COMMISSION STAFF WORKING DOCUMENT Final Evaluation of Regulation (EU) No 1294/2013 of the European Parliament and of the Council of 11 December 2013 establishing an action programme for customs in the European Union for the period 2014-2020 (Customs 2020) and repealing Decision No 624/2007/EC Accompanying the document Report from the Commission to the European Parliament and the Council on the final evaluation of the Customs 2020 Programme
Date: 2022-11-18
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU programme, customs cooperation, customs formalities, customs inspection, customs union, exchange of information, information system

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.11.2022  SWD(2022) 363 final  COMMISSION STAFF WORKING DOCUMENT Final Evaluation of Regulation (EU) No 1294/2013 of the European Parliament and of the Council of 11 December 2013 establishing an action programme for customs in the European Union for the period 2014-2020 (Customs 2020) and repealing Decision No 624/2007/EC              Accompanying the document Report from the Commission to the European Parliament and the Council  on the final evaluation of the Customs 2020 Programme {COM(2022) 635 final}  
 
 
Table of contents 

1. 

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

Purpose and scope of the evaluation ............................................................................... 3 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ............. 6 

2.1  Description of the intervention and its objectives ............................................... 6 

2.2 

Point(s) of comparison ......................................................................................... 8 

3.  HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 

PERIOD? ..................................................................................................................... 9 

Current state of play ........................................................................................................ 9 

Implementation of the recommendations from the mid-term evaluation ..................... 13 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ............................................. 14 

4.1.  TO  WHAT  EXTENT  WAS  THE  INTERVENTION  SUCCESSFUL  AND 

WHY? ........................................................................................................................ 14 

4.1.1.  To what extent has the programme contributed to facilitating and enhancing 
cooperation and exchange of information? ................................................................... 14 

4.1.2.  To what extent has the programme supported the preparation, coherent 
application, and effective implementation of Union law in the field of customs and 
related matters? ............................................................................................................. 22 

4.1.3.  To what extent has the Customs 2020 programme supported legitimate 
economic activities and prevented illegal ones............................................................. 30 

4.1.4.  To what extent have the Customs 2020 programme’s resources produced best 
possible results at the lowest possible cost? ................................................................. 34 

4.1.5.  To what extent is the Customs 2020 programme coherent with broader EU 
policies? 41 

4.2.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE? ........................ 45 

4.3.  IS THE INTERVENTION STILL RELEVANT? .................................................... 48 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ....................... 51 

ANNEX I:   PROCEDURAL INFORMATION ............................................................... 57 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ....................... 65 

Approach and method ................................................................................................... 65 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS 

ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) ........ 68 

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ANNEX  IV.  OVERVIEW  OF  BENEFITS  AND  COSTS  [AND,  WHERE 
RELEVANT,  TABLE  ON  SIMPLIFICATION  AND  BURDEN 
REDUCTION] ........................................................................................................... 80 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ................. 86 

ANNEX  VI. 

  ASSESSMENT  OF  THE  IMPLEMENTATION  OF  THE 

RECOMMENDATIONS OF THE MIDTERM EVALUATION ........................... 100 

ANNEX VII.  KEY FEATURES OF CUSTOMS EIS AND JOINT ACTIONS ........... 109 

ANNEX VIII.  MEMBER STATES INVESTMENTS IN EIS FOR CUSTOMS ......... 115 

ANNEX IX.  LIST OF ABBREVIATIONS ................................................................... 117 

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1.  INTRODUCTION 

The Customs Union is a foundation of the EU and an essential element in the functioning 
of the single market. The EU Customs Union territory is governed by common rules and 
procedures  laid  down  in  the  Union  Customs  Code  (UCC)1.  They  require  proper  and 
uniform  interpretation,  implementation  and  application  across  the  Member  States. 
Moreover,  customs  policy  and  the  customs  administrations  constantly  need  to  adapt  to 
modern trade realities, increasing responsibilities and modern communication tools. The 
UCC  is  a  milestone  in  modernising  EU  customs,  aiming  to  reach  a  paperless  and  fully 
automated  Customs  Union.  The  EU’s  Customs  2020  programme  is  indispensable  in 
supporting its implementation, allocating the necessary resources  for the adaptation and 
functioning  of  existing  European  Information  Systems  (EIS)  for  customs  and  for  the 
development of required new ones.  

The  Customs  2020  programme  was  set  up  by  Regulation  (EU)  No  1294/2013  of  11 
December 20132 as a multiannual action programme for customs in the EU, to facilitate 
and enhance cooperation between national customs administrations, providing them with 
the possibility to exchange information, data and expertise. The programme is a key EU 
tool,  striving  towards  a  Customs  Union  functioning  seamlessly  as  one,  instead  of  a 
patchwork  of  27  separate  administrations.  It  allows  for  the  joint  development  and 
operation of major trans-European IT systems, and for the establishment of networks that 
bring  together  national  officials  from  across  Europe.  In  accordance  with  Article  18(1) 
and  (3)  of  the  Regulation,  the  Commission  carried  out  a  final  evaluation  of  the 
programme.  

Purpose and scope of the evaluation 

The purpose of the final evaluation is to assess the programme since its start on 1 January 
2014  up  to  its  end  on  31  December  2020,  or  where  necessary  until  20213.  The 
geographical scope includes all participating countries in the programme, comprising the 
EU  Member  States4,  as  well  as  candidate  countries  (Albania,  North  Macedonia, 

1   Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  of  9  October  2013 

laying down the Union Customs Code (OJ L 269, 10.10.2013, p. 1). 

2   Regulation (EU) No 1294/2013 of the European Parliament and of the Council of 11 December 2013 
establishing  an  action  programme  for  customs  in  the  European  Union  for  the  period  2014-2020 
(Customs 2020) and repealing Decision No 624/2007/EC (OJ L 347, 20.12.2013, p. 209). 

3   Certain activities funded in the programming period 2014-2020 continued or even started in 2021. This 
was due to the delay in adopting the new  programme and releasing the budget from the Multiannual 
Financial Framework 2021-2027. Moreover, there are some activities of the programme that run with 
no interruption between each programming period. 

4   The  United  Kingdom  withdrew  from  the  EU  and  is  a  third  country  as  of  1  February  2020.  It  was 

therefore considered a participating country for most of the programme duration. 

