areas 
depend on the input received from other competent authorities. If cooperation turns out to 
be  difficult,  the  outcome  of  risk  management  is  irrelevant.  Similarly,  another  Member 
State  referred  to  data  protection  requirements  (GDPR)  and  limited  willingness  of  other 
institutions  to  communicate  and  share  data.  In  terms  of  data  quality,  one  Member  State 
mentioned a lack of standardisation of data on customs declarations in Member States, e.g. 
address details; such standardisation is essential to conduct data mining. They also referred 
to  a  lack  of  a  sufficient  number  of  validation  rules,  e.g.  goods  nomenclature.  The 
authorities noted that data quality needs to improve and suggested this can be achieved by 

96 

 
 
 
cooperating with trade e.g. postal services, to raise awareness and provide declarants with 
the necessary understanding. 

Some Member States advocated for a more coherent approach to risk management at EU 
level.  One  noted  that  the  priorities  of  different  EU  or  national  authorities  do  not  always 
align  and  that  certain  activities  can  only  be  carried  out  when  both  sides  have  the  same 
priorities  and  capacities.  One  administration  expressed  they  want  to  see  a  consistent 
approach  which  is  communicated  in  a  clear  manner  to  Member  States,  referring  to  the 
various  pathways  that  the  EU  Commission  pursues  in  meetings  and  projects  related  to 
different  risk  management  matters.  One  Member  State  considered  the  main  external 
challenge  to  be  the  complexity  of  Commission  guidelines  and  a  lack  of  guidance  on 
common standards. 

Other  external  challenges  mentioned  included  delayed  IT  projects  and  dealing  with  the 
implications of Brexit. 

3.3.  Priorities for the future 

3.3.1. 

Customs administrations’ priorities 

A high priority, mentioned by 15 Member States, is to enhance risk analysis capabilities, 
including by improving or developing new national risk engines and improving human risk 
analysis  capabilities.  This  includes  adding  new  functions  to  risk  management  engines, 
employing  data  analysts,  and  using  new  working  methods  and  technology  including 
datamining and AI. Another key priority is to launch new IT projects, notably ICS2. Others 
include increasing cooperation (including data sharing) and mitigating specific risks related 
to e.g. e-commerce and financial risks. 

One Member State stated that they are prioritising improvement of their risk management 
engine  by  enhancing  the  use  of  new  technological  developments  like  predictive  analytic 
instruments.  Another  plans  to  develop  the  risk  analysis  concept  by  setting  up  new 
collaborative and multidisciplinary teams made up of specialists in data analytics (which is 
currently a rare skill in customs), risk analysts and risk managers, and providing them with 
new  modern  tools  and  techniques  (e.g.  machine  learning,  neural  networks  and  other 
advanced  analytics)  to  properly  address  the  new  challenges.  Another  Member  State  will 
continue to use datamining techniques in risk management to help select the foreign trade 
operations  to  be  controlled.  Two  Member  States  specifically  mentioned  the  use  of  data 
analysis  methods  and  AI.  The  authorities  of  one  of  them  also  mentioned  ensuring  the 
interoperability  of  systems  -  principally  in  the  area  of  justice  and  home  affairs  (Europol 
and the Schengen Information System). 

Another Member State is prioritising updates of the current import declaration system AIS, 
the  NCTS  system  for  phase  5,  and  the  AES/ECS  system.  The  administration  of  another 
Member State reported that their priority for the next years is to further develop their risk 
engine, adding ICS2 related functions and interfaces linked to other customs and external 
data  sources  and  relevant  functionalities  of  automated  analysis,  in  addition  to  employing 

97 

 
 
 
additional personnel, especially for ICS2 purposes. The main priority for another Member 
State  is  to  develop  and  introduce  into  the  risk  management  system  more  data  analysis 
techniques.  These  should  in  turn  act  as  a  tool  to  better  understand  fraud  patterns  and 
predict emergent and new risks. 

Launching  new  IT  projects,  particularly  ICS2,  was  mentioned  as  a  priority  by  10 
Member  States  -  even  as  the  main  priority  by  some  of  them.  For  instance,  one  Member 
State said that in the short term it aims to ensure that it can cope with release 1 of ICS2, 
and in the medium term to have the necessary human and IT resources for releases 2 and 3. 
Another reported that its main customs risk management priority is to develop an IT entry 
system to implement ICS2. 

Cooperation - including on data sharing - was mentioned as a priority by eight customs 
administrations.  For  instance,  one  stated  that  its  priorities  for  the  coming  years  include 
data-driven risk analysis, more generalised sharing of datasets between European customs, 
and sharing of knowledge of datamining models and profiles, as well as prioritising access 
to reliable and real-time data on the global supply chain. Another Member State noted that 
to perform effective risk management customs needs to know ‘who’ is moving ‘what’, to 
‘whom’, from ‘where’ – data on the real parties behind the transaction (buyer and seller or 
owner)  and  the  routing  of  the  goods  throughout  the  supply  chain  involved,  is  crucial.  It 
further  stressed  that  it  is  also  critically  important  that  this  data  is  available  as  early  as 
possible, is relevant and of high quality  - this is fundamental to risk management but the 
current  input  data  does  not  meet  minimum  requirements.  This  administration  explained 
that in this context, the AEO programme adds value but has limitations when it comes to 
the e-commerce B2C business model. This is due to the consignments mainly being small 
and delivered through the international postal supply chain and air express. To address this 
specific  issue,  the  administration  reported  they  are  cooperating  with  the  major  online  e-
commerce platforms in order to receive transactional payments data to overcome poor data 
quality and to perform effective risk management.  

One customs administration stated that it would continue the operational collaboration and 
MOU with the border police. Another Member State stated that they aim to develop further 
interagency cooperation with other authorities in the area of product and health safety, and 
enforcement  and  security.  Another  administration  mentioned  that  its  main  priorities 
include  operational  cooperation  with  Member  States  that  face  similar  challenges  as  them 
(e.g.  large  seaports  and  e-commerce),  as  well  as  cooperation  with  third  countries  in  the 
supply  chain.  One  Member  State  also  referred  to  cooperation  with  third  countries  and 
specifically  mutual  data  exchange  agreements  that  allow  the  immediate  and  systematic 
monitoring  of  specific  shipments  from  notification  of  exports  in  a  third  country  to  an 
import procedure in the EU. 

Risk mitigation of specific risks including e-commerce and financial risks is a priority 
in six Member States. The rapid increase in the volume of e-commerce was highlighted as 
a priority by the six customs administrations. On financial risks, three of them highlighted 
mitigating risks of undervaluation as a key priority. One Member State also referred to the 

98 

 
 
 
implementation  of  the  ‘fuzzy  random  method’  in  risk  mitigation  measures.  Another 
Member  State’s  main  priority  is  the  implementation  and  testing  of  newly  deployed 
technical solutions and significant changes in existing systems in connection to FRC. 

3.3.2. 

How a successor to the strategy could support the priorities of 

Member States 

The last question in the questionnaire asked respondents their views on how a successor to 
the  strategy  could  best  support  the  priorities  of  national  customs  administrations, 
considering  the  challenges  and  priorities  described  above  to  strengthen  customs  risk 
management.  Responses  to  this  question  broadly  related  to  ensuring  the  availability  and 
quality  of  data,  development  /  revision  of  common  risk  analysis  supporting  tools,  and 
training for data analysts at EU level. 

  Ensuring the availability and quality of data.  

One  Member  State  suggested  that  a  successor  strategy  should  focus  on  strategic  or  legal 
incentives  for  enhancement  and  support  for  the  exchange  of  risk  information  among 
Member  States.  Another  suggested  more  ambitious  actions  to  increase  this  information 
sharing  amongst  EU  Member  States  including  the  increased  use  of  CRMS.  The  same 
administration  also  suggested  to  focus  on  improving  data  quality  and  ensuring  the 
availability  of  data  and  risk-relevant  information,  which  depends  on  the  development  of 
the necessary IT systems.  

The  administration  of  one  Member  State  emphasised  that  the  ICS2  project  represents 
progress in terms of collaboration between Member States on risk analysis. However, they 
noted  that  safeguards  on  the  transmission  and  use  of  data  will  need  to  be  ensured.  Two 
other Member States also stated that cooperation should be ensured.  

One  Member  State  suggested  that  the  entire  strategy  should  have  a  solid  legal  basis, 
particularly  for  cooperation  and  data  and  information  sharing  among  national  and  EU 
bodies  so  as  to  overcome  the  GDPR  barrier.  Another  suggested  that  a  successor  to  the 
strategy  should  support  national  interagency  cooperation  by  promoting  cooperation  at 
relevant  Commission  DG-level,  as  they  explained  that  sometimes  there  is  a  need  of  an 
initiative ‘from the top’. 

  Development / revision of common risk analysis supporting tools  

This  was  suggested  by  four  Member  States.  One  noted  that  at  a  time  of  exponentially 
increasing volumes, old  techniques may no longer be appropriate risk management tools, 
the tools of the future should therefore be a core element of any future strategy. Another 
suggested that sufficient resources should be made available and greater emphasis should 
be placed on developing of central  EU applications such as a single system  for targeting 
shipments at EU level.  

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  Training for data analysts at the EU level  

This was suggested by four Member States. One explained that a focus on additional ways 
of  sharing  best  practices  and  expertise  among  Member  States  would  further  strengthen 
capacities,  and  human  resources  training  in  risk  management  related  areas  such  as  data 
analytics should continue. Another suggested training courses coordinated at EU level on 
‘big data’ analysis technology. A third stated that targeted training for Member States’ data 
analysts  /  scientists  and  setting  up  an  EU  multidisciplinary  expert  team  including  data 
analysts / scientists and risk experts would be a great support. 

