REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods
Date: 2022-11-10
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: cultural heritage, exchange of information, fight against crime, heritage protection, illicit trade, import (EU), import licence, information system, surveillance concerning imports, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.11.2022  COM(2022) 580 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods   
 
 
Table of Contents 

1. 

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

2.  OBJECTIVES TO BE MET ............................................................................................................ 4 

3.  PROJECT ARCHITECTURE AND PLANNING APPROACH ................................................... 5 

Phase 1 – Conceptualisation ................................................................................................................ 5 

Phase 2 – System development: .......................................................................................................... 5 

Phase 3 – Deployment and Operation: ................................................................................................ 5 

4.  PROGRESS OVERVIEW............................................................................................................... 6 

Adoption of implementing provisions ................................................................................................. 6 

Conceptualisation – Business Case ..................................................................................................... 6 

Project definition - Vision Document.................................................................................................. 6 

Project development ............................................................................................................................ 7 

Methodology: approach used for the implementation of the ICG System .......................................... 8 

High-level planning ............................................................................................................................. 8 

Request for Changes (RfCs) ................................................................................................................ 9 

External synergies ............................................................................................................................... 9 

Cooperation between DG TAXUD and DG SANTE .......................................................................... 9 

Work with the Project Group on ‘Digitalisation of Cultural Goods’ .................................................. 9 

5.  RISKS FOR DELAYS .................................................................................................................. 10 

Risk 1 – Staff allocation .................................................................................................................... 10 

Risk 2 – Covid-19 pandemic and Ukraine crisis ............................................................................... 10 

Risk 3 – Proposal for an EU Single Window Environment for Customs .......................................... 11 

Mitigation actions .............................................................................................................................. 11 

6.  CONCLUSIONS ........................................................................................................................... 11 

ANNEX I: MULTIANNUAL STRATEGIC PLANNING............................................................... 13 

ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE ............ 15 

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Business Case 

Vision Document 

ICG system 

TRACES 

GLOSSARY 

The document that provides the IT project justification 
and defines its budgetary requirements. 

The Vision Document elaborates on the assumptions 
made in the Business Case Document. It records the 
system owner/system supplier partnership and 
understanding of the system at the time of writing. 

Import of Cultural Goods system - the centralised 
electronic system for the import of cultural goods. 

Trade Control and Expert System - the European 
Commission's multilingual online platform for sanitary 
and phytosanitary certification. 

EU CSW - CERTEX 

EU Customs Single Window - Certificates Exchange. 

MFF 

BPM 

Multiannual Financial Framework; the EU long-term 
budget, running from 2021 to 2027. 

Business Process Model - the application-level Business 
Process Model describes the entirety of the business 
process and flow of information for an application, 
completing the System Business Process Model created 
during the “System Specification” phase, to take into 
account the application’s own needs. 

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1.  INTRODUCTION 

Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 20191 
on  the  introduction  and  the  import  of  cultural  goods  (hereafter  “the  Regulation”)  aims  to 
prevent the illicit trade in cultural goods, in particular when it contributes to the financing of 
terrorist  activities,  and  to  prohibit  the  import  into  the  customs  territory  of  the  Union  of 
cultural goods exported illegally from third countries.  

The  Regulation  subjects  the  import  of  certain  cultural  goods  that  are  considered  to  be 
particularly  endangered  (namely,  archaeological  objects  and  parts  of  monuments  that  have 
been dismembered) to  import licences and others, which  are considered  less endangered, to 
importer statements and  ensures that they undergo uniform  controls  when imported into the 
Union.  Certain  imports  of  cultural  goods  that  are  intended  for  specific  uses  (educational, 
scientific or research-related) are exempted from these documentary requirements. 

The obligation for importers to obtain an import licence or draw up and submit an importer 
statement  to  customs  will  only  start  to  apply  from  the  moment  that  a  centralised  electronic 
system (the ICG system) will become operational.  

The  ICG  system  will  not  only  serve  as  a  means  for  the  accomplishment  of  formalities  by 
operators, but  also  for the storage  and the  exchange of information  between Member States 
administrations in charge of implementing the Regulation (customs and cultural authorities).  

The  good  functioning  of  the  ICG  system  is  closely  linked  to  the  success  of  the  EU  Single 
Window Environment for Customs2, which aims to provide a legal basis for the functioning of 
the  EU  Customs  Single  Window  Certificates  Exchange  (EU  CSW-CERTEX).  The  “EU 
Single Window Environment for Customs” is designed to provide quicker and more efficient 
sharing  of  electronic  data  between  national  customs  administrations  and  EU  regulatory 
authorities  across  policy  domains,  creating  a  digital  framework  for  enhanced  cooperation 
between  all  border  authorities  and  facilitate  the  administrative  checks  at  the  moment  of 
customs clearance. 