*   This designation is without prejudice to positions on status and is in line with UNSCR 1244/1999 and 

the International Court of Justice Opinion on the Kosovo declaration of independence. 

3 

 
                                                           
 
Montenegro, Serbia and Turkey) and potential candidates (Bosnia and Herzegovina and 
Kosovo*).  

The final evaluation builds on the results of the mid-term evaluation performed in 2018 
and seeks to shed light on the: (1) achievement of the general and specific objectives and 
programme’s performance; (2) cost-effectiveness of the different activities funded, with 
special  focus  on  the  European  information  systems  (EIS)  for  customs;  (3)  continued 
relevance  of  the  programme  for  the  Customs  Union  and  customs  administrations;  (4) 
coherence  and  synergies  with  other  EU  policies  and  priorities;  and  (5)  value  added  of 
acting  at  EU  level.  Moreover,  the  evaluation  examined  (6)  the  implementation  and 
follow-up of recommendations made in the mid-term evaluation. For accountability and 
learning  purposes,  the  evaluation  also  identified  areas  for  improvement  for  the  future. 
These  complement  the  recommendations  from  the  mid-term  evaluation  and,  in  some 
cases, build on measures that are currently ongoing.  

The evaluation took into account the programme’s full range of funded and management 
activities, stakeholders and participating countries.  

In  line  with  Article  18(1)  of  Regulation  (EU)  No  1294/2013,  which  mandates  an 
independent  final  evaluation  of  the  programme,  Directorate  General  for  Taxation  and 
Customs Union (DG TAXUD) commissioned an external contractor to perform a study 
in support of the Commission evaluation (hereinafter referred to as ‘the external study’). 
The external study was carried out between November 2020 and December 2021 and is a 
key contribution to this staff working document (SWD).   

The  evaluation  followed  a  two-pronged  approach  with  an  overall  programme 
assessment, including a desk review of programme documents, in-depth interviews with 
a number of key stakeholders and a benchmarking exercise, and a contribution analysis 
through  five  thematic  case  studies5.  The  benchmarking  exercise  aimed  to  provide 
suggestions  and  guidelines  for  the  management  of  the  EIS  for  customs  by  comparison 
with  similar  IT  systems6  that  are  comparable  in  scale  and  complexity.  The  five  case 
studies  focused  on  a  set  of  themes7,  which  were  primarily  based  on  the  IT  capacity 
building activities to allow for insightful analysis of the EIS for customs in conjunction 
with other Customs 2020 activities. The selected EIS for customs were those particularly 
relevant in terms of resource allocation8.  

5   These add to the seven case studies of Annual Work Programme projects, that were carried under the 
mid-term evaluation and which provided in-depth qualitative research to support the evaluation.  

6   Schengen Information System - SIS (DG HOME), European Exchange of Criminal Records System  - 

ECRIS (DG JUST) and Trade Control and Expert System - TRACES (DG SANTE). 

7   Risk management, classification of goods, customs decision, economic operator management and the 

EU Customs Trader Portal and the EU Single Window environment for customs  

8  

ICS2, SURV3, EBTI3, CDS, EU CSW-CERTEX, AEO upgrade. 

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Annex II  presents the analytical diagram for the two-pillar approach and details behind 
the data collection tools and techniques for each pillar. An overview of the benchmarking 
exercise and the rationale  for selecting the thematic case studies is  also  covered in  that 
annex.  

The  main  challenges  identified  during  the  evaluation  and  the  measures  taken  to 
counterbalance them are summarised below:  

  Nature  and  complexity  of  the  programme  –  the  programme  supports  a  broad 
range  of  policy,  legislative,  operational  and  IT  processes  and  systems  through 
diverse  activities  and  actions.  These  in  turn  contribute  to  objectives  at  various 
levels,  but  often  in  indirect  ways,  alongside  other  factors  such  as  national 
administrations’  administrative  capacity  and  priorities,  prevailing  economic  and 
trading  conditions,  and  potential  unexpected  factors  such  as  the  COVID-19 
outbreak. Due to this complex environment, it was difficult at outcome level and 
close  to  impossible  at  impact  level  to  attribute  changes  in  outcome  to  the 
functioning  of  the  programme  in  a  precise  quantifiable  way  and  to  differentiate 
the programme and its outcomes and impacts from that of the policies it supports. 
Nevertheless, an in-depth qualitative research was conducted to identify the likely 
contribution of the programme activities across a wide range of areas.  

  Stakeholder bias – an important part of the stakeholders consulted were national 
customs officials from the participating countries, who are direct beneficiaries of 
the  programme  and  thus  potentially  more  inclined  to  positive  judgement.  To 
mitigate  this  risk,  their  views  were  triangulated  with  those  of  DG  TAXUD  and 
other  Directorate-Generals  (DGs),  EU 
level  stakeholders,  and  economic 
operators, where possible.  

  Timing – this evaluation covers the programming period 2014-2020. However, a 
significant  number  of  Customs  2020  activities  were  still  ongoing  at  the  end  of 
2021, and for many recently implemented activities, including notably some EIS, 
the impacts will not have been realised yet. 

  Data limitations - Limited quantitative data on costs and benefits of the EIS for 
customs, did not allow to carry out a cost-effectiveness assessment of the systems 
as  originally  envisaged.  As  an  alternative,  a  quantitative  cost  assessment  was 
conducted, contextualised and exemplified by non-quantifiable benefits achieved 
thanks to the IT systems funded by the programme. In addition, the limitations of 
the information provided by the Performance Measurement Framework (PMF) of 
the  Customs  programme9  affected  the  ability  to  assess  the  programme’s 
performance  at  outcome  and  impact  level.  This  evaluation  could  therefore  only 
use a few indicators from the PMF to assess the programme’s performance.  

9   These  limitations  were  raised  in  an  external  Study  on  the  Performance  Measurement  Framework  of 

DG TAXUD’s Programmes, November 2020.  

5 

 
                                                           
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1   Description of the intervention and its objectives 

Figure  1  presents  the  main  features  of  the  Customs  2020  programme  in  terms  of  its 
objectives,  supported  activities,  beneficiaries  and  overall  financial  envelope.  The 
intervention logic underpinning the evaluation is presented in Figure 2.      