Two administrations  mentioned the need to  address  rising  threats  related to  e-commerce, 
while other responses were less specific.  

For example, one Member State noted that a successor of the strategy must not stand in the 
way of developments that must occur in response to unforeseen developments, and that the 
focus should be on the follow-up of Objectives 1, 2 and 5 of the current strategy.  

Another Member State suggested that a successor should build upon the previous approach 
and the progress achieved, as the main objectives are still vital but they need to be updated 
or redefined in line with current and future legislative, business and technical requirements 
with  regard to  data quality, information sharing,  capacities and cooperation (interagency, 
with  trade, and international). Another  administration suggested it could  focus on certain 
key elements instead of attempting to depict a larger scale of objectives. 

One  Member  State  considered  an  update  of  the  action  plan  to  be  necessary,  whereas  the 
strategy  itself  could  continue  for  a  few  years  without  major  revision.  Another  noted  that 
risk  management  is  a  process  that  is  not  limited  to  specific  actions  with  a  definitive 
beginning and end. Faced with new threats and challenges, customs must continuously act 
and adapt to contribute to the security and safety of EU citizens, while avoiding any undue 
negative impact on the fluidity of international trade. Several of the strategy’s actions are 
marked  as  being  ‘in  progress’  as  they  cannot  have  set  deadlines  due  to  their  continuous 
nature.  

One  respondent  expressed  the  belief  that  the  strategy  should  be  revised  and  updated  in 
view of new realities and what has already been accomplished, and that updates should be 
in line with the upcoming Customs Action Plan, which will likely consider the importance 
of  customs  risk management  and  the  interoperability  of  security  and  border  management 
and customs IT systems. 

100 

 
 
 
 
 
4. PERFORMANCE AND MONITORING FRAMEWORK 

In the Council Conclusions on the second progress report on the strategy, the Commission 
was  invited  to  develop  in  close  cooperation  with  Member  States,  based  on  the  proposals 
mentioned  therein,  an  efficient  reporting  mechanism  to  measure  the  impact  of  outcomes 
and results of specific actions deriving from the strategy.  

While the current strategy covers 2014-2020, the monitoring framework needs to cover an 
expected successor strategy. Importantly, though the precise features of the future strategy 
are not yet known, it is likely to address and follow-up on many of the same issues as the 
present  strategy.  It  has  therefore been possible to  develop  a draft monitoring  framework, 
even if some aspects concerning final operationalisation will need to be defined when the 
new strategy is in place.  

The second progress report noted that while the strategy’s actions and sub-actions provide 
a useful framework for categorising planned activities, they are also fragmented in a way 
that risks the ability of standardised monitoring tools (such as surveys and questionnaires) 
to capture the ‘big picture’ in a consistent and un-burdensome way.  

The  performance  and  monitoring  framework  therefore  focuses  on  a  limited  number  of 
strategic  elements,  as  encapsulated  in  the  strategy’s  intervention  logic.  The  intervention 
logic outlines the causal chain between activities and expected results, thereby illustrating 
what  should  be  measured/monitored  in  order  to  assess  performance,  and  providing  a 
foundation  to  develop  the  indicators  and  sources  of  evidence  that  will  inform  the 
monitoring framework. 

4.1.  The Strategy’s intervention logic 

An  intervention  logic  lays  out  the  main  elements  of  an  intervention  (in  this  case,  the 
Strategy  and  the  Action  Plan),  from  the  pre-existing  problem  it  is  meant  to  address  to 
desired long-term impacts,  and shows how they  relate to  each other in a series of  causal 
relationships.  These  obviously  simplify  reality,  which  is  too  complex  to  represent 
accurately on a single page. Nonetheless, by pinning down the strategy’s key features and 
how they fit together, the intervention logic helps figure out where to look for evidence of 
success. The intervention logic will naturally change when the new strategy is decided. 
However,  many  of  the  key  issues  and  areas  of  action  could  be  assumed  to  remain 
valid. 

Figure  (1)  below  presents  the  current  strategy’s  intervention  logic.  The  following  bullet 
points outline its main features to make the diagram easier to follow. 

  Overall  structure:  the  strategy  describes  action  to  be  taken  across  seven 
objectives, but does not explicitly say how they relate to each other. In fact, there is 
an  implicit  hierarchy  between  the  different  objectives.  At  the  highest  level, 
Objective  3  encapsulates  the  desired  outcome  of  the  strategy,  which  is  that  risk 

101 

 
 
 
mitigation  and  control  measures  are  consistently  employed.  This  is  achieved 
through  strategic/infrastructure  action  carried  out  under  Objectives  1,  2  and  4, 
which relate (respectively) to arrangements with economic operators (Eos), access 
to  and  use  of  data  by  customs  authorities  and  the  CRMF.  Objectives  5,  6,  and  7 
play  an  enabling  role  by  fostering  cooperation  at  various  levels.  This  structure 
implies  that  Objectives  1-4  comprise  the  ‘core’  of  the  strategy  that  should  be  the 
focus of future monitoring efforts. 

  Problem/rationale:  the  Communication  on  Customs  Risk  Management  and 
Security  of  the  Supply  Chain  (COM(2012)793final)  described  specific  gaps 
relating  to  the  approach  to  customs  risk  management  and  supply  chain  security. 
These showed a need for more concerted action that led the Council to invite from 
the  Commission  a  ‘coherent  strategy  on  risk  management  and  supply  chain 
security’. 

  Activities:  while  the  strategy’s  54  sub-actions  cover  a  wide  range  of  issues,  the 
activities undertaken to implement them can be grouped reasonably neatly into six 
main categories (albeit with some overlap):  

o  Guidance  and 

o  Analysis and capacities development:  focused  on conducting an  analysis 
of a given issue or problem and coming up with solutions to address it. 
tools: 

to  develop  guidelines, 
recommendations,  standards,  criteria,  training  programmes,  factsheets  or 
other tools. 

common 

action 

o  EU legislation: any activity related to preparing, proposing and/or adopting 
legal  provisions  at  EU  level  to  ensure  the  legal  base  for  progress  in  risk 
management.  

o  European  Information  Systems:  work  related  to  the  whole  development 
cycle  of  EIS  with  risk  management  aspects,  such  as  (but  not  limited  to) 
ICS2 and CRMS2. 

o  Cooperation:  mainly under Objectives 5, 6 and 7 these activities relate to 
the development, strengthening and enforcement of arrangements with third 
parties,  such  as  non-customs  authorities,  EOs, 
third  countries  and 
international organisations.  

o  Working practices: this includes action by national customs authorities to 
broadly  improve  working  practices,  e.g.  risk  management  and  related 
processes,  work  flows,  use  of  relevant  information,  capacities  and 
capabilities, etc.  

  Outputs:  this  level  depicts  the  immediate  products  of  the  above-mentioned 
activities, which  can  range from new  IT solutions and pieces  of legislation to  the 
identification of new measures that are needed to address identified weaknesses in 
risk management practice and specific methodologies. 

  Results:  taken  together,  the  different  outputs  should  make  a  real  improvement  to 
risk  management  methodologies  and  procedures  in  the  areas  covered  by  the 
strategy’s  objectives.  These  ultimately  flow  into  the  improved  methodologies  and 
procedures of Objective 3. 

102 

 
 
 
  Outcomes:  the  desired  outcome  is  that  the  improved  methodologies  and 
procedures,  drawing  on  better  practice  across  the  strategy’s  core  areas,  lead  to 
better, more efficient and/or uniform EU-wide customs risk management.  

  Impact:  at  the  highest  level,  the  strategy  should  play  a  contributing  role  towards 
the objectives of the Customs Union, namely the improved management of customs 
risks  and  strengthened  supply  chain  security,  in  addition  to  the  facilitation  of 
legitimate trade. 

103 

 
 
 
Figure (1): The strategy’s intervention logic 

104 

 
 
 
 
 
 
 
4.2.  The indicator framework  

4.2.1. 

Developing the indicators for the new strategy 

The work on the monitoring framework has consisted of assessing, refining, updating and 
operationalising the  existing  indicators in line with  the RACER criteria defined in  the 
Better  Regulation  Toolbox31.  This  ensures  that  the  future  monitoring  framework 
corresponds to the real needs of stakeholders and is likely to add value for them, as well as 
being manageable in terms of reporting requirements.  

This  section  provides  some  practical  insights  and  examples  for  operationalising  the 
monitoring  framework  with  a  view  to  the  advice  on  monitoring  in  the  Better  Regulation 
Guidelines  and  Toolbox  and  tailored  to  the  strategy’s  specific  characteristics32.  The 
recommendations  primarily  concern  considerations  for  ensuring  that  the  data  collection 
and  reporting  plans  are  appropriate  and  that  complementary  activities,  such  as  periodic 
evaluations, are also carried out. 

The evidence that needs to be collected is covered in the indicator tables in Section 4.2.2. 
One should note that while the indicators have been developed with the future strategy in 
mind, at least some aspects are likely to change by the time it is in place. Moreover, some 
indicators  may  become  obsolete  once  certain  initiatives  (e.g.  specific  IT  systems)  are 
implemented  or  completed,  or  if  important  new  initiatives  are  launched.  It  is  therefore 
suggested to revisit the indicators at each reporting cycle. The vast majority of indicators 
should  be  maintained  for  purposes  of  comparing  performance  over  time,  but  a  small 
number  could  be  adapted  as  needed  on  an  ongoing  basis.  Some  indicators  might  be 
collected but not made public for sensitivity reasons. 