The EU CSW-CERTEX represents  the  central  component of the EU Single Window  and is 
developed by the Commission to link the national Single Window Environments for customs 
to  Union  systems  or  databases  managing  non-customs  requirements  so  that  all  relevant 
authorities can access the relevant data and collaborate more easily on border checks.  

EU CSW-CERTEX covers exchanges for a multitude of other non-customs formalities hosted 
in  EU  databases  and  regulated  by  different  legal  acts  under  the  responsibility  of  various 
Commission Directorates, including the formalities related to cultural goods. 

Every  12  months  from  the  entry  into  force  of  the  Regulation  and,  until  the  ICG  system 
becomes operational, the Commission is to present a report to the European Parliament and to 
the Council on the progress made with establishing this electronic system.  

1 OJ L 151, 7.6.2019, p. 1–14 
2 The  formal adoption and publication of the  Regulation establishing the EU Single Window Environment for 
Customs is expected in Q4 2022. See Single Window proposal: 
https://taxation-customs.ec.europa.eu/system/files/2020-10/201028_commission_proposal_single_window.pdf  

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The Commission presented its first annual progress report in June 20203. The report outlined 
the action taken by the Commission services during the first year after the Regulation entered 
into  force,  namely:  (a)  the  preparatory  work  for  adopting  the  necessary  implementing 
provisions,  and  (b)  the  consultations  with  the  Member  States  via  the  Expert  Group  for 
customs  issues  related  to  cultural  goods  and  the  Project  Group  for  the  import  of  cultural 
goods.  

The  second  annual  progress  report  was  submitted  in  July  20214.  It  presented  the  progress 
achieved with the adoption of the Commission Implementing Regulation (EU) 2021/10795, as 
well as the roll-out of Phase 1 – ‘Conceptualisation’ of the ICG project, the work carried out 
by the Project Group created for this purpose and the advancement of the Business Case and 
the Vision Document for the ICG project. 

The third annual progress report covers the period from July 2021 to June 2022. For the sake 
of completeness, the objectives to be met, the project architecture and the planning approach, 
which  are  detailed  in  the  first  annual  progress  report,  are  briefly  mentioned  also  here.  The 
overall assessment of the progress made and the identified risks for delay are summarised in 
the conclusions section of this report. 

2.  OBJECTIVES TO BE MET 

The ICG system is to become operational by 28 June 2025 at the latest, as on that date, it will 
become mandatory for all operators to obtain import licences or submit importer statements to 
customs through that electronic system, in order for them to be able to import6 legally specific 
categories of cultural goods into the Union.  

After the adoption, in June 2021, of Commission Implementing Regulation  (EU) 2021/1079 
and the approval of the Vision Document, the development phase of the ICG system begun. It 
will cover about two years, at the end of which, the third phase will start. In the third phase, 
the  ICG system  will be  interconnected to  the EU-CSW CERTEX, to  allow the exchange of 
documents  with  Member  States  customs  systems.  In  parallel,  training  sessions  will  be 
organised 
ICG  system’s  operational 
functionalities.  

their  administrations  with 

to  familiarise 

the 

Alongside other activities of the Commission services in the field of customs, the project on 
the import of cultural goods is also planned in detail through the Multi-Annual Strategic Plan 
for electronic Customs 2019 revision7 (MASP-C rev. 2019). An excerpt of the planning of the 
project on the import of cultural goods from MASP-C rev. 2019 is provided in Annex I to this 
report (table 1).  

As  already  explained,  part  of  the  project  on  the  import  of  cultural  goods  is  developed  also 
within the EU Single Window Environment for Customs (MASP-C rev 2019 Fiche 1.13) of 

3 COM(2020) 342 final  
4 COM(2021) 358 final 
5  Commission  Implementing  Regulation  (EU)  2021/1079  of  24  June  2021  laying  down  detailed  rules  for 
implementing certain provisions of Regulation (EU) 2019/880 of the European Parliament and of the Council on 
the introduction and the import of cultural goods; OJEU L 234 of 2.7.2021, p. 67. 
6 The Regulation defines as ‘import’ the placement of goods under the following customs procedures: release for 
free  circulation;  storage  in  customs  warehouses  or  free  zones;  temporary  admission;  and  end-use,  including 
inward processing. 
7 See https://ec.europa.eu/taxation_customs/general-information-customs/electronic-customs_en. 