Figure 1. Key features of the Customs 2020 programme 

Source: DG TAXUD 

6 

 
Figure 2. Intervention logic for Customs 2020 programme 

Source: ‘Customs 2020 Programme Progress Report 2020’  

The  programme’s  multiannual  budget  envelope  is  implemented  through  annual  work 
programmes  (AWP)  providing  annual  allocations  for  budget  disbursement  across  the 
three  types  of  supported  activities  (IT  capacity  building,  joint  actions  and  human 
competency building). The Commission directly manages the Customs 2020 programme 
with assistance of the Customs 2020 Committee10.  

2.2 Point(s) of comparison  

It  is  very  difficult  to  establish  points  of  comparison  because  the  Customs  2020 
programme  builds  upon  previous  iterations  of  the  programme  (see  Figure  1)  and  the 
Customs  programme  as  such  has  been  in  place  already  for  30  years.  The  IT  systems, 
constituting approximately  87% of the programme’s expenditure, have long become an 
integral part of the national and EU customs landscapes. In fact, the programme (and its 
iterations) has been around too long for most stakeholders to meaningfully consider the 

10   The Customs 2020 Committee is a comitology committee based on Regulation (EU) No 182/2011 of 
the  European Parliament and  of the  Council of 16 February 2011 laying down the rules and general 
principles  concerning  mechanisms  for  control  by  Member  States  of  the  Commission’s  exercise  of 
implementing powers (OJ L 55, 28.2.2011, p. 13)  

7 

 
 
                                                           
situation before it started. The programme has evolved along with changes in the customs 
landscape including the opportunities for increasing digitalisation and automation.  

Compared  to  the  previous  programme,  the  Customs  2020  Programme  represented  a 
considerable financial increase (61.5%) and was instrumental to implement the new 
customs' legislative framework (UCC) that started to apply in May 2016. The need to 
deliver the new UCC rules and particularly to adapt existing IT systems and develop new 
ones  to  achieve  a  fully  electronic  customs  environment,  lays  at  the  core  of  the  current 
programme. Moreover, the programme introduced a new type of joint action, the expert 
teams, whose results are specifically referenced where appropriate.  

In line with  the Commission’s commitment to  monitor the EU budget11 and ensure the 
accountability for value for money, DG TAXUD developed a framework for monitoring 
the outputs and results of the programme  – the Performance Monitoring Framework 
(PMF).  The  PMF  was  put  in  place  for  the  current  iteration  of  the  Customs  programme 
and its outcome has been taken into account to the extent possible in this evaluation12. It 
includes, for most of the indicators, the corresponding baselines and targets presented in 
specific references in this report. However, the information provided is limited, in terms 
of  indicators  at  outcome  and  impact  level.  For  this  reason,  and  based  on  one  of  the 
recommendations  of  the  mid-term  evaluation,  DG  TAXUD  commissioned  an  external 
study to reassess the current set of indicators and better align the monitoring results with 
decision-making needs.  The study was finalised in December 2020  and forms the basis 
for  the  programme  monitoring  and  evaluation  framework  (MEF)  for  the  next  funding 
period, which is currently under preparation.   

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

Current state of play 

The  Commission  reports  on  the  implementation  and  performance  of  the  programme 
annually,  through  the  Annual  Progress  Reports13.  The  overview  of  the  programme’s 
implementation  presented  here  is  based  mostly  on  the  2020  Annual  Progress  report, 
which provides its latest state.   

The  Customs  2020  programme  had  a  committed  budget  of  EUR  531.7  million  for  the 
period 2014-2020. This budget is significantly higher than the 272 million committed for 
the previous programming period (2007-2013). This is mainly due to the increased focus 
on  the  development  of  the  EIS  for  customs  in  the  context  of  implementation  the  new 

11   As set out in Article 17 of the Customs 2020 Regulation, the Commission is required to monitor the 

implementation of the programme and its actions. 

12   Based on Article 17(3) of the Customs 2020 Regulation. 

13   Customs: Reference documents (europa.eu)  

8 

 
                                                           
legislative  framework  set  by  UCC.  Table  1  presents  the  committed  expenses  per  year 
and by main categories of activities.  

Table 1. Committed expenses per year and by main action categories of activities  

2014 

2015 

2016 

2017 

2018 

2019 

2020 

EIS for customs 

57.232.015  

61.196.379  

59.897.436  

82.067.173  

71.396.600  

 67.822.380  

64.857.451  

Joint actions14  

Joint Actions - 
expert teams 

Human competency 
buiding 

Studies and 
communication 

 6.323.000  

5.500.000  

5.400.000  

5.815.000  

5.450.000  

6.264.000  

 5.639.100  

                 -

   -    

1.767.365  

1.350.000  

995.000  

 2.646.000  

-    

-    

1.726.971  

1.450.667  

 2.100.000  

1.800.000  

1.836.000  

1.814.000  

1.184.798  

817.233  

1.782.025  

1.087.965  

1.694.366  

812.953  

720.239  

External experts 

 200.000  

200.000  

 240.000  

230.000  

255.618  

100.000  

33.210  

TOTAL 

66.289.813  

68.708.612  

71.732.826  

89.200.138  

82.323.555  

78.286.000  

75.164.000  

Source: data extracted from ABAC 

As  shown  in  Figure  3  below  most  of  the  budget  was  spent  on  the  development  and 
operation of the EIS for customs (EUR 464.5 million or 87%), followed by the joint 
actions  (EUR  56.8  million  or  11%,  including  expert  teams,  as  well  as  studies, 
communication actions and external experts15) and human competency building (EUR 
10.4  million  or  2%).  This  is  in  line  with  Annex  III  of  the  Customs  2020  Regulation, 
which  states  a  minimum  indicative  allocation  of  funds  of  at  least  75%  to  IT  capacity 
building,  a  maximum  of  20%  for  joint  actions,  and  a  maximum  of  5%  to  human 
competency building. 

14   Other than expert teams and studies. 

15   Overall, 0.2% of the budget was spent on “External experts”, i.e., the reimbursement of costs incurred 
by  external  experts  (representatives  of  other  governmental  authorities,  economic  operators' 
organisations,  or  international  organisations)  who  are  invited  to  contribute  to  selected  activities 
organised  under  the  programme.  External  experts  are  mostly  involved  in  joint  actions,  and  therefore 
this budget line has been included under Joint actions here. 