As for the monitoring framework’s reporting cycle, a 1-2 year time frame is suggested, 
depending on what is considered appropriate and feasible. This corresponds roughly to the 
cycle  under  the  present  strategy,  and  has  worked  well  in  terms  of  placing  only  a 
manageable  burden  on  stakeholders  (e.g.  for  Member  State  officials  to  respond  to  a 
questionnaire).  

Finally,  attention  should  be  paid  to  the  links  between  the  new  strategy  and  other 
initiatives  such  as  the  Customs  Union  Action  Plan,  the  Customs  Control  Equipment 
Programme, the Joint Analysis Capacity project, the Customs Union Performance project, 

31 

32 

See tool #41. Monitoring arrangements and indicators. RACER stands for Relevant, Accepted,  
Credible, Easy to monitor and Robust. The Toolbox is available on the Commission’s website.  
https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation- 
why-and-how/better-regulation-guidelines-and-toolbox/better-regulation-toolbox_en 
Better Regulation Guidelines Chapter V on Monitoring:  
https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines-monitoring.pdf 

105 

 
 
 
 
 
                                                 
  
  
  
the  AEO  programme  and  the  post-Customs  2020  programme.  In  different  ways,  these 
initiatives will address issues of relevance to the new strategy, while in some cases having 
their own monitoring frameworks.  

4.2.2. 

Indicator tables 

The  below  tables  present  the  indicators  for  the  strategy’s  seven  objectives.  Given  the 
similarities between some objectives, indicators for Objectives 1 and 2, and for Objectives 
5,  6  and  7  are  presented  together.  The  tables  show  the  type  of  evidence  that  could  be 
collected, as well as from whom. 

The tables contain the following six columns: 

  Level: part of the intervention logic that the indicator refers to (outputs, results or 

outcomes); 

 

 

Intervention logic text: box from the diagram that the indicator relates to; 

Indicator: the actual indicators, phrased to be as RACER as possible; 

  Purpose / definition: overview of the rationale of the indicator and what it means in 

practical terms; 

  Unit  of measurement:  number of, level  of, or existence of an element  that  can be 

used to record the indicators; 

  Source of data: already existing from e.g. CUP reporting or needing to be collected 

from e.g. Commission departments or questionnaire to Member States. 

106 

 
 
 
 
 
1 

2 

3 

4 

5 

6 

Table (1): Indicators for Objectives 1 & 2 

#  Level 

Intervention  logic 
text 

Indicator  

Outputs 

IT  solutions 
for 
submission of data 
by 
and 
EOs 
information 
sharing 
customs 
authorities 

between 

Number  of  projects 
completed 
to 
develop new systems 
improve  existing 
/ 
systems 
to  submit 
data  by  EOs  and  to 
facilitate  sharing  of 
risk-relevant 
information  between 
customs authorities 

Number  of  external 
data 
sources  MS 
customs  authorities’ 
IT 
are 
systems 
linked with 

of 
of 
/  updated  IT 
with 
for 
risk 

Level 
implementation 
new 
systems 
relevance 
customs 
management  

Results 

Appropriate  legal, 
procedural  and  IT 
mechanisms 
in 
place  to  allow  for 
information 
submission, 
availability 
sharing 

and 

Legislation  on  ENS 
data collection, other 
relevant  EO  data 
collection/access, 
and 
to 
legislation 
facilitate  sharing  of 
risk-relevant  supply-
data 
chain 
implemented 
Number 
registered for ICS2 

of  EOs 

Existence  of 
fora 
and tools for sharing 
supply-chain 
information  among 
customs  authorities 
including 
solutions 
allowing  traceability 
to be implemented 
Level  of  perceived 
of 
usefulness 
IT 
to  submit 
systems 
data  by  EOs  and  to 
facilitate information 
between 
sharing 

7  Outcomes 

to 

of 
and 

Availability 
customs 
authorities 
high-quality 
comprehensive 
data 

on 

int’l 

/ 

the 
of 
data 
MS 

Purpose 
definition   
Keep  track  over 
time  of  new  IT 
projects  aimed 
at  making 
it 
easier  for  EOs 
to  submit  data 
customs 
and 
authorities 
to 
obtain and share 
risk-relevant 
information 
Gauge 
number 
external 
sources 
customs 
authorities  have 
access to 
Measure 
whether  and  to 
what  extent  the 
system(s) 
IT 
been 
have 
implemented 
and 
identify 
problems  with 
certain 
e.g. 
aspects or MS 
Gauge  whether 
relevant 
legislation  has 
been 
implemented  in 
the MS 

Keep  track  over 
time  of  how 
many  EOs  are 
registered 
for 
ICS2 
Gauge  whether 
envisaged 
fora 
and  tools  have 
been established 
and 
are 
functioning 

Keep  track  over 
the 
time 
of 
of 
usefulness 
the  IT  systems 
to  submit  data 
exit, 
(entry, 

Unit 
measurement 
Number  of 
projects 

of 

IT 

Source of data 

Commission 
departments 

Number 
external 
sources 

of 
data 

Data  would  need  to  be 
collected from: 
Questionnaire 
filled in by MS 

be 

to 

Commission 
departments 

Implementation 
status 
for 
different  aspects 
of 
system 
among  different 
actors 

the 

Number 
of 
legislative act(s) 

Implementation reports 
Commission 
departments 

Number  of  EOs 
registered 

Commission 
departments 

Number 
of 
specific  fora  and 
tools 

Commission 
departments 

of 

Views 
customs 
authorities 
perceived 
usefulness  on  a 
scale of 1-4 

of 

Data  would  need  to  be 
collected from: 
Questionnaire 
filled in by MS 

be 

to 

107 

 
 
chain 

Intervention  logic 
text 
supply 
movements 
MS 
customs 
authorities  able  to 
and 
analyse 
mitigate 
risks 
collaboratively 
where 
and 
equivalent 
treatment of EOs 

relevant 
ensure 

#  Level 

8 

Indicator  

Purpose 
definition   

/ 

Unit 
measurement 

of 

Source of data 

customs authorities   export  summary 
declarations)  by 
EOs 
to 
and 
facilitate 
information 
sharing 
according 
customs 
authorities   
Keep  track  over 
the 
time 
of 
to 
usefulness 
customs 
authorities 
of 
the  information 
from  given  fora 
and tools  

Level  of  perceived 
usefulness 
of 
shared 
information 
through relevant fora 
and tools 

to 

of 

Views 
customs 
for 
authorities 
different fora and 
tools  on  a  scale 
of 1-4 

Data  would  need  to  be 
collected from: 
Questionnaire 
filled in by MS 

be 

to 

Table (2): Indicators for Objective 3 

#  Level 

Intervention logic text 

Indicator  

advance, 
in 
‘Assess 
control  where  required’ 
methodologies 

relates 

to 
Note:  also 
‘Right’ place and time for 
controls 
risk 
mitigation measures 

and 

Outputs 

‘Proof  of  concept’  and 
related solutions 

relates 

to 
Note:  also 
‘Right’ place and time for 
controls 
risk 
mitigation measures 

and 

Results 

Methodologies 
and 
procedures  in  place  to 
allow  risk-based  controls 
at  the  most  appropriate 
time and place 

1 

2 

3 

4 

Number  of  projects 
to develop ‘assess in 
control 
advance, 
required’ 
where 
methodologies 
(per 
type of risk) 

of 

Number 
tools 
created  /  updated  in 
main  policy  areas 
(i.e.  health  safety, 
risks, 
financial 
intellectual  property 
rights,  and  product 
safety 
and 
compliance)  
Number of ‘assess in 
control 
advance, 
where 
required’ 
methodologies 
implemented  by  MS 
customs  authorities 
(per type of risk) 

Extent  of  use 
usefulness 
‘Toolbox’ 
recommendations 

/ 
of 

of 

Unit 
measurement 
Number 
projects 
type  of 
covered 

of 
per 
risk 

Source of data 

Commission 
departments 

Number 
tools 

of 

Commission 
departments 

/ 

Purpose 
definition   
Keep track over 
time of projects 
on 
focused 
‘assess 
in 
advance, 
control  where 
required’ 
methodologies 
(per 
risk) 
Keep track over 
tools 
time  of 
created 
/ 
updated  in  the 
relevant areas  

type  of 

Gauge extent to 
which 
methodologies 
in 
developed 
this  area  are 
actually 
implemented 
(per 
risk) 
Gauge extent to 
which 
‘Toolbox’ 
recommendatio
ns  are  actually 
/  useful 
used 

type  of 

Number 
of 
methodologies 
per 
type  of 
risk covered 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

of 

Views 
Commission 
officials  on  a 
scale of 1-4 

Commission 
departments 

108 

 
 
 
 
 
#  Level 

Intervention logic text 

Indicator  

5  Outcomes 

and 
Risk  mitigation 
control 
measures 
consistently  employed  to 
respond  to  identified  EU 
and  national  risks  while 
maximising 
efficiency 
and fluidity of the supply 
chain 

Number  of  controls 
of  different 
types 
carried  out  based  on 
(different  types  of) 
risk analysis  

Proportion 
of 
(different  types  of) 
controls  leading  to 
of 
detection 
the 
irregularities 

6   

/ 

Purpose 
definition   
when 
Commission 
departments 
review 
legislative acts 
Keep track over 
time  of  extent 
to  which  risk 
analysis 
leads 
concrete 
to 
actions 
of 
different  kinds, 
and  how 
this 
varies  by  e.g. 
type 
of 
declaration  and 
MS.  
Gauge extent to 
which  different 
types 
of 
controls 
become  better 
targeted 
over 
time 