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which  EU  CSW-CERTEX  is  the  key  IT  system.  An  excerpt  of  the  planning  of  EU  CSW-
CERTEX from MASP-C Fiche 1.13 is provided in Annex I to this report (table 2). 

3.  PROJECT ARCHITECTURE AND PLANNING APPROACH 

As explained analytically in the first annual progress report, the Project Architecture is based 
on  the  methodology  provided  for  in  MASP-C  rev.  2019  and  its  Annexes,  including  the 
Governance  Scheme8,  the  EU  Customs  Business  Process  Modelling  Policy9  and  the  IT 
strategy10. A comprehensive roadmap, with the main project phases and the critical milestones 
is detailed in Annex II. 

Despite  of  the  project  progressing  on  several  levels  at  the  same  time,  it  can  be  figuratively 
divided into three phases: 

Phase  1  –  Conceptualisation:  Initially,  a  Business  Case  is  prepared,  providing  the  project 
justification  and  defining  budgetary  requirements.  Further,  the  Level  3  (user  requirements 
BPMs) and Level 4 (functional requirements BPMs) are produced, with the aim of providing 
a  visual  representation  of  business  processes  and  detailed  functional  requirements  to 
guarantee that the envisaged operational IT system will function as set out in the legislation. 
Next  a  Vision  Document  is  produced,  which  provides  more  detailed  information  on  the 
project definition in terms of architecture, cost, time, and risk, as well as information such as 
milestones,  deliverables  and  project  organisation.  These  documents  reflect  the  discussions, 
and the content of the implementing act to be produced by the Commission.  

Phase 2 – System development: Following the provisions of the implementing act, and the 
production  of  user  requirements  and  the  functional  specifications  for  the  system,  technical 
specifications  on  how  the  system  will  be  constructed  are  developed.  These  technical 
specifications include: the architecture to be used, the messages to be submitted by economic 
operators, the interfaces to other systems, testing plans, etc. 

Once  the  design  of  the  system  is  ready  from  a  conceptual  perspective  and  the  deliverables 
listed in Table 1, Milestones 1 and 3 (see Annex I) are produced, a more in-depth work begins 
and more technical aspects are taken into account in the Application & Service specifications 
and Technical System Specification documents, which are the concretisation of the Business 
Case (prepared during Phase 1) and the Vision Document (prepared during Phase 2). The ICG 
will be integrated in the existing TRACES platform and therefore reuse most of the existing 
specifications, architecture, messages and interface. 

Phase  3  –  Deployment  and  Operation:  The  actual  IT  development  phase  begins 
(Construction Phase), which is followed by a Transition phase where the early versions of the 
ICG  system  will  be  gradually  rolled  out  to  the  different  groups  of  users  and  tests  are 
performed to  ensure that, by  28 June 2025, operators and  competent  authorities are capable 
and  well  trained  in  the  use  of  the  system.  To  this  phase  will  follow  a  6  months  after-care 
period,  in  which  the  system  will  be  fine-tuned  to  match  any  operational  needs  that  may 
become evident only after an IT system becomes mandatory, and to ensure that operations are 
running smoothly. 

8 https://ec.europa.eu/taxation_customs/sites/taxation/files/2019_masp_annex3_en.pdf  
9 https://ec.europa.eu/taxation_customs/sites/taxation/files/2019_masp_annex4_en.pdf  
10 https://ec.europa.eu/taxation_customs/sites/taxation/files/2019_masp_annex5_en.pdf  

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It  is  to  be  noted  that  the  ICG  system  will  be  interconnected  with  Member  States’  customs 
administrations  via  the  EU  CSW-CERTEX  by  3  March  2025,  following  the  Commission 
proposal on an EU Single Window Environment for Customs11 to allow customs automated 
controls on the documents issued for the import of cultural  goods. This activity will require 
Conformance Testing. 

4.  PROGRESS OVERVIEW  

Adoption of implementing provisions 
During  the  previous  phase  the  Commission  adopted  the  necessary  implementing  provisions 
for  the  establishment  of  the  electronic  system.  In  order  to  get  a  better  perspective  from  a 
practical  implementation  point  of  view,  it  consulted  extensively  with  Members  States 
representatives in  the Expert Group on customs issues related to  cultural  goods12 and in  the 
Cultural Goods Committee. 

Art market associations have been informed by the Commission services about the progress of 
work at every opportunity, so as to ensure that the practical implementation of the Regulation 
is  well  adapted  to  the  realities  of  the  market.  During  the  adoption  procedure,  the  draft 
implementing act was also made available online for consultation to stakeholders for a 4-week 
period.  