9 

 
 
    
                   
                      
                      
                                                           
Figure 3: Programme expenditure by type of activity (2014-2020) 

Programme expenditure 2014-2020, by type of action

2%

11%

87%

European Information Systems

Joint actions Human competency building

Source: data extracted from ABAC 

IT capacity building activities 

The  Customs  2020  programme  contributed  to  financing  the  development  of  EIS  for 
customs. In particular, it financed the Union components16 of new EIS for customs or the 
upgrades  to  the  existing  ones.  A  brief  description  of  the  customs  EIS  which  are 
referenced in this SWD is provided in Annex VII. Under Customs 2020, the development 
of most EIS was linked to the implementation of the UCC, as defined in the UCC Work 
Programme17.  This  was  in  addition  to  the  development,  maintenance,  and  operation  of 
other  systems  not  governed  by  the  UCC,  such  as  the  EU  Customs  Single  Window 
Certificates  Exchange  project  (EU  CSW-CERTEX),  COPIS  system  for  anti-Counterfeit 
and anti-Piracy Information or the VAT e-Commerce.  

In particular, the UCC Work Programme, defined 17  IT projects for electronic systems 
aimed  at  the  harmonised  exchange  of  information  for  customs  procedures  and 
authorisations.  The  IT  capacity  building  activities  under  the  Customs  2020  programme 
led  to  the  release  of  nine  of  these  projects18.  The  others  are  either  national  systems  or 
their release will happen during the next iteration of the Customs programme. 

16   The EIS for customs include Union and national components. The Union components are the IT assets 
and  services  that  the  Commission  owns.  They  are  developed  by  DG  TAXUD  and  funded  by  the 
programme. In turn, Member States develop, maintain and operate national components with national 
funding.  Nonetheless,  these  need  to  comply  with  common  specifications  to  ensure  interoperability, 
which are also supported by the programme.  

17   Initially  established  in  April  2014  by  Commission  Implementing  Decision  (EU)  2014/255.  It  was 
subject  to  a  first  revision  replacing  it  by  Commission  Implementing  Decision  (EU)  2016/578  of  11 
April 2016. It has recently been replaced by Commission Implementing Decision (EU) 2019/2151 of 
13 December 2019 establishing the work programme relating to the development and deployment of 
the electronic systems provided for in the Union Customs Code. 

18   Registered Exporters IT system (REX), the UCC Customs Decisions system (CDS), the Uniform User 
Management & Digital Signature (UUM&DS), European Binding Tariff Information-3 system (EBTI-
3),  UCC  Surveillance  3  (SURV3),  the  upgrade  of  the  Authorised  Economic  Operator  (AEO)  and 
Economic Operator Registration and Identification (EORI) systems,  the UCC Information Sheets for 
Special Procedures (INF SP) and the upgrade of the Import Control System (ICS2) release 1 in 2021. 

10 

 
 
                                                           
The  Customs  2020  programme  also  financed  the  operation  of  the  common  IT 
infrastructure on which all the EIS for customs operate  – the Common Communication 
Network/Common Systems  Interface (CCN/CSI) and Single Portal  for Entry or Exit of 
Data (SPEED), including their respective evolutions (CCN2 and SPEED2)  

In  addition,  the  programme  financed  implied  major  updates  in  the  field  of  IT  after  the 
United Kingdom’s (UK) Withdrawal Agreement and Northern Ireland Protocol.   

Joint actions 

The  joint  actions  bring  together  officials  from  participating  countries.  They  include 
seminars  and  workshops,  project  groups,  working  visits,  joint  monitoring  activities, 
expert teams, capacity building and supporting actions, studies and joint communication 
actions. A detailed description of the key features of joint actions is provided in Annex 
VII. 

Overall, the number of actions, events and participants remained at a constant high level 
until 2019, as demonstrated in Figure 4. However, in 2020, the Covid-19 pandemic and 
the restrictive measures had a strong impact on the number of joint actions organised and 
the number of participants.  

It is also worth underlining that the lower number in 2014 is due to the transition period 
between  Customs  2013  and  Customs  2020  programmes.  This  transition  included  one 
month  of  complete  inactivity  followed  by  a  slow  start  for  the  new  joint  actions  under 
Customs 2020 in May 2014, which led to fewer activities being organised. 

Figure 4. Evolution of the number of operational Joint Actions19and participants 

Evolution of the number of participants

5.608

5.669

5.236

5.311

4.704

6.511

4.875

2014

2015

2016

2017

2018

2019

2020

19   Operational  Joint  Actions  include  the  ones  that  were  launched  in  previous  years  and  continued  their 
activities in the year mentioned, together with the newly launched actions. 

11 

 
 
 
                                                           
Number of operational joint actions per year 

Capacity Building

Communication

Workshops

Seminars

Monitoring

Working Visits

Project Groups

500

450

400

350

300

250

200

150

100

50

0

s
n
o
i
t
c
a

t
n
i
o
j

f
o

r
e
b
m
u
N

2014

2015

2016

2018

2019

2020

2017
Year

Source: Customs 2020 Programme Progress Reports for 2014-2020  

Human competency building activities 

Human competency building activities consist of common training actions to support the 
necessary  professional  skills  and  knowledge  relating  to  customs.  During  the  Customs 
2020 programme, they included the development of eLearning modules, interactive (face-
to-face) training courses intended for different audiences (customs officials or economic 
operators), as well as the development of the EU Customs Competency  Framework and 
Training  Curricula,  which  aims  at  harmonising  and  raising  customs  performance 
standards throughout the EU20. 

The peak in training expenditure in 2016 was mainly due to development and deployment 
of an extensive eLearning programme supporting the implementation of the UCC, which 
entered into force on 1 May 2016. In 2017, there were no commitments as the contracts 
signed  in  previous  years  were  of  a  multiannual  nature  and  the  activities  carried  out  in 
2017 were funded out of these contracts. In general, DG TAXUD produced over the life 
of  the  programme  30  new  eLearning  modules  in  English,  as  well  as  over  327 
translations  and  updates  of  existing  modules.  In  2020  specific  training  support  was 
provided in the context of the preparation for UK’s withdrawal from the EU, and all the 
eLearning modules offered by DG TAXUD were adapted and updated to consider Brexit 
preparedeness.   