Unit 
measurement 

of 

Source of data 

Commission 
departments 

Commission 
departments 

of 
of 

Numbers 
controls 
different  types   
divided 
by 
import,  export 
and 
transit 
declarations of 
different 
types) 

of 

Number 
irregularities 
detected 
during: 
documentary 
control; 
documentary 
control  based 
on  electronic 
risk  analysis; 
physical 
control; 
physical 
control  based 
on  electronic 
risk  analysis; 
Post-
other 
Release 
Controls 
divided 
by 
import,  export 
and 
transit 
declarations of 
different types  

109 

 
 
 
 
 
 
 
 
 
 
 
Table (3): Indicators for Objective 4 

#  Level 

Intervention logic text 

Identification of MS weaknesses 
/ measures to address them 

Common  Risk  Criteria  and 
implementation plans 

Outputs 

1 

2 

3 

4 

Results 

MS  capacities  related  to  CRMF 
strengthened  and  continuously 
monitored and evaluated 

5 

6 

Indicator  

of 
Number 
completed  pieces  of 
analysis  carried  out 
at  EU  level  on  MS 
weaknesses  and  /  or 
measures  to  address 
them  (per  type  of 
border) 

of 

new 
Number 
common  risk  criteria 
defined  

Change  in  capacities 
the 
to 
in  relation 
implementation 
of 
the  CRMF 
(CRC, 
PCAs, CRMS) 

Level 
implementation 
CRMS2 

of 
of 

Number 
of  Risk 
Information  Forms 
(RIFs) 
issued 
through  CRMS  for 
different categories 

Number 
profiles 

of 

risk 

7  Outcomes 

and 

uniform 
Effective 
implementation  of 
the  EU 
CRMF  across  all  MS  and 
corresponding responsiveness to 

of 

hits 
Number 
based 
CRC 
on 
(automated  and  after 
assessment) 

/ 

to 

Purpose 
definition   
Gauge 
progress 
with 
ongoing 
analytical 
work  on  MS 
weaknesses 
(per  type  of 
border) 
track 
Keep 
of 
the 
evolution  of 
the  common 
risk  criteria 
for 
the  11 
policy  areas 
concerned 
Gauge 
extent 
which 
capacities  in 
relation 
to 
the 
implementati
on  of 
the 
CRMF  have 
been 
strengthened 
Measure 
whether  and 
to 
what 
the 
extent 
CRMS2  has 
been 
implemented 
and  identify 
problems 
with 
certain 
aspects 
MS 
Gauge actual 
of 
usage 
and 
RIFs 
of 
sharing 
information 
between MS 
Gauge 
comprehensi
and 
veness 
breadth 
of 
RIF system 
Gauge 
extent 
to 
which  CRC 
informs  risk 

e.g. 

or 

Source of data 

Commission 
departments 

of 

Unit 
measurement 
Number of pieces 
of  analysis  per 
type  of  border 
road, 
(air,  sea, 
rail, 
inland 
water) 

of 
Number 
criteria  per  type 
of  risk  /  policy 
area 

Commission 
departments 

Views  of  MS  on 
of 
extent 
progress  on 
a 
scale of 1-4 

to 

Data 
would 
be 
need 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Commission 
departments 

Implementation 
status 
for 
different  aspects 
system 
of 
among  different 
actors 

the 

Number of RIFs   Commission 
departments 

Number 
profiles  

of 

Commission 
departments 

Number of hits 

already 

Data 
exists in: 
CRC  quarterly 
reports 

110 

 
 
#  Level 

Intervention logic text 

Indicator  

newly identified risks 

8 

9 

Level  of  perceived 
usefulness of RIFs in 
different MS 

Extent 
CRMS2 
improved 
risk management 

to  which 
has 
customs 

/ 

Purpose 
definition   
analysis 
Gauge 
extent 
to 
which  RIFs 
are  useful  in 
practice 
for 
risk  analysis 
in  different 
MS 
Gauge 
extent 
which 
CRMS2  has 
improved 
customs  risk 
management 

to 

Unit 
measurement 

of 

Source of data 

Views  of  MS  on 
usefulness  on  a 
scale of 1-4 

Views  of  MS  on 
extent 
of 
improvement  on 
a scale of 1-4 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Table (4): Indicators for Objectives 5, 6 & 7 

# 

Level 

Intervention logic text 

Indicator  

Number  of  relevant 
interagency 
agreements  made  at 
MS and EU level 

Cooperation 
agreements 

in 
Participation 
Customs 
2027 
collaborative actions 

Outputs 

AEO promotion  

Number  of  AEOs  in 
different MS 

Extent  to  which  MS 
provide  the  benefits 
for  AEO  allowed  in 
the UCC 

1 

2 

3 

4 

5 

/ 

to 
risk 

Purpose 
definition   
Gauge extent to 
which 
the 
Commission, 
MS 
customs 
authorities  and 
other 
authorities  are 
forming 
agreements 
facilitate 
management  
Gauge extent to 
MS 
which 
participate 
in 
Customs  2027 
collaborative 
actions 
facilitate 
management 
and 
cooperation 
Measure 
evolution 
in 
uptake  of  AEO 
in different MS 
Gauge  progress 
with  action  to 
strengthen 
the 
AEO concept 

to 
risk 

improve 

Source of data 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS and 
Commission 
departments 

Commission 
departments 

of 

of 

Unit 
measurement 
Number 
formal 
agreements 

of 
2020 

MS 

Number 
Customs 
collaborative 
actions 
customs 
authorities 
participate in 

Number of AEOs  Commission 
departments 

of 

Number 
additional 
national  benefits 
introduced 

Number 
partnerships 

of 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 
Data 
would 
be 
need 
collected from: 
Questionnaire 

to 

111 

Partnerships 
legitimate EOs 

with 

Number  of  relevant 
partnerships  between 
MS 
customs 
authorities and EOs 

Gauge extent to 
which  customs 
authorities  are 
forming 

 
 
 
# 

Level 

Intervention logic text 

Indicator  

6 

7 

8 

9 

Mutual recognition 

Research 
practices 

and 

best 

Number  of  mutual 
recognition 
agreements 
third countries 

with 

Number 
submitted  by 
country AEOs 

of  ENS 
third 

of 

Number 
international 
cooperation  models 
developed 

Level  of  agreement 
cooperation 
that 
between customs and 
competent 
other 
and  EU 
national 
authorities 
has 
improved  

10 

Results 

Improved cooperation 

of 

Number 
joint 
customs  operations 
that  MS 
customs 
authorities 
participate 
risk area) 

(per 

in 

Level  of  agreement 
that cooperation with 
EOs has improved  

11 

/ 

third 

third 

Purpose 
definition   
partnerships 
with  EOs  that 
facilitate 
risk 
management 
Keep  track  of 
level 
of 
cooperation 
with 
countries 
Keep  track  of 
how 
cooperation 
with 
countries 
evolves 
in 
terms of mutual 
recognition  of 
AEOs 
Gauge  progress 
with  action  to 
strengthen 
international 
cooperation 
Gauge  whether 
key 
stakeholders 
feel 
that 
cooperation  has 
improved   

Gauge extent to 
MS 
which 
participate 
in 
customs 
joint 
to 
operations 
facilitate 
risk 
management 
and 
cooperation 
Gauge  whether 
key 
stakeholders 
feel 
that 
cooperation  has 
improved   

improve 

Unit 
measurement 

of 

Source of data 

to  be  filled  in  
by MS 

Number 
agreements 

of 

Commission 
departments 

Number of ENS 

Commission 
departments 

of 

Number 
international 
cooperation 
models 
developed 
Views  of  MS  on 
extent  to  which 
cooperation  has 
improved  on  a 
scale of 1-4 

Commission 
departments 

to 

would 
Data 
be 
need 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Number  of  joint 
operations  MS 
customs 
authorities 
participate in (per 
risk area) 

to 

would 
Data 
be 
need 
collected from: 
Questionnaires 
to  be  filled  in 
by MS 

Views  of  MS  on 
extent  to  which 
cooperation  has 
improved  on  a 
scale of 1-4 

to 

Data 
would 
be 
need 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

112 

 
 
12 

13 

14 

15 

16 

# 

Level 

Intervention logic text 

Indicator  

Level  of  agreement 
international 
that 
cooperation 
has 
improved  

/ 

Purpose 
definition   
Gauge  whether 
key 
stakeholders 
that 
feel 
cooperation  has 
improved   

of 

Unit 
measurement 
Views  of  MS  on 
extent  to  which 
cooperation  has 
improved  on  a 
scale of 1-4 

Source of data 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Extent  to  which  data 
obtained  from  other 
national authorities is 
exploited 
risk 
management 
purposes 

for 

Extent  to  which  data 
obtained from EOs is 
exploited 
risk 
management 
purposes 

for 

is 
for 

Gauge 
the 
extent  to  which 
data  from  other 
national 
authorities 
exploited 
risk 
management 
purposes 
Gauge 
the 
extent  to  which 
data  from  EOs 
is  exploited  for 
risk 
management 
purposes 

Views  of  MS  on 
extent  to  which 
data  from  other 
national 
authorities 
is 
exploited  for  risk 
management 
purposes  on  a 
scale of 1-4 
Views  of  MS  on 
extent  to  which 
data  from  EOs  is 
exploited  for  risk 
management 
purposes  on  a 
scale of 1-4 

to 

would 
Data 
be 
need 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

to 

Data 
would 
be 
need 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Extent  to  which  data 
obtained 
from 
international 
third 
cooperation 
countries is exploited 
for  risk  management 
purposes 