Conceptualisation – Business Case 
The  Business  Case  was  approved  by  the  Information  Technology  and  Cybersecurity  Board 
(ITCB)13 of the European Commission on 23 September 2020 and by the Electronic Customs 
Coordination  Group  (ECCG)14  on  16  October  2020  without  comments.  The  Business  Case 
explores  the  different  alternatives  and  confirms  that  the  TRACES  system  hosted  by  the 
Commission  Directorate-General  for  Health  and  Food  Safety  (DG  SANTE)  is  the  most 
suitable  platform  to  develop  the  ICG  system,  as  most  of  the  functionalities  required  for 
certification and licencing schemes are well developed in that platform. 

Project definition - Vision Document 
The Vision Document further refines the initial assessment made in the business case, and it 
details  the  methodological  approach,  the  project  governance  and  the  synergies  with  other 
projects.  As  a  result,  the  ICG  system  will  be  developed  in  partnership  between  the 
Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD) and DG 
SANTE,  leveraging  on  the  long-term  cooperation  and  synergy  between  these  two 

11 The political trilogue took place on 19/05/2022 between high representatives from DG TAXUD, the EP and 
the Presidency of the Council and achieved a successful outcome to the negotiations. The co-legislators endorsed 
the  parts  of  the  text  preliminarily  agreed  at  the  technical  level  and  reached  political  agreement  on  several 
additional themes that emerged from their proposed amendments to the Commission’s original proposal. Formal 
adoption  and  publication  of  the  Regulation  establishing  the  EU  Single  Window  Environment  for  Customs  are 
expected in Q4 2022. 
12  The  Expert  Group  is  a  forum  for  the  discussion  of  implementation  issues  of  Union  legislation  on  cultural 
goods pertaining to customs and, in particular, Regulation (EU) 2019/880 on the introduction and the import of 
cultural goods and Regulation (EC) 116/2009 on the export of cultural goods.   
13 The  Information Technology and Cybersecurity Board (ITCB) of the European Commission  is a permanent 
sub-group  of  the  Corporate  Management  Board.  It  ensures  that  resources  and  investments  in  Information 
Technology  are  used  efficiently  and  that  business  needs  are  supported  by  efficient,  secure  and  resilient 
communication and information systems, in compliance with personal data protection principles. It oversees the 
implementation of the European Commission Digital Strategy. 
14 The ECCG is made up out of representatives from all Member States (and Candidate Countries), mandated by 
their administration and with competencies in areas such as legislation, processes & BPM, project management, 
operations, planning and IT-technical aspects. 

6 

 
 
                                                           
Directorates-General  for 
the  collaboration  between  customs  and  partner  competent 
authorities, which to-date has proven to be very successful in the field of import controls of 
animals,  food  and  feed.  The  Vision  Document  was  approved  by  the  Electronic  Customs 
Coordination Group (ECCG) on 25 June 2021. 

Project development  
Given that the legislation15 determining the functioning and legal deadlines of the ICG system 
were  already  adopted,  technical  activities  have  been  well-progressing  during  the  reporting 
period.  Both  level  3  (user  requirements  BPMs)  and  level  4  (functional  requirement  detailed 
BPMs) were reviewed by the Member States and published on ARIS16 Publisher. While this 
package includes the first version of the BPMs, additional updates will be required during the 
development phase.  

Further, the Business Acceptance Criteria (BAC) document was created and delivered in Q1 
2022. This document guides the execution of all business tests, including acceptance tests, as 
a  means  of  validating  the  implementation  against  the  system  and  application  specifications. 
The document contains all the test scenarios17 required to test comprehensively the business 
requirements18  and  functional  requirements19  for  the  ICG  system,  so  as  to  ensure  that  all 
identified business needs can be implemented by it. In order to make this verification, there 
are  four  groups  of  test  scenarios  that  describe  the  business  processes,  pertaining  to  the 
business  areas  falling  under  the  scope  of  the  BAC  document,  i.e.  1)  the  import  license  for 
cultural  goods,  2)  the  importer  statement  for  cultural  goods,  3)  the  general  description 
document and 4) administrative cooperation. 

The  test  scenarios  are  presented  as  sequences  of  steps  describing  end-to-end  processes  as 
defined by the Level 4 BPMs. Based on them, the test cases20 were produced and specific test 
cases  have  been  defined  for  particular  scenarios.  Test  cases  represent  different  business 
workflows  of  a  specific  scenario,  depending  on  input  parameters,  prerequisites  and  all 
information  contained in  a dataset.  Performing all  test cases for a specific scenario allow to 
verify the end-to-end process for positive and negative flows. 