Implementation of the recommendations from the mid-term evaluation 

The  Commission  broadly  accepted  the  recommendations  of  the  external  mid-term 
evaluation21  by  adopting  in  2019  together  with  national  customs  authorities  an  Action 
Plan outlining the extent to and ways in which they would be implemented.  

20   CustCompEU - EU Customs Competency Framework (europa.eu) 

21   Mid-term evaluation of the Customs 2020 programme 

12 

 
 
                                                           
 
 
 
The  mid-term  evaluation  made  thirteen  recommendations  that  were  classified  in  four 
categories:  “programming  and  design”  (five);  “implementation”  (two);  “monitoring 
and  reporting”  (three);  and  “communication”  (three).  Most  of  the  recommendations 
have  been  implemented  or  are  planning  to  be  implemented  in  the  next  iteration  of  the 
programme.  The  paragraphs  below  provide  some  examples  of  the  improvements  and 
actions taken. A detailed assessment of their follow-up is provided in Annex VI.  

In terms of programming and design, the Commission has developed a more top-down 
and strategic design for the next programme, where the planning follows a tree structure, 
with  various  policy  objectives  divided  into  well-defined  policy  projects,  split  into 
programme  actions.  Also,  for  the  next  funding  period  the  Commission  will  establish 
multiannual work programmes, which are more strategic and reflect better the nature of 
the  activities.  Technological  improvements  have  also  been  achieved  in  the  area  of 
eLearning where DG TAXUD is piloting an EU-level Learning Management System for 
supporting  the  development  and  delivery  of  EU  eLearning  materials.  DG  TAXUD  has 
also introduced a new ‘Customs & Tax EU Learning Portal’22 to facilitate the access to 
trainings for customs staff and professionals across the Union.  

Regarding  implementation  aspects,  the  synergies  between  Customs  and  Fiscalis 
programmes are being further exploited and will be extended where possible to the new 
instrument  on  customs  control  equipment23.  In  addition,  DG  TAXUD  has  made 
significant progress in optimising the procedures and resources for the implementation of 
joint  actions,  in  line  with  more  strategic  planning  outlined  above  and  simplifying 
administrative processes and tasks.  

On  monitoring  and  reporting,  the  Commission  is  finalising  the  new  monitoring  and 
evaluation  framework  for  the  next  funding  period  on  the  basis  of  an  external  study,  as 
explained  in  section  2.  In  terms  of  communication,  DG  TAXUD  has  made  efforts  in 
raising  the  awareness  of  the  programme  to  national  coordinators  and  other  officials  by 
sending  quarterly  newsletters.  The  implementation  of  several  other  recommendations 
under  this  category  is  still  work  in  progress,  including  reviewing  the  programme’s 
communication strategy  and tools, increasing senior-level  buy-in  and political  will, and 
reviewing the strategy for dealing with economic operators and citizens.  

22   European Union, Customs & Tax EU Learning Portal, available at: https://customs-

taxation.learning.europa.eu/ 

23   Regulation  (EU)  2021/1077  of  the  European  Parliament  and  of  the  Council  of  24  June  2021 
establishing, as part of the Integrated Border Management Fund, the instrument for financial support 
for customs control equipment.  

13 

 
                                                           
4.  EVALUATION FINDINGS (ANALYTICAL PART) 

4.1.  TO WHAT EXTENT WAS THE INTERVENTION SUCCESSFUL AND WHY?  

This section examines the extent to which the programme has achieved its objectives by 
looking at  its three levels of results. The first one about  exchange of information and 
cooperation relates to outputs, the second one about the preparation, implementation24 
and application of Union law concerns its outcomes, and the third one on the support 
to  legitimate  activities  and  prevention  of  illegal  ones  refers  to  the  impacts  of  the 
programme.  Furthermore,  this  section  presents  the  evaluation  findings  on  the  cost-
efficiency  of  the  programme  activities  as  well  as  their  coherence  with  broader  EU 
policies.  

4.1.1.  To what extent has the programme contributed to facilitating and enhancing 
cooperation and exchange of information? 

Customs  2020  programme  has  largely  contributed  to  facilitating  and  enhancing 
cooperation  and  information  exchange  through  its  three  types  of  activities  which  fully 
complemented  each  other.  The  contribution  was  strongest  from  IT  capacity  building 
activities and joint actions.  

IT  capacity  building  activities  were  key  to  facilitate  the  secure  and  efficient 
information  exchange  between  customs  authorities,  but  also  with  economic  operators 
and  other  governmental  authorities.  As  indicated  in  section  3,  this  has  been  achieved 
mainly by: 1) financing the functioning of the network infrastructure on which all EIS for 
customs  operate  (CCN/CSI  and  SPEED)  and  upgrading  it  (CCN2  and  SPEED2);  2) 
developing  and  upgrading  certain  systems  (in  particular  those  linked  to  the  UCC 
implementation); and 3) operating all of them.    

As depicted in Table 2, the availability25 of CCN met the target stipulated in Annex I of 
the  Customs  2020  Regulation,  and  the  number  of  exchanged  messages  and  their 
volume grew considerable throughout the funding period. 

Another important output of the Customs 2020 programme is the increased number of 
EIS  for  customs  (from  39  in  201426  to  56  at  the  end  of  2020)27.  Their  availability  is 
essential as  they play  a  vital  role in  interconnecting customs authorities  within the EU. 
Table  3  below  presents  the  availability  of  the  New  Computerised  Transit  System 

24   ‘Implementation’  as  the  process  of  moving  Union  law  from  concept  to  reality,  namely  translating  it 

into concrete processes, including the systems that allow them, to ensure its application. 

25   CCN and EIS availability means that the network or the IT system is functional, up and running and 

that it works and can be used as designed.  

26   European Commission, Commission Staff Working Document  – Customs 2020 Programme Progress 

Report 2014. 

27   European Commission, Commission Staff Working Document  – Customs 2020 Programme Progress 

Report 2020 (DRAFT). 