/ 

Gauge 
the 
extent  to  which 
data 
from 
international 
cooperation 
/ 
third  countries 
is  exploited  for 
risk 
management 
purposes 

Views  of  MS  on 
extent  to  which 
data 
from 
international 
cooperation 
/ 
third  countries  is 
exploited  for  risk 
management 
purposes  on  a 
scale of 1-4 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Extent  to  which  data 
is 
from 
exploited 
risk 
management 
purposes 

AEOs 
for 

Gauge 
the 
extent  to  which 
from 
data 
is 
AEOs 
exploited 
for 
risk 
management 
purposes 

Views  of  MS  on 
extent  to  which 
data  from  AEOs 
is  exploited  for 
risk  management 
purposes  on  a 
scale of 1-4 

to 

Data 
would 
be 
need 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

113 

 
 
 
# 

Level 

Intervention logic text 

Indicator  

17 

18 

19 

20 

21 

Risk  information  from 
other  competent  EU 
and MS authorities 

Level  of  agreement 
that 
cooperation 
between customs and 
competent 
other 
and  EU 
national 
has 
authorities 
improved 
risk 
management 
practices 

Level  of  agreement 
that cooperation with 
improved 
EOs  has 
risk 
management 
practices 

Extent  to  which  data 
from AEOs improves 
risk 
management 
practices 

/ 

Purpose 
definition   
Gauge  whether 
key 
stakeholders 
that 
feel 
cooperation  has 
improved 
risk 
management 
practices 

of 

Unit 
measurement 
Views  of  MS  on 
extent  to  which 
cooperation  has 
risk 
improved 
management 
practices  on  a 
scale of 1-4 

Source of data 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Gauge  whether 
key 
stakeholders 
feel 
that 
cooperation  has 
risk 
improved 
management 
practices 

Views  of  MS  on 
extent  to  which 
cooperation  has 
improved 
risk 
management 
practices  on  a 
scale of 1-4 

to 

Data 
would 
be 
need 
collected from: 
Questionnaires 
to  be  filled  in 
by MS 

the 
Gauge 
extent  to  which 
data 
from 
AEOs improves 
risk 
management 
practices 

Views  of  MS  on 
extent  to  which 
data  from  AEOs 
improves 
risk 
management 
practices  on  a 
scale of 1-4 

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

Outcomes 

Supply  chain  security, 
trade  facilitation  and 
trade data exploitation 

Level  of  detected 
for 
irregularities 
AEOs  versus  non-
AEOs 

Measure 
performance  of 
the 
AEO 
programme as a 
security 
measure 

International  standards, 
debates 
and 
data/information 
exchange 

Level  of  agreement 
international 
that 
has 
cooperation 
improved 
risk 
management 
practices 

Gauge  whether 
key 
stakeholders 
feel 
that 
cooperation  has 
risk 
improved 
management 
practices 

in 
of 

Difference 
number 
irregularities 
detected  (during 
documentary 
control; 
documentary 
control  based  on 
electronic 
risk 
analysis; physical 
control;  physical 
control  based  on 
risk 
electronic 
analysis; 
other 
Post-Release 
Controls) 
for 
AEOs  and  non-
AEOs 
Views  of  MS  on 
extent  to  which 
cooperation  has 
improved 
risk 
management 
practices  on  a 
scale of 1-4 

Commission 
departments  

to 

would 
Data 
need 
be 
collected from: 
Questionnaire 
to  be  filled  in 
by MS 

114 

 
 
 
 
 
 
 
5. ANNEX: IMPLEMENTATION TABLE 

The tables below provide an overview of the status of all actions under the action plan. While 
some actions have been completed, especially those related to legislation or the analysis of a 
situation, a large number of them are categorised as ‘ongoing’ or ‘permanent’. These actions 
have been initiated as foreseen in the action plan.  

COMPLETED 
PERMANENT 
ONGOING 
NOT STARTED  The Action has not started.  

The Action is completed. 
The Action is a process of a permanent nature with no end date. 
The Action has started, but is not yet finalised. 

5.1.  Objective 1: Improve data quality and filing arrangements for effective risk 

management 

Action 1.1 

1.1.1  COMPLETED 

1.1.2  COMPLETED 

the  necessary 

Exercise  the  empowerment  granted  in  the  Union  Customs  Code  to 
adopt Commission acts 
For  goods  brought  into  the  EU  customs  territory;  conclude  the 
analysis  for 
improvement  of  entry  summary 
declaration  (ENS)  data  taking  into  account  different  business 
models,  the  results  of  air  cargo  security  pilot  actions,  and  the 
evaluation of the Import Control System (ICS) 
For  goods  brought  into  the  EU  customs  territory;  propose  a 
harmonised  solution  for  collecting  and  integrating  ENS  data  from 
trade  sources,  based  on  an  analysis  of  costs  and  benefits  and 
associated implementation issues (including technical, financial and 
organisational aspects) 

A  Customs  2020  project  group  concluded  the  analysis  of  the  implementation  feasibility  for 
Objectives 1-2 of the EU risk management strategy. 

1.1.3  COMPLETED  Adopt provisions within legal acts 
This  action  was  completed  with  the  adoption  of  the  Code,  the  delegated  regulation  and 
implementing regulation. The legislation applies since 1 May 2016. 

Action 1.2 

1.2.1 

ONGOING 

Develop and implement appropriate IT solutions 
Adjust and further develop necessary IT systems for ENS 
data submission by economic operators, and its collection 
and integration for customs authorities  

The Commission is working to ensure the completion by 2025 of all 17 Union Custom Code 
electronic  systems,  and  publishes  annual  progress  reports.  In  total,  this  work  requires  the 
upgrading or creation of 14 trans-European systems and three purely national systems. (see § 
2.1.3) 

1.2.2 

ONGOING 

Develop  IT  access  by  customs  to  economic  operators’ 

115 

 
 
 
 
 
 
 
systems  in  the  area  of  aviation  security  (Article 127(8) 
Union Customs Code) 
This  action  is  (to  be)  pursued  at  the  national  level.    One  Member  State  has  already  started 
working in  this direction of gaining access  to  express  carriers’  systems.  This  action touches 
more on access to express carriers’ systems, and less on postal systems. 

116 

 
 
 
5.2.  Objective 2: Ensure availability of supply chain data, sharing of risk-relevant 
information  and  control  results  among  customs  authorities  to  analyse  and 
mitigate risks and ensure equivalent treatment of economic operators 

Action 2.1 

2.1.1 

COMPLETED 

2.1.2 

COMPLETED 

Exercise the empowerment granted in the Union Customs Code to 
adopt Commission acts 
Identify  options  for  availability  and  sharing  among  customs 
authorities of supply chain data for risk management purposes 
Identify  options  for  availability  and  sharing  of  risk-relevant 
information, 
including  control  results,  among  EU  customs 
authorities to analyse and mitigate the risks on a real-time basis 

  The  Commission  and  Member  States  have  made  progress  on  the  necessary 
modifications  to  the  legal  base  under  the  Union  Customs  Code.  Most  of  the  legal 
provisions  have  been  agreed  upon  and  the  relevant  Commission  implementing  and 
delegated acts should be adopted in course of 2020.  

  For  customs  procedures  after  entry  and  in  particular  concerning  the  ‘Surveillance  3’ 
(functional 

process  model 

(BPM) 

of 

system, 
requirements/specifications) has been completed. 

business 

drafting 

the 

  The  Surveillance  3  system  was  successfully  deployed  on  1 October 2018  although 
some data migration is ongoing as the full use and benefits of the system will manifest 
when  all  Member  States  submit  the  legally  defined  import  and  export  data  from  the 
Member States ‘upgraded national systems’. The data analytics platform went live in 
March 2019, allowing the Commission to exploit surveillance data.  

  For  transit,  the  amendment  of  Council  Regulation  (EC)  No  515/97  on  mutual 
assistance  offered  a  clear  legal  basis  for  the  Anti-Fraud  Transit  Information  System 
(ATIS) and enlarged the scope of the information  to  be exchanged between customs 
authorities and between the Commission and the national authorities. 

  The  common  guidelines  for  customs  authorities  have  been  finalised  (all  guidance 

documents are now in place). 

Action 2.2 

Develop and implement appropriate IT solutions 
Adjust  and  further  develop  necessary  IT  systems  for  availability 
and  sharing  of  supply  chain  data,  and  risk-relevant  information, 
including control results, among EU customs authorities 
For entry 

ONGOING 

2.2.1 
For  entry,  the  analysis  has  been  completed  and  laid  down  in  the  business  case  and  vision 
document for ICS2. 
2.2.2 
For customs procedures after entry, particularly those concerning the Surveillance 3 system, 
drafting of the L4 business process model (BPM) (functional requirements/specifications) has 
been completed. The business case has been updated and reviewed. 
2.2.3 

For customs procedures after entry  

For export and exit  

ONGOING 

ONGOING 

117 

 
 
 
 
 
 
 
 
Commission proposal for a Regulation of the European Parliament and of the Council, setting 
up  a  Union  regime  for  the  control  of  exports,  transfer,  brokering,  technical  assistance  and 
transit of dual-use items (recast)33 

In April 2020, the Council adopted new rules34 creating a uniform legal framework for the use 
of electronic freight transport information for all modes of transport, which will make it easier 
for freight transport companies to provide information to authorities in digital form. Increased 
digitalisation  of  freight  transport  and  logistics  will  bring  significant  cost  savings  for 
businesses, and make the transport sector more efficient and sustainable. The new rules will 
apply in full from 21 August 2024.  
2.2.4 
In  2016,  the  new  computerised  transit  system  (NCTS)  project  group  began  work  on 
developing in more detail the functional transit system specifications, including the phasing of 
the progress changes related to safety and security. It is a system of electronic declaration and 
processing that traders must use to submit Union Transit (UT) and Transports Internationaux 
Routiers  (TIR)  declarations  electronically.  Paper  declarations  are  only  allowed  when  transit 
declarations  cannot  be  made  on  the  NCTS  system  or  for  travellers  with  goods  in  excess  of 
their duty-free allowance. 