Taking into account that the ICG system will be a TRACES module for which the interface is 
already  designed,  the  import  licence,  importer  statement,  and  general  description  document 
need to be aligned with  the current interface. Therefore, the TRACES environment must be 
configured  and  provisioned  with  test  data  to  allow  and  ensure  the  execution  of  all  test 
scenarios and test cases. 

15 Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction 
and  the  import  of  cultural  goods  and  Commission  Implementing  Regulation  (EU)  2021/1079  of  24 June  2021 
laying  down  detailed  rules  for  implementing  certain  provisions  of  Regulation  (EU)  2019/880 of  the  European 
Parliament and of the Council on the introduction and the import of cultural goods 
16  Architecture  of  Integrated  Information  Systems  (ARIS)  is  an  enterprise  management  framework  that  offers 
methods and techniques for management of business processes. 
17 A test scenario is a set of test cases that ensure that the business process flows are tested from end to end as 
they are described in the L4 BPMs 
18  Business  requirements  highlight  the  main  business  steps  or  functionalities  that  must  be  performed  to 
successfully complete a task and logical grouping of tasks or process, regardless if a system is involved or not. 
19 A functional requirement describes a specific behaviour or function of the system. It describes what the 
system is supposed to accomplish. Each functional requirement should correspond to a business requirement, 
yet a business requirement can have multiple functional requirements. 

20 A test case is a combination of inputs (data  sets), prerequisites (execution conditions) and testing procedure 
that defines a particular software application path to be executed, and the expected results for that combination. 
The expected results are used to verify compliance with a specific requirement(s). 

7 

 
 
                                                           
Thus,  with  the  help  of  the  BAC  document,  user  stories  were  created  and  linked  to  the  test 
cases defined in  the BAC document, verifying the information  needed for the developers to 
estimate and implement the functionalities necessary to meet the requirements. The tool that 
was used for the creation and tracking of these stories is Jira, a software application used for 
project management, in order to ensure the tracking of progress and the specific details related 
to  the  effort  organised  in  structures  that  provide  meaning  for  the  business  users,  developers 
and other relevant roles within the project.  

Methodology: approach used for the implementation of the ICG System 
The  methodological  approach  used  for  the  implementation  of  the  ICG  represents  a  mix 
between the DG TAXUD Electronic Management of Projects Online (TEMPO) methodology 
for the conceptualisation phase and quality assurance and Agile practices used in DG SANTE 
for  development  and  deployment.  In  this  context,  the  regular  internal  meetings  and  demo 
sessions  allow  for  discussing  and  implementing  real  functionalities,  avoiding  too  elaborate 
mock-up  screens.  The  adaptive  planning  allows  for  responding  faster  to  expectations  and 
changes in a flexible way. To get proper feedback from the field and properly implement the 
system, the Member States will be associated on a voluntary basis as soon as there is  a test 
version.  The  test  environment  will  be  accessible  from  the  outside  using  generic  training 
profiles as of Q4, 2022.  

High-level planning 
The ICG features are classified under different categories as presented below: 

A)  “ICG  core  features  with  existing  base  in  TRACES”:  essential  features  where  existing 
functionality will be reused; 

B) “ICG core features without existing base in TRACES”: essential features to be built from 
scratch; 

C) “ICG not core features”: important but not essential features; 

D) “External connections”: features that rely on external inputs; 

E)  “Out  of  scope”:  for  ICG  features  out  of  the  scope  of  the  first  ICG  system  version  (e.g. 
Artificial Intelligence); 

An estimation of availability by quarter is given in the table below. 

Table 1: High-level overview of availability targets 

The effort is currently organised in 8 releases from Q1, 2022 to Q2, 2024, with the caveat that 
this organisation is subject to continuous agile refinement and optimisation. 

The  first  release  (R1)  mainly  addresses  the  general  functional  infrastructure  (e.g.  support 
entities,  search  indexes,  reference  data,  users,  roles)  but  also  on  basic  business  relevant 

8 

 
 
 
functionality  such  as  the  first  limited  set  of  fields  and  the  associated  logic  for  the  ICG 
documents and the first draft ICG documents. 

As reflected in the table (“external connections” section), the work on CERTEX integration is 
yet  to  start  (planned  as  of  Q2,  2023)  and  will  be  a  significant  part  of  the  ICG  overall 
functionalities, allowing data exchanges with national customs systems. 