14 

 
                                                           
(NCTS), the Export Control System (ECS) and the Import Control System (ICS) as well 
as  the  centralised  IT  customs  applications  between  2014  and  2020,  which  has  steadily 
improved.  These  systems  allow  seamless,  automated  exchange  of  information  on 
transit/export/entry  movements  between  Member  States  and  with  third  countries  and 
other  stakeholders  of  the  supply  chain  at  international  level.  For  instance,  in  2020, 
operational  exchanges  included  around  11.2  million  transit  movements,  14.74  million 
indirect export movements and more than 50 million entry summary declarations. Figure 
5 on the evolution of the messages exchanged through the main EIS for custom is also 
illustrative  of  the  contribution  of  these  EIS  for  customs  to  facilitating  the  exchange  of 
information continuously.  

Table 2: Reliability of the common infrastructure (2014-2020) 

Indicator 

Target 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Availability of CCN 
overall (%) 

98 

99.00 

99.97 

99.98 

99.98 

99.98 

99.47 

99.97 

Number of messages 
on CCN (billions) 

Grow or 
stable 

Grow or 
stable 

Volume of CCN 
messages 
(Terabytes) 

Availability of 
SPEED2 (%) 

2.7 

4.3 

3.2 
(↗) 

4.7 
(↗) 

4.5 
(↗) 

5.54 
(↗) 

4.3 
(≈) 

5.8 
(↗) 

6.9 
(↗) 

22.89 
(↗) 

29.08 
(↗) 

32.23 
(↗) 

8.4 
(↗) 

42.21 
(↗) 

N/A 

99.85 

98.46 

99.24 

99.51 

99.68 

Source: Customs 2020 Programme Progress Reports for 2014-2020 

Table 3: Availability of the EIS for customs (2014-2020) 

Indicator 

Target 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Availability of 
NCTS, ECS, ICS (%) 

Availability of 
centralised IT 
customs applications 
(%) 

99% 

99.00 

99.00 

99.23 

99.30 

99.26 

99.41 

99.51 

97% 

99.00 

98.95 

98.37 

98.70 

99.68 

96.27 

99.82 

15 

 
 
Figure 5: Evolution of messages exchanged by application.  

EBTI

ECS

EO

ICS

NCTS

SMS

SURV

SURV3

)
s
n
o
i
l
l
i

M

(

s
e
g
a
s
s
e

M

f
o
b
N

250

200

150

100

50

0

177

117

40
18

8

2016

218

158

44

17

13

2017

223

162

48

17

9

2018

221

164

45

17

13

2019

219

163

19

17

12

2020

Source Table 3 and Figure 5: Customs 2020 Programme Progress Reports 2014-2020 

The  study  emphasised  the  important  contribution  of  certain  EIS  to  enhancing  the 
exchange  of  information.  The  Customs  Decision  System  (CDS)  for  instance  has 
allowed  systematic,  standardised  and  automated  consultation  to  other  customs 
authorities when required by the relevant procedure.  

The European Binding Tariff Information-3 system (EBTI-3), the electronic system 
for  quota  management  /  allocation  (QUOTA)  and  the  integrated  Tariff  of  the 
European Union (TARIC) are also central databases developed for the explicit purpose 
of  exchanging  information  between  customs  authorities  in  the  area  of  binding  tariff 
information,  quota  management  and  classification  of  goods,  respectively.  All 
stakeholders  interviewed  highlighted  the  importance  and  usefulness  of  these  central 
databases to ensure a uniform approach to the classification of goods within the EU, and 
were, overall, positive about the information exchanged in terms of content and quality. 
Timeliness was particularly valued.  

These systems  also supported the exchange of information with economic operators, 
Moreover, the implementation of the EU Customs Trader Portal (EUCTP) and of the 
Authorised Economic Operator (AEO), EBTI and INF trader portals specifically allowed 
automated  data  exchange  between  customs  authorities  and  economic  operators  in  a 
uniform  way  throughout  the  EU.  They  enabled  economic  operators  to  submit 
applications  and  additional  information  and  to  receive  notifications  from  the  customs 
authority.   

The  EU  CSW-CERTEX  system  has  contributed  to  facilitating  and  enhancing  the 
exchange  of  information  with  other  (non-customs)  governmental  authorities.  This 
system has  connected on a voluntary basis the national customs system of participating 

16 

 
 
 
 
 
countries  to  several  EU  non-customs  databases28,  enabling  the  automated  exchange  of 
information on a number of non-customs regulatory formalities29 required for the import 
and export of goods. 

Some room for improvement in facilitating the exchange of information between customs 
administrations has been identified in the context of the interim evaluation of the UCC, 
where  eight  Member  States  responding  to  a  survey  indicated  that  the  central  CDS  had 
poor  communication  functionalities,  pushing  Members  States  to  resort  to  e-mails  when 
they needed to consult others. 

Beyond  the  information  exchanges  facilitated  through  the  EIS,  cooperation  between 
customs  administrations  in  the  context  of  customs  EIS  took  two  forms:  1)  when 
developing the systems and 2) when using them. Evaluation findings showed that the 
programme has substantially enhanced cooperation for the development of customs EIS. 
Evidence  on  the  extent  to  which  the  use  of  these  systems  has  improved  operational 
cooperation  between  customs  authorities,  beyond  information  exchanges,  is  however 
scarcer.  Indeed,  the  development  of  the  EIS  for  customs  relied  on  the  cooperation  of 
Member  States  between  each  other  and  with  the  Commission,  including  through  joint 
actions.  Evidence  of  this  cooperation  includes  the  CDS,  which  represents  the  largest 
joint  deployment  in  DG TAXUD’s  IT  history30.  It  enables  economic  operators  to 
submit applications for 22 different types of authorisations electronically through a single 
electronic access point at EU level, which is linked to the central CDS. Importers in all 
Member States now use the same portal, and the information is automatically exchanged 
between  all  relevant  customs  authorities31.  Another  example  is  the  Uniform  User 
Management  and  Digital  Signatures  (UUM&DS)  collaboration  project  group,  which 
mapped  the  sharing  of  data,  including  identification,  authentication,  and  authorisation 
data, as well as digital signature, so that central services could grant economic operators 
user  access  to  authorised  features.  The  UUM&DS  system  itself  is  the  product  of  this 
cooperation.  

28    i.e., TRAde Control and Expert System (TRACES) and ODS Licensing System. 

29   Common  Health  Entry  Documents,  FLEGT  licences  for  the  import  of  timber  and  timber  products, 

certificate of inspection for organic products, etc.  