ONGOING 

For transit  

Action 2.3 

1. 

ONGOING 

Propose  solutions  for  traceability  of  goods’  movements  during 
various customs control stages 
Identify  options  for  the  traceability  of  goods’  movements  in  the 
various  stages  of  supply  chain  movements  involving  more  than  one 
Member State and through data provided by economic operators.  
Identify appropriate customs supervision solutions from goods’ entry 
into the EU customs territory to their final customs clearance, taking 
account  of  ongoing  initiatives  and/or  by  adjusting  the  existing 
customs transactions systems. 

Several initiatives have been launched as reported in section 2.2.3. 

2.  

ONGOING 

Put  forward  the  appropriate  approach,  taking  into  account  relevant 
aspects. 

The  implementation  of  this  action  will  depend  on  the  outcome  of  projects  like  the  ones 
mentioned above. 

33 
34 

COM(2016) 616 final of 28.9.2016. 
Regulation (EU) 2020/1056 of the European Parliament and of the Council of 15 July 2020. 

118 

 
 
 
 
 
 
 
 
 
                                                 
5.3.  Objective  3:  Implement  the  concept  of  ‘Assess  in  advance  -  control  where 
required’  to  respond  adequately  to  identified  EU  and  national  risks  while 
maximising efficiency in the use of resources and fluidity of the supply chain 

Action 3.1 

3.1.1 

PERMANENT 

Develop  methodologies  to  implement  the  concept  of 
‘Assess in advance - control where required’ 
Propose  a  methodology  to  determine  the  most  appropriate 
place and time for the application of customs  controls  and 
risk  mitigation  measures  based  on  the  type/level  of  risk, 
control  and  supply  chain  constraints  (availability  of 
information, documentation, and control possibilities) 

Section 2.3.1. describes the credibility checks and the Systems-Based Approach. Credibility 
checks  are  automated  checks  introduced  at  the  clearance  stage  of  imports.  They  check  the 
compatibility of entries in the customs declaration against three parameters: (i) legal checks; 
(ii) mass-related checks; and (iii) price-related checks. To date, 429 such measures have been 
introduced  via  the  integrated  Tariff  of  the  European  Union  (TARIC).  This  is  a  permanent 
exercise.  

Action 3.2 

3.2.1 

PERMAMENT 

Perform  ‘proof  of  concept’  within  the  main  policy  areas  and 
propose appropriate solutions 
Identify the main policy areas and undertake operational  actions 
to  test solutions  e.g. through priority  control  area  (PCA) actions 
in cooperation with relevant stakeholders 

Priority Control Area (PCA) is the key mechanism in the CRMF (see details under Objective 
4)  that  enables  the  EU  to  designate  specific  areas  to  be  treated  as  a  priority  for  customs 
control.  The  PCA  tool  has  been  used  to  coordinate  EU  customs  actions  in  most  major  risk 
areas already since 2007, delivering operational results and strategic lessons.  

During crises, PCAs are replaced by crisis. This was the case for COVID-19 in 2020.  

3.2.2 

COMPLETED 

into 

account 

outcomes 

Taking 
‘Toolbox’: 
recommendations  to  provide  guidance  in  the  preparation  or 
review of legislative acts which provide for customs controls, by 
describing how customs action can be envisaged in line with EU 
customs legislation and international trade practices. 

the 

of 

The  Toolbox  has  been  finalised  and  distributed  to  Commission’s  departments  and  national 
customs authorities. 

119 

 
 
 
 
 
 
 
 
 
 
 
5.4.  Objective  4:  Strengthen  capacities  to  secure  equivalence  in  effective 
implementation of the common risk management framework and to increase 
responsiveness to newly identified risks 

Action 4.1 

4.1.1 

PERMANENT 

Identify  and  address  weaknesses  and  inappropriate 
variances  in  the  current  implementation  of  the  CRMF 
at  Member  State  level,  where  relevant  through  EU-
level support  
Analyse,  determine  and  put  forward  appropriate  IT 
solutions, where relevant through EU-level support 

The vast majority of Member States have either completed or are in the process of carrying 
out analysis in this area, while nearly all the remaining Member States have some planned.  
Nearly  half  (13)  of  the  Member  States  reported  planned,  ongoing  or  completed  work  to 
analyse  and  develop  their  IT  systems.  These  involve  various  IT  systems  and  capacities,  the 
most commonly reported is analysis related to the forthcoming implementation of ICS2. This 
is a permanent action.  

4.1.2 

PERMANENT 

Identify  and  address  weaknesses  and  inappropriate 
variances by non-IT solutions 

Identifying  and  addressing  weaknesses  and  inappropriate  variances  by  non-IT  solutions  is  a 
permanent  activity.  A  significant  non-IT  solution  to  address  variances  in  harmonised 
implementation  of  customs  competences  throughout  the  EU  is  the  EU  Competency 
Framework  (EU  Customs  CFW)  which  primarily  aims  to  harmonise  and  raise  customs 
performance standards throughout the EU. 

Action 4.2 

4.2.1. 

ONGOING 

Develop  possible  further  capacities  and  enhance 
cooperation  and  coordination  between  customs 
authorities 
Identify and determine - at Member State and EU level 
- possible further capacities that might be necessary to 
support more effective and efficient risk management, 
including increased responsiveness to newly identified 
risks 

The Commission, in close cooperation with Member States, has improved the use of CRMS 
for exchanging risk information. 
A complete reshape (‘CRMS2’) was decided on the basis of 2 years work with the Member 
States and with the users of the system. 
The development phase of CRMS 2 has now been completed and the construction phase has 
begun. This will be followed by a transition phase, which includes testing.  
CRMS2 is expected to go live in Q4 2021. 

4.2.2. 

PERMANENT 

Analyse  and  identify  options  for  further  enhanced 
proactive  cooperation,  coordination  and  better  risk 
assessment of the supply chain on a real-time basis in 
cooperation with the Member States 

This  is  a  permanent  activity.  Numerous  experts  and  contact  groups  continuously  work  to 
further enhance proactive cooperation, coordination and better risk assessment of the supply 
chain on a real-time basis (ODYSSUD, ICARUS, LFCG, RALFH, CDTPG, ConTraffic-ENS, 

120 

 
 
 
 
 
 
ConTraffic-SAD,  Europol  SOCTA,  security  risk  rules,  financial  risk  rules,  and  different 
CRMS network subgroups).  

4.2.3. 

ONGOING 

Put  forward  and  implement  appropriate  solutions 
(including  IT)  for  developing  necessary  further  risk 
management capacities at Member State and EU level 
(also  considering  solutions  proposed  by  EU-funded 
research projects), including enhanced cooperation and 
coordination between the customs authorities 

The  Commission  and  the  Member  States  carried  out  detailed  work  and  progress  was  made 
towards  the  introduction  of  massive  new  flows  of  better  data  under  Release  2  of  ICS2  that 
will collect a full set of pre-arrival information for the entire air transport.  

The Surveillance database records and centralises on a daily basis all EU trade data (imports 
and  exports)  provided  by  national  customs  authorities.  The  SURV3  system  introduced  an 
upgrade to the standard exchange of information in the earlier (SURV2) system to align the 
system  with  UCC  requirements.  The  upgrade  implemented  electronic  data-processing 
techniques  and  established  adequate  functionalities  needed  for  processing  and  analysing  the 
full surveillance dataset obtained from Member States 

4.3.1. 

Action 4.3 

PERMANENT 

Develop  further  national  and  EU  level  customs  threat  and  risk 
assessments for the full range of threats and risks 
Work  on  a  strategic  analysis  to  identify  trends  of  illicit  trade 
crossing  EU  borders  with  a  view  to  better  identifying  common 
profiles of illicit trade within the CRMF 
This  is  a permanent  activity. For instance, over the last few  years, the  relevant  Commission 
departments and customs authorities have become more and more involved Europol’s work on 
Strategic Organised Crime Threat Assessment (SOCTA) in order to better match terminology 
and include the customs angle.   

4.3.2 

PERMANENT 

Develop customs threat and risk assessments at national level and 
ensure that their results are shared and deployed in the CRMF and 
used for development and refinement of the common risk criteria 
and standards, where appropriate 

This  is  a  permanent  activity.  Member  States  share  the  results  of  their  threat  and  risk 
assessments through RIFs via CRMS. 

4.3.3. 

PERMANENT 

Develop  customs  threat  and  risk  assessments  at  EU  level  and 
ensure  their  results  are  shared  and  deployed  in  the  CRMF  and 
used for development and refinement of the common risk criteria 
and standards, where appropriate 

This is a permanent activity. Commission departments share the information they obtain and 
the results of their analysis through RIFs via CRMS (e.g. RIF on fulfilment traffic (ICARUS), 
all the work on COVID-19, CRC on firearms, Ebola, etc.). 