Request for Changes (RfCs) 
While the development activities are progressing and internal discussions are ongoing, several 
changes  are identified to be implemented  at the Level  2-Level  4  ICG  BPMs.  Therefore, the 
BPMs will be updated during the Q3 2022 to reflect the latest status and the BAC document 
will be updated accordingly as well, to be enhanced with new data sets (or test cases) for the 
testing phase of the system. 

External synergies 
During  the  reporting  period,  the  Commission  has  been  liaising  closely  with  international 
organisations,  such  as  the  International  Council  of  Museums  (ICOM)  for  ensuring  that  the 
system  incorporates  elements  of  risk  management,  notably  from  the  ICOM  Red  Lists21.  In 
addition,  other  tools  used  by  ICOM  to  protect  cultural  heritage  (i.e.  Object  ID22, 
Observatory23, etc.) were explored with the aim of combating illicit trafficking.  

At the same time, in light of the continuous efforts towards the digitalisation of the cultural 
goods  domain  and  the  use  of  innovative  technologies,  the  Commission  has  been  exploring 
possible  synergies  with  international  organisations  on  the  possible  use  of  Artificial 
Intelligence  (i.e.  to  describe  cultural  goods  and  identify  potentially  false  declarations  in 
importer statements and applications for import licences). 

Cooperation between DG TAXUD and DG SANTE 
An  extensive  cooperation  exists  between  TAXUD  and  SANTE,  both  Directorates-General  
being  responsible  for  a  number  of  policies  that  are  deeply  intertwined.  The  operational 
framework  of  cooperation  has  been  agreed  between  the  two  parties  and  has  been  further 
enhanced during the reporting period through continuous monitoring.  

Work with the Project Group on ‘Digitalisation of Cultural Goods’ 
The  Commission  has  created  a  Customs  Project  Group  on  the  Digitalisation  of  Cultural 
Goods24  (former  title  ‘Customs  Project  Group  on  the  import  of  cultural  goods’  –  ‘PGICG’) 
which  serves  as  a  discussion  forum  for  experts  from  Member  States  national  customs 
administrations and competent (cultural) authorities with experience in carrying out licencing 
formalities  in  heritage  matters,  in  particular  digitally.  The  Group  provided  support  in  the 
preparation of the implementing act, and is assisting the Commission services with defining 
the parameters and elaborating the criteria for the functional specifications of the ICG system. 

21 https://icom.museum/en/resources/red-lists/ 
22 https://icom.museum/en/resources/standards-guidelines/objectid/  
23 https://www.obs-traffic.museum/  
24  The  Project  Group  on  Digitalisation  of  Cultural  Goods  serves  as  a  discussion  platform,  where  experts  from 
national customs administrations and competent (cultural) authorities with experience in carrying out licencing 
formalities in heritage matters, in particular digitally, come together to provide support with the activities related 
to the development of the ICG System.  

9 

 
 
                                                           
The Project Group25 consists of delegates from 14 Member States (AT, BE, BG, GR, ES, LV, 
PT, RO, DE, NL, IT, FR, HU and DK) and to-date it has met fourteen times (five during the 
reporting period 29.6.2021 – 28.6.2022). 

During this reporting period, the Project Group mainly examined and discussed the following 
matters: 

  Registration  of  beneficiaries  for  exemption  from  documentary  requirements 

(estimation of expected numbers, timeline); 

 

Identification of Member State competent authorities within the ICG system; 

  Frequently Asked Questions (FAQ) document to provide technical assistance to  ICG 

users; 

 

ICG library with basic information on the laws of third (exporting) countries; 

  Safekeeping, the creation of refuges by Member States (voluntary scheme); 

  Aspects that are useful in progressing on the technical activities such as: reducing the 
free  text  fields  within  the  import  licence  and  importer  statement  templates  and 
generating lists of values, defining roles in TRACES according to the structure that the 
Member States are using, defining pre-registration guidelines, ensuring that the same 
evaluation criteria will be used for each Member State (for private/semi-public entities 
or  bodies)  to  confirm  whether  an  institution  complies  with  the  trustworthiness 
requirement and other key matters; 

  Developments  with  Artificial  Intelligence  for  use  in  a  future  version  of  the  ICG, 
identifying  innovative  approaches  to  tackle  the  way  in  which  cultural  goods  are 
described and controlled by EU customs at the border (the implementation of AI is not 
foreseen for the first version of the system and might come as a future development); 

  Cooperation with international organisations (e.g. ICOM for the Red Lists, notably for 
the  creation  of  a  compendium  or  library  feature  of  the  ICG  aiming  to  help  Member 
State  administrations  and  importers  at  better  identifying  export  restrictions  or 
requirements in the third countries). 