30   As  of  2  October  2017,  economic  operators  submit  all  new  applications  for  customs  decisions  or 
authorisations electronically through a single electronic access point at EU level, which is linked to the 
central  CDS.  Importers  in  all  Member  States  use  the  same  portal,  and  the  information  is  exchanged 
between all relevant customs authorities. CDS manages 22 different types of authorisations. It enables 
European  economic  operators  to  benefit  from  authorisations  having  been  granted  with  EU  wide 
validity  and  being  managed  in  a  harmonised  way.  The  system  allows  economic  operators  to  file 
electronically and in one place applications for these 22 customs authorisations. This development will 
considerably facilitate the flow of more than EUR 3 trillion worth of goods in and out of the EU each 
year. For more information, see section 6.2. in Commission Staff Working Document, Customs 2020 
Programme – Progress Report 2017 (SWD (2019) 153 final, 1.4.2019). 

31   For  more  information,  see  section  6.2.  in  Commission  Staff  Working  Document,  Customs  2020 

Programme – Progress Report 2017 (SWD (2019) 153 final, 1.4.2019). 

17 

 
                                                           
The Customs 2020 programme,  in  general, has created a  collaborative  IT environment, 
where  customs  authorities  see  themselves  as  working  together  towards  the  same  end. 
There  is  little  quantitative  evidence  to  show  that  the  use  of  customs  EIS  and  the 
information exchanged through them have resulted in enhanced operational cooperation. 
Nevertheless, the Customs Risk Management System (CRMS) constitutes an example of 
the  cooperation  between  customs  authorities  that  stems  from  the  use  of  the  systems. 
Customs officials interviewed for the Risk Management case study judged the CRMS as 
vital  for  exchanging  risk-related  information.  CRMS  provides  a  fast  and  easy-to-use 
mechanism  to  store  and  exchange  risk-related  information  directly  between  operational 
officials  and  risk analysis centres in  the Member States.  It facilitates EU-wide customs 
intervention for the highest risks at the EU’s external borders and within its borders.  

Joint  actions  provided  a  platform  for  exchanging  knowledge  and  good  practices 
between customs authorities and their officials and to promote their cooperation.  

An  example  of  positive  impact  of  joint  actions  in  enhancing  the  exchange  of 
information and good practices is the AEO network, gathering relevant experts from all 
Member  States.  It  was  highly  valued  by  interviewees,  both  in  the  context  of  this 
evaluation  and in  the  UCC interim evaluation,  as  a forum  to  exchange expertise and  to 
find  practical  solutions  to  problems  arising  in  the  implementation  of  the  AEO 
programme. This work has crystallised in practical guidelines.  

Adding  to  this,  working  visits  were  also  a  vehicle  to  facilitate  the  exchange  of 
information and expertise in a tailor-made way. For instance, Czech officials visited 
their  counterparts  in  Germany  to  exchange  experiences  in  the  field  of  authorisations 
(CDS)32  and  so  did  Portuguese  officials  who  visited  Spain  and  Italy  on  the  Single 
Window area33.  

Overall,  the  evidence  collected  through  the  interviews  showed  that  the  contacts 
established  through  joint  actions  led  to  durable  professional  relationships  and 
fostered information exchange beyond the specific activities. This was confirmed by 
the  data  collected  through  the  event  assessment  forms  (EAF),  which  evidence  the  high 
degree of networking generated through joint actions. Between 95.5% and 96.5% (2014-
2019)  of  participants  filling  in  the  EAF  indicated  that  joint  actions  provided  a  good 
opportunity to expand their network and contacts with officials abroad. In addition, most 
participants  (between  70%  and  77.7%  for  2014-2019)  reported  that  they  had  been  in 
contact  for  work  purposes  with  the  officials  they  had  met  during  a  joint  action  since  it 
ended34.  These  figures  dropped  in  the  context  of  the  Covid-19  pandemic  to  81.1%  and 
54.9%  respectively  in  2020.  This  could  be  due  to  traveling  and  meeting  restrictions 
and/or  to  an  unclear  understanding/adjustment  period  to  alternative  ways  to  “be  in 

32   CWV/617 CZ. 

33   CWV/433. 

34   The programme poll used to cover this information. The data source changed from the programme poll 

to the event assessment form to improve data availability for years without poll. 

18 

 
                                                           
contact”, which increasingly include collaborative tools beyond the traditional contacts. 
Indeed, interviewed customs officials noted that the increased virtuality of exchanges and 
meetings  brought  by  the  pandemic  had  affected  networking  opportunities  which  were 
easier during face-to-face exchanges.  

In  terms  of  enhancing  cooperation,  all  joint  actions  brought  together  national 
customs  officials  from  participating  countries  for  cooperation  purposes.  As 
presented  in  section  3,  the  customs  authorities’  participation  rate  has  increased 
throughout the life of the programme. Monitoring data from the PMF also show that 
all countries that could participate did so35. Moreover, the countries with the highest 
level  of  participation  in  joint  actions  were  usually  those  with  the  largest  customs 
administrations,  like  Germany  and  France36.  Countries  with  the  lowest  level  of 
participation  were  usually  those  with  significantly  smaller  customs  administrations.  In 
2017,  for  example,  Estonia37  had  the  lowest  level  of  participation  with  15 officials 
involved in joint actions. For the other years of the programme, it was usually a candidate 
or  potential  candidate  country  that  had  fewer  officials  involved,  although  overall  they 
have  increasingly  participated  in  joint  actions38.  Albania39  then  had  the  lowest  level  of 
participation  in  joint  actions  in  2018  and  2019.40  Nevertheless,  some  smaller  Member 
States  had  a  notable  participation  in  joint  actions  relative  to  the  size  of  their 
administrations. For example, Estonia, the participating country with the lowest absolute 
number  of  participants  in  2017,  had  2.57%  of  its  customs  staff  participating  that  year. 
This  was  less  than  1%  in  the  case  of  Germany  in  2018,  when  they  had  the  highest 
absolute  number  of  participants.  So,  in  relative  terms,  Estonia  showed  higher  levels  of 
participation of its customs staff in joint actions than countries with the largest customs 
administrations.  Cyprus,  Luxembourg,  and  Slovenia  provide  similar  examples  of  high 

35   No data available for Kosovo (This designation is without prejudice to positions on status and is in line 
with UNSCR 1244/1999 and the International Court of Justice Opinion on the Kosovo declaration of 
independence.), as they joined the programme in 2020. 