Action 4.4 

4.4.1.  ONGOING 

Further develop EU common risk criteria and standards (CRC) for 
the full range of risks, in cooperation with the competent services 
Develop further, under the CRMF, EU common risk criteria, where 
relevant,  together  with  competent  authorities  for  the  full  range  of 

121 

 
 
 
 
 
 
 
risks associated with goods’ movements 
A  Commission  implementing  decision  on  common  risk  criteria  and  standards  for  air  cargo 
security pre-loading  risk analysis should be adopted in  the second half of 2020 at  the latest 
and will be supported by the common operational guidance. 
4.4.2.  COMPLETED  Propose  and  adopt  appropriate  legal  acts  for  the  new  EU  common 

As already reported in 2016, this action is completed. 

risk criteria 

Action 4.5 

4.5.1. 

PERMANENT  

Systematically monitor, evaluate and improve  implementation of 
the  EU  risk  management  by  the  Member  States  and  measure 
performance of the CRMF 
Continue to evaluate and improve the effectiveness and efficiency 
of the existing CRC; improve the arrangements for CRC review 

The  Commission  developed  the  CRMF  evaluation  cycle  model  with  all  Member  States  and 
will continue its work in this area.  

4.5.2. 

PERMANENT 

a 

approach 

structured 

for 
Develop 
systematically  monitoring, 
improving 
implementation  of  EU  risk  management  by  the  Member  States 
and  measuring  the  performance  of  the  CRMF,  to  ensure 
harmonised, effective and efficient implementation 

(evaluation 
and 

evaluating 

cycle) 

This  is  a  permanent  activity.  CRC  evaluation  reports  are  provided  every  year  on  the 
implementation of the security and safety risk assessment at entry, export and transit. 
For financial risks, it is under development in the context of the FRC decision. Further actions 
need to be engaged to set up a review cycle. The first review cycle for the FRC decision is 
planned for the end of 2021. 

5.5.  Objective 5: Promoting interagency cooperation and improving information 
sharing between customs and other authorities at the Member State and EU 
level to ensure effective risk management 

Action 5.1 

5.1.1 

PERMANENT 

Develop  further  cross-sectoral  cooperation  arrangements, 
improve  sharing  and  accessibility  of  (risk)  information  and 
customs involvement in risk and threat assessments 
Develop further the cooperation arrangements between customs 
and  other  competent  authorities,  with  a  view  to  ensuring 
complementarity of roles in supply chain risk management 

  Achievements  made  in  respect  to  this  sub-action  include  the  Official  Control 
Regulation  (OCR)  2017/625.  The  new  OCR  gradually  became  applicable  with  the 
main  application  date  being  14  December  2019.  In  total  33  delegated  and 
implementing  acts  have  been  developed  to  supplement  the  OCR  and,  were  adopted 
prior  to  14th  December  2019.  21  Delegated  and  Implementing  acts  developed  to 
supplement OCR are directly related to the official controls of the animals and goods 
entering the Union. 

  Together  with  Interpol  and  Europol,  various  coordinated  actions  were  carried  out  to 
tackle  illegal  wildlife  trafficking,  including  joint  police  and  customs  operations  in 
April-May 2019 targeting the illegal trade in reptiles. 

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  On  Forest  Law  Enforcement  Governance  and  Trade  (FLEGT),  the  Commission 
updated the 2014 ‘Customs and FLEGT implementation Guidelines’ and published the 
related ‘Guidance’ in January 2020. This updated guidance also explicitly refers to the 
use of risk management in profiling and controls on timber and timber products under 
the FLEGT licensing scheme. 

 

In  2018,  with  the  modification  of  the  Council  Regulation  (EU)  No 904/2010  on 
administrative  cooperation  in  the  field  of  VAT,  the  cooperation  between  tax  and 
customs  authorities  on  VAT  exempt  importations  (CP42  and  63)  has  been 
significantly enhanced. Customs authorities now have access to the VAT information 
exchange system  for validating VAT numbers at the moment  of importation  and for 
controlling the correct reporting of these transactions for customs and VAT purposes. 
Tax  authorities  were  also  granted  access  to  Surveillance  3  to  identify  unreported 
transactions.  Once  the  practice  in  using  these  tools  will  be  established,  the 
communication between tax and customs on this issue will be streamlined and fraud 
detection will be more efficient. 

5.1.2 

PERMANENT 

Ensure  customs  participation  in  relevant  supply  chain  security 
threat and risk assessments at national  and EU levels and ensure 
the integration of this work into customs risk management of the 
supply chain 

This  is  a  continuous  action.  Member  States  reported  substantial  progress  on  this  action, 
notably regarding the exchange of and access to information between authorities (see § 2.5.1). 

5.1.3 

PERMANENT 

Develop together with the competent authorities the EU common 
risk  criteria  and  standards  and  mechanisms  for  their  regular 
evaluation and review, where appropriate 

This  is  a  permanent  activity,  which  is  ongoing  for  product  safety,  cash  control  and  to  be 
started for IPR.  

5.1.4. 

PERMANENT 

Improve  accessibility,  sharing  and  utilisation  of  risk  information 
from  other  authorities  and  ensure  its  timely  integration  into  the 
risk management of the supply  chains,  including  in  ad hoc/crisis 
situations 

Actions  were  taken  towards  enhancement  of  customs  cooperation  with  security  and  border 
management  authorities  to  support  more  joined-up  external  border  management  and  timely, 
more effective and coherent actions across agencies to counter border security risks. 

The EU introduced new legislative rules in 2019 on interoperability between EU information 
systems in the area of justice and home affairs.  

In 2018, Commission and Member State practitioners carried out a preliminary assessment of 
the  interoperability  of  security  and  border  management  systems  with  customs  systems.  The 
expert  group  presented  their  assessment  report  to  the  Council’s  Standing  Committee  on 
Operational Cooperation on Internal Security (COSI) in February 2019. 
The Commission and Member States will continue activities in this area.  
5.1.5. 

PERMANENT  Promote complementarity and coherence of initiatives from other 

123 

 
 
 
 
 
 
 
 
 
authorities  aimed  at  improving  security  of  the  supply  chain  to 
avoid undue disruption or burden to trade 

This is a permanent exercise. 

The new EU Security Union Strategy for 2020-2025 adopted on 27 July 2020 underlines the 
importance of a secure external border and states that ‘Customs activities in detecting safety 
and security risks in all goods before they arrive in the EU and in controlling goods when they 
arrive are crucial in the fight against cross-border crime and terrorism’. 

5.2.1 

Action 5.2 

the  EU  Authorised  Economic  Operator 

(AEO) 
Strengthen 
programme  through  broader  recognition  and  promotion  by  other 
authorities 
Strengthen 
(AEO) 
programme  through  its  broader  recognition  by  other  authorities  in 
the  relevant  existing  or  future  partnership  programmes  or  in  the 
control regimes stemming from other policies 
Trade partnership programmes have been set up by various government authorities. Further 
streamlining such programmes with the AEO programme can potentially help close security 
gaps,  while  avoiding  duplication  of  administrative  efforts  for  both  authorities  and  the 
operators.    

the  EU  Authorised  Economic  Operator 

ONGOING 

Action 5.3. 

5.3.1 

PERMANENT 

Promote use of good practices and cooperation methods between 
customs and other national authorities 
the  exchange  of  good  working  practices  and 
Encourage 
cooperation  methods  between  Member  State  customs  and  other 
national authorities (Customs 2020, CCWP) 

This is a permanent action. Progress during the reporting period included in particular: 

 

In May 2017, the EU adopted new crime priorities for the 2018-2021 EU Policy Cycle 
for serious international and organised crime (‘EMPACT’).  

  Work is ongoing to further strengthen the synergies between the 2018-2021 EU Policy 

 

Cycle / EMPACT and the 10th CCWP Action Plan for 2020-2021. 
 The  Reporting  Formalities  Directive  2010/65  has  been  replaced  by  Regulation 
2019/1239  establishing  a  European  Maritime  Single  Window  environment.  The  new 
regulation will be fully applicable by 2025. 

124 

 
 
 
 
 
 
 
 
 
 
 
 
5.6.  Objective  6:  Develop  cooperation  with  trade  to  secure  and  facilitate 

legitimate trade 

Action 6.1 

6.1.1. 

PERMANENT 

Continue  to  strengthen  and  promote  the  AEO  programme,  by 
addressing  any  relevant  weaknesses  identified  and  providing 
further benefits 
Continue  to  strengthen  the  AEO  programme  by  addressing  any 
relevant  weaknesses  identified  through  the  monitoring  and 
evaluation  of  the  implementation  of  the  programme  and  by 
ensuring its harmonised implementation throughout the EU. 

This is a permanent activity. 
During the reporting period, particular progress was achieved. The Commission and Member 
States have agreed on an action plan to further strengthen the EU AEO Programme. Activities 
include fact-finding/field visits to all Member States to find out how the AEO programme is 
implemented  and  to  identify  best  practices.  The  visits  started  in  July  2019,  but  have  been 
disrupted due to the COVID-19 crisis.  

6.1.2. 

PERMANENT 

Identify and develop enhanced benefits for AEOs to be given by 
customs, propose and adopt adequate legal acts. 

This  is  a  permanent  activity.  During  the  reporting  period  particular  progress  was  achieved 
through the implementation of the UCC. 

Action 6.2 

6.2.1. 