5.  RISKS FOR DELAYS 

Risk 1 – Staff allocation 
The initial  proposal  from  the Commission  did not  provide for the creation  of an  IT system. 
Thus,  resources  were  not  allocated  accordingly.  However,  in  the  course  of  the  negotiations 
and  at  the  request  of  the  co-legislators,  the  creation  of  the  ICG  system  was  included  in  the 
Regulation, which called for unforeseen at that point, additional resources. The needs for this 
six-year project in terms of IT development personnel in DG TAXUD were estimated, at the 
time of the final political trilogues in December 2018, to be two full time Administrator posts. 
However, only one full time Administrator could be allocated from mid-July 2020. 

Risk 2 – Covid-19 pandemic and Ukraine crisis 
The COVID-19 public health crisis affected to some extent the team’s capacity to deliver and 
especially  the  project  activities  and  meetings  with  the  Expert  Group  and  the  Project  Group 
with  the  Member  States.  Meetings  were  held  in  a  virtual  format,  with  shorter  agendas  and 
limited  interaction.  Moreover,  the  public  health  crisis  forced  a  rescheduling  of  priorities 

25 For more details on the Project Group’s mandate and work, please see the Commission’s first Progress Report 
COM(2020) 342 final. 

10 

 
 
                                                           
within Member States, thus limiting their capacity to provide input and feedback to the file. 
At the same time, customs are today being challenged by the geopolitical tensions due to the 
war in Ukraine, dealing with fundamental transformations in this context.  

Risk 3 – Proposal for an EU Single Window Environment for Customs 
The good functioning of the  ICG system is  linked to  the success  of  the EU Single Window 
Environment for Customs, which aims to provide a legal basis for the functioning of the EU 
CSW-CERTEX.  The  government-to-government  (G2G)  pillar  of  that  proposal  reflects  how 
customs and partner competent  authorities will exchange data digitally.  At the first  political 
trilogue on the proposal for a Regulation on the EU Single Window Environment for Customs 
that took  place  on 19 May 2022, the co-legislators  reached an agreement that improves and 
extends the scope of the Commission’s proposal, without impacts for the ICG system. Soon 
after the formal adoption and publication of the Regulation, DG TAXUD will start working 
on preparing the implementing and delegated acts governed by this Regulation. The proposed 
draft  text  of  these  acts  will  be  discussed  with  the  Member  States  at  a  new  section  of  the 
Customs  Code  Committee,  named  “Single  Window  Environment”  (CCC-SWE).    Although 
the  positive  developments  mark  an  important  step  forward,  the  adoption  by  the  European 
Parliament and Council, as well as the preparations for the draft implementing and delegated 
acts, are the next key steps that must be taken into account.  

Risk 4 - The overall customs IT development priorities 

The assessment of the main risks for the timely implementation of the Union Customs Code 
(UCC) IT systems reveals that the risks are situated mostly on the side of the Member States 
and  linked  to  resource  constraints,  the  complexity  of  the  projects  and  their  integration, 
contractual and procurement issues in addition to some external factors such as the COVID-
19  pandemic.  Some  Member  States  have  experienced  additional  problems  related  to  the 
impact of Brexit, the eCommerce project and more recently the war in Ukraine. This situation 
is  currently  being  assessed  and  the  options  of  derogations  under  the  UCC  or  updates  to  the 
UCC Work Programme are being considered. 

Mitigation actions 
The risks have been reported within DG TAXUD.  

6.  CONCLUSIONS 

The  main  actions  undertaken  during  the  period  covered  by  this  third  progress  report  to 
develop the ICG system can be summarised as follows:  

* The first version of the package of BPMs for the ICG system is finalised and reviewed by 
the Member States. Additional updates on the BPMs will be required during the development 
phase. 

*  The  BAC  document  was  finalised,  describing  the  test  scenarios  that  define  the  testing 
activities  for  the  validation  of  all  business  and  functional  requirements  and  ensuring  their 
implementation by the system. Consequently, user stories were created and aligned with the 
BAC. 

*  The  features  were  classified  under  different  categories  and  marked  accordingly  in  the 
specified planning (see Table 1: High-level overview of availability targets). 

*  The  ICG  System  development  has  started  and  the  first  basic  results  are  already  on  the 
screen,  with  the  aim  to  associate  the  stakeholders  around  Q4,  2022  and  gather  feedback. 

11 

 
 
Therefore, DG TAXUD receives regular demonstrations during the development cycle, while 
Member States will be engaged as soon as there is a test version. 

*  Close  collaboration  with  the  members  of  the  Project  Group  on  ‘Digitalisation  of  Cultural 
Goods’ has allowed to advance the technical activities.  

The Commission has so far been on schedule. Potential risks for delay in delivering the ICG 
system  within  the  set  deadline  have  been  identified  only  in  connection  with  the  overall 
customs  IT  development  priorities  and,  in  particular,  the  UCC  IT  systems.  The  COVID-19 
public health crisis has only slightly affected progress with the ICG project.  

12 

 
 
 
 
 
ANNEX I: MULTIANNUAL STRATEGIC PLANNING 

The  MASP-C  ensures  an  effective  and  coherent  management  of  IT  projects  by  setting  out  both  a 
strategic framework and milestones within the legal deadlines established in legislation. It is ultimately 
endorsed by the Member States in the Customs Policy Group (CPG) based on advice provided by the 
Electronic  Customs  Coordination  Group  (ECCG)  and  consultations  with  trade  at  the  Trade  Contact 
Group (TCG). 
The planning for the electronic system has been discussed and approved by the Member States and is 
described in detail in Fiche 1.18 of the MASP-C rev. 2019. 

Table 1 below provides an excerpt of the planning of the project on the import of cultural goods from 
MASP-C rev. 2019 Fiche 1.18. 

Table 1 - Excerpt of MASP-C rev. 2019 Fiche 1.18 

Milestones 

Estimated completion date 

1  Business Analysis and Business Modelling 

- Business Case Document 
- Level 3 (User Requirements BPM) 
- Level 4 (Functional Requirement detailed BPM) 

2  Legal Provisions 

3 

4 

- Current provisions adopted* 
- Future provisions adopted** 
Project Initiation Phase 
- Vision Document 
- GO decision 
IT Project 
- Application & Service Specifications 
- Technical System Specifications 
Construction Phase 
- Central services implementation 
- Service integration in National Systems 
- National implementation 
Transition Phase 
- Deploy and rollout 
- Conformance tests 

5  Operation 

- Commission, Member States administrations and 
Traders 
- Non-EU Countries and non-EU traders (in case 
required) 
Implementation support (training and communication) 
- Centrally developed training and communication 
- National training and communication 

6 

Q4 2020 
Q1 2022 
Q1 2022 

Q2 2019 
Q2 2021 

Q2 2021 
Q2 2021 

Q2 2023 
Q2 2023 

Q3 2024 
N/A 
N/A 

Q4 2024 
Q2 2025 

Q2 2025 

N/A 

Q4 2024 
Q4 2024 

*Current provisions refer to Regulation (EU) 2019/880 
**Future provisions refer to the implementing provisions to be adopted according to Regulation (EU) 
2019/880 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2 provides an excerpt of the EU CSW-CERTEX project, with a focus on Component 2 of the 
EU-CSW CERTEX project, interconnecting the ICG system. 

Table 2 - Excerpt of MASP-C rev. 2019 Fiche 1.13 – Component 2 “EU CSW- CERTEX” 

Milestones 

Estimated completion date 

1  Business Analysis and Business Modelling 

- Business Case Document 
- Business Case Annex 
- Level 3 (User Requirements BPM) 
- Level 4 (Functional Requirement detailed BPM) 

2  Legal Provisions 

3 

4 

- Current provisions adopted* 
- Future provisions adopted** 
Project Initiation Phase 
- Vision Document 
- Vision Document Annex 
- GO decision 
IT Project 
- Application & Service Specifications 
- Technical System Specifications 
Construction Phase 
- Central services implementation 
- Service integration in National Systems 
- National implementation 
Transition Phase 
- Deploy and rollout 
- Conformance tests 

Q1 2017 
Q2 2023 
Q1 2024 
Q1 2024 

In force 
2021 

Q3 2017 
Q3 2023 
Q3 2023 

Q2 2024 
Q2 2024 

Q3 2024 
From Q4 2024 onwards 
From Q4 2024 onwards 

Q4 2024 
From Q1 2025 onwards 

5  Operation 

- Commission, Member States administrations and 
Traders (NB: This is the Operations date for the 
Commission, MS will conformance test from Q2 2020) 
- Non-EU Countries and non-EU traders (in case 
required) 
Implementation support (training and communication) 
- Centrally developed training and communication 
- National training and communication 

6 

Q2 2025 

N/A 

N/A 
N/A 

*Current provisions refer to Regulation (EU) 2019/880 
**Future provisions refer to the implementing provisions to be adopted according to Regulation (EU) 2019/880 

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE 

15