36   France (approximately 16 665 customs staff in 2014), Hungary (approximately 3 837 customs staff in 
2015),  the  Netherlands  (approximately  4 290  customs  staff  in  2016  and  2017),  and  Germany 
(approximately 35 661 customs staff in 2018 and 2019). World Customs Organisation, Annual reports 
2014-2015, 2015-2016, 2016-2017, 2018-2019. 

37   Estonia  had  approximately  583  customs  staff  in  2017.  World  Customs  Organisation,  Annual  report 

2017-2018. 

38   Albania,  North  Macedonia,  Montenegro,  Serbia,  and  Turkey  joined  the  programme  in  2014,  Bosnia 
and Herzegovina in 2015 and Kosovo in 2020. Turkey participated in joint actions from 2014 onwards, 
with  a  high  level  of  participation  throughout.  Serbia  started  participating  in  2016,  and  the  others  in 
2017. 

39   Albania  had approximately 1 102 customs  staff in 2018-2019. World Customs Organisation,  Annual 

report 2018-2019. 

40   European Commission, Customs 2020 Programme Progress Reports for 2014-2019. 

19 

 
                                                           
participation relative to the size of their administration. In 2018 for example, there were 
89 participants from Luxembourg, namely 20% of its staff41. 

As  shown  in  Figure  6,  the  reported  level  of  achievement  of  joint  actions  in  enhancing 
cooperation  between  customs  authorities42  and  between  their  officials  was  above  the 
target  from  2015  onwards.  The  average  indicator  is  however  not  representative  of  all 
joint  actions  as  the  form  was  not  filled  in  systematically  by  the  respective  action 
managers.   

Figure 6: Level of achievement of joint actions aimed at enhancing cooperation 

Average score 0 (not achieved) to 4 (fully achieved)

4

3

2

1

0

2014

2015

2016

2017

2018

2019

2020

Target

AFF

AFF working visits

Source: Based on Customs 2020 Programme Progress Reports for 2014-2020. 

Amongst joint actions, expert teams, the new collaboration tool between Member States 
aiming  at  pooling  resources  to  perform  tasks  in  specific  domains  or  to  carry  out 
operational activities, provide the best example in terms of enhancing cooperation: 

  Customs  Laboratories  Expert  Team  (CLET)  was  signalled  by  consulted 
stakeholders as the “best example of successful cooperation” where one Member 
State  helped  the  customs  authority  of  another  that  did  not  have  the  means  to 
conduct the analysis of a product. This expert team, launched at the beginning of 
2017,  counts  the  participation  of  11  Member  States.  It  pools  expertise  and 
equipment in a network (meta-laboratory) to analyse samples and share analytical 
results;   

  Customs Eastern and South-Eastern Land Border Expert Team (CELBET)43 
was  also  identified  as  a  platform  of  expanding  cooperation.  This  expert  team 

41   Luxembourg  had  approximately  439  customs  staff  in  2018.  World  Customs  Organisation,  Annual 

report 2018-2019. 

42   The  indicator  is based on the monitoring data  from the  Action follow-up form (AFF)  and represents 
the views of the action manager, who is the person in the Commission or in the national administration 
(grant beneficiaries) acting as the manager/leader of the collaborative activity (joint action). 

43   See  CELBET.  Customs  Eastern  and  South-Eastern  Land  Border  Expert  Team  (CELBET)  is  an 
initiative  of  11  EU  Member  States:  Finland,  Estonia,  Latvia,  Lithuania,  Poland,  Hungary,  Slovakia, 
Croatia,  Romania,  Bulgaria  and  Greece.  CELBET  works  under  the  Customs  2020  programme.  The 
aim is to strengthen and improve the operational co-operation using a new  way of working based on 
real operational co-ordination, deeper sharing of information and pooling of human resources and thus 
contributing to the implementation of common customs legislation and policy. 

20 

 
 
                                                           
pools  expertise and makes  proposals  for further  improvement  of the operational 
management in EU Eastern and South-Eastern land border;  

  The  Expert  team  on  new  approaches  to  develop  and  operate  Customs  IT 
systems  (ETCIT)  constitutes  an  additional  example  of 
the  programme 
contribution  to  cooperation  enhancement.  This  expert  team  created  in  2018 
currently  involves  around  40  experts  from  16  Member  States  and  explores  new 
approaches to develop and maintain decentralised customs IT systems, which fall 
under the responsibility of the Member States.  

The  main  issue  identified  in  relation  to  expert  teams  was  the  difficulty  to  find  a 
Member State to take the lead. Taking leadership was considered as an extra-burden as 
it  meant  complying  with  procedures  that  are  heavier  than  for  other  joint  actions. 
Moreover, it entailed a legal responsibility, as the lead is also the grant coordinator. 

Joint  actions  have  also  supported  the  exchange  of  information  and  cooperation  with 
other  governmental  authorities.  This  was  the  case  of  Prohibitions  and  Restrictions 
Customs  Controls  Strategy  (PARCS)  expert  group  that  gathers  customs  and  other 
competent authorities responsible for regulatory formalities applicable to the import and 
export  of  goods,  the  project  group  on  best  working  practices  related  to  non- 
compliance  with  import  requirements  of  F-gas  legislation44,  or  several  joint  actions 
supporting  the  development  of  the  EU  Single  Window  Environment  for  Customs 
(SWE-C) initiative.  

Finally, there is  evidence of  customs authorities cooperating with third  countries to 
tackle common challenges through joint actions. Data from the Activity Reporting Tool 
(ART)  indicates  that  46  out  of  945  joint  actions  (5%)  involved  third  countries45. 
Consultations with  customs  officials  corroborated this and referred to  the project  group 
on  EU/Hong  Kong  Cooperation  on  intellectual  property  rights  customs  enforcement  as 
example. 

The  human  competency  building  activities  did  not  aim  at  enhancing  exchange  of 
information  and  cooperation  between  authorities.  By  nature,  they  target  individuals 
who benefit personally through increasing their understanding, knowledge and capacity, 
and in turn this is expected to improve competences in administrations. This is especially 
the case for eLearning modules which do not entail at