PERMANENT 

Improve  the  knowledge  of  supply  chains,  raise  trade 
awareness and exploit valuable data available to trade 
Increase  supply  chain  visibility  by  ensuring  that 
valuable  additional  data  (not  required  by  customs 
legislation)  available  to  traders  and  made  available  to 
customs is exploited for risk management purposes by 
getting  access  to  economic  operators’  knowledge  and 
information 

The  PEN-CP  (Pan-European  Network  of  Customs  Practitioners)  continuously  collects  and 
analyses  customs security  user need ideas, across the six PEN-CP customs security themes. 
(see § 2.6.1.12) 

6.2.2 

ONGOING 

Improve  data  quality  and  knowledge  on  supply  chain 
vulnerabilities  through  close  engagement  with  trade 
organisations at EU and Member State level 

The  Commission  has  made  notable  progress  in  implementation  of  this  action  within  the 
framework of the ICS2 programme. It focused on improvements of supply chain data quality 
in  the  context  of  the  advance  cargo  information  requirements,  i.e.  new  entry  summary 
declaration and functional / technical design of the ICS2 system. Actions were taken in close 
work with the national authorities and trade both at the legal and technical level. On the legal 
side, necessary amendments to the UCC Annex B Delegated and Implementing Regulations 
were  integrated  in  order  to  provide  to  economic  operators  clear  and  transparent  data 
requirements, and as well as requirements for the format and structure of ENS data, consistent 
with the EU customs data model. On the technical side, COM completed common functional 
and technical specifications for the ICS2 Harmonised Trader Interface for Releases 1 and 2 of 
the ICS2 system. 

6.2.3 

ONGOING 

Identify  existing  solutions  and,  where  necessary,  put 
forward appropriate solutions 

The  Commission  has  made  notable  progress  in  implementation  of  this  action  within  the 

125 

 
 
  
 
framework of the ICS2 programme. Details are described under Action 6.2.2. 

6.2.4 

ONGOING 

Implement the appropriate IT solution(s), if necessary, 
to  ensure  that  valuable  data  available  to  operators  is 
exploited by authorities for risk management purposes 
This  action  is  partly  supported  by  ICS2.  In  this  context,  The  Commission  finalised 
construction  of  two  core  central  ICS2  components,  notably  Shared  Trader  Interface  and 
Common Repository, for start of implementation of ICS2 Release 1 (15March 2021 - postal 
and  express  consignments  for  air  pre-loading  data  submissions  and  risk  analysis).  These 
components will be critical in ensuring that in future trade provides ENS data in compliance 
with  the  legal  requirements  and  EU  level  harmonised  trader  interface  specifications.  It  also 
started work on Releases 2 and 3 of ICS2 that will implement new, improved ENS and risk 
analysis processes for pre-arrival processes for all transport sectors and business models. 

Action 6.3 

6.3.1. 

COMPLETED 

Promote  compliance  management  by  customs  administrations  in 
close cooperation with trade 
Identify  best  practices  in  the  implementation  of  compliance 
management  by  comparing  national  programmes,  and  continue 
raising awareness among economic operators of the importance of 
managing their own compliance with customs regulations 

This  sub-action  was  regarded  as  completed  in  the  previous  progress  report.  The  respective 
Project  Group on Compliance, which  was mapping practices including  client  segmentation, 
presented its findings in December 2015.  

6.3.2. 

COMPLETED 

Explore  possibilities  for  establishing  a  harmonised  approach  to 
client  segmentation  as  an  element  of  the  overall  concept; 
complementing  the  AEO  programme  and  supporting  more 
effective and efficient risk management 
The action is finalised.  The presentation of the roles of AEO in the supply chain are made 
available in the Customs Union Performance. 

6.3.3. 

Subject  to  the  feasibility  of  harmonised  standards  in  the  area  of 
client segmentation and their possible incorporation into customs 
risk  management,  put 
the  appropriate  approach, 
supported by the business case. 
Not being pursued at this time given other high priorities in the risk management area. 

NOT 
STARTED 

forward 

126 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Action 6.4 

6.4.1. 

ONGOING 

Promote  the  re-use  of  customs  data  submitted  electronically  by 
economic  operators  to  streamline  customs  procedures,  reduce 
costs and improve efficiency 
With  the  proposed  legal  amendments  of  UCC  Annex  B,  the 
Commission  introduced  data  requirements  to  ensure  a  stronger 
link  between  different  phases  of  customs  entry  processes.  This 
will  allow,  once  the  new  IT  systems  under  the  UCC  are  fully 
implemented,  national  authorities  and  economic  operators  to  re-
use  a  wealth  of  data  already  submitted  at  an  earlier  stage  for 
subsequent  processes.  This  data  will  be  made  available  without 
legal obstacles (e.g. ENS-Presentation-Temporary Storage). 

The Commission harmonised the data requirements as well as the 
format  of  that  data  between  the  different  procedures  and  IT 
systems.  For  example,  on  entry  procedures.  Even  though  the 
implementation  of  presentation,  temporary  storage  declaration 
systems will be national, the requirements will be harmonised and 
very much aligned to the ENS. The ENS data structure has been 
taken  over  to  presentation  notification  and  to  temporary  storage 
declaration, which enables the trade to  have  a simpler  IT system 
on their side. 

6.4.2. 

COMPLETED 

Analyse,  in  cooperation  with  trade,  whether  re-use  of  data  will 
increase  efficiency  of 
identified  procedures  for  economic 
operators and customs administrations 
The data requirements as defined in the UCC legislative package have been aligned with the 
WCO data model. 

6.4.3. 

COMPLETED 

Put  forward  appropriate  proposals  to  agree  with  Member  States 
and economic operators 

As  already  reported  in  2016,  the  EU  customs  data  model  can  be  seen  as  a  supporting 
instrument  for  Member  States  and  trade.  This  data  model  also  provides  for  specific  views 
such as the ‘consignment view’, which allows for the mapping of the EU safety and security 
data against the WCO data model. 

6.4.4. 

COMPLETED 

Draft  adequate  legal  basis  to  enable  and  support  implementation 
in practice 

As  already  reported  in  2016,  the  analysis  of  the  UCC  delegated  and  implementing  act  data 
requirements has been finished and agreed with Member States and trade stakeholders.  

127 

 
 
 
 
 
5.7.  Objective  7:  Tap  the  potential  of international  cooperation,  to  improve  risk 
management  of  the  supply  chain,  for  better  identification  of  risks,  more 
effective risk mitigation and cost reduction for operators and authorities 

Action 7.1 

7.1.1. 

PERMANENT 

international  cooperation 

through  multilateral  and 

Develop 
bilateral initiatives 
On  the  basis  of  the  objectives  and  priorities  of  the  overall 
strategy, develop international cooperation models in the area of 
risk  management  and  supply  chain  security,  including  AEO 
mutual  recognition  schemes,  development  of  trusted  and  fluid 
trade lanes and necessary exchanges of information 

This is a permanent activity. The following activities took place during the reporting period  
(i) on AEO mutual recognition: implementation of the existing agreements with China, Japan, 
US,  Norway  and  Switzerland;  negotiations  with  Canada;  and  preparatory  steps  with 
Singapore  
(ii)  on  the  EU-China  Smart  and  Secure  trade  Lane  Pilot  (SSTL):  the  number  of  operators, 
SSTL  ports  and  trade  lanes  have  increased  and  the  pilot  was  extended  to  other  modes  of 
transport under the current data exchange conditions.  In particular, the number of rail lanes 
between  the  EU  and  China  has  increased and  several  Member  States  have  started  air 
lanes.  Two e-commerce platforms have also joined SSTL, thereby facilitating the tackling of 
high volume items. 

7.1.2. 

PERMAMENT 

Pursue the existing bilateral  cooperation, including piloting with 
third countries,  with  a view to  reaching  a stable  operational  and 
legal basis for full implementation 

This  is  a  permanent  activity.  During  the  reporting  period  the  Commission  continued  its 
bilateral cooperation with third countries as described in detail in Chapter 2.7.2 of this report.  

7.1.3. 

PERMANENT 

Develop 
bilateral initiatives 

international  cooperation 

through  multilateral  and 

This  is  a  continuous  activity.  During  the  reporting  period,  cooperation  continued  through 
multiple multilateral and bilateral initiatives. 

Action 7.2 

7.2.1. 

ONGOING 

Implement  appropriate  cost-effective  IT  solutions 
international cooperation 
Implement  necessary 
enabling 
cost-effective 
international  cooperation  to  support  EU  customs  authorities  in 
detecting  risks  with  the  use  of  utility  blocks  (UB  1  -  exchange  of 
AEO  mutual  recognition  data  and  information  from  customs 
transaction systems; and UB 2 - relevant risk information) 

to  enable 

solutions 

IT 

The  UB1  is  used  for  the  five  AEO  mutual  recognition  agreements  on  data  exchange  (US, 
China,  Japan,  Switzerland  and  Norway)  and  works  well.  It  will  also  be  the  basis  for  the 
future MRA data exchange.    

128 

 
 
 
  
 
 
 
 
 
Discussions on UB 2 took place in the WCO SAFE Working Group. An implementation is 
currently not pursued. 

7.3.1. 

Action 7.3 

PERMANENT 

Ensure that the EU and its Member States play a proactive role in 
the  development  of  global  standards  in  the  relevant  multilateral 
fora 
Continue  ensuring 
establishment of international standards 
The  EU’s  input  has  contributed  to  the  development  of  international  standards,  namely  the 
‘utility  blocks’  that  are  either  approved  or  still  under  development.  There  are  three  utility 
blocks that the EU has helped/helps develop: (i) UB1 - exchange of AEO MR data; (ii) UB2 - 
exchange of information from customs transaction systems; and (iii) UB3 - exchange of risk-
relevant information. The EU will continue its activities. 

input  and 

the  EU’s 

leading 

role 

in 

7.3.2. 

PERMANENT 

Ensure  that  the  international  norms  and  standards  are  respected 
and implemented in the EU 

The  Commission  and  Member  States  continuously  strive  to  ensure  that  international  norms 
and standards are respected and implemented in the EU.  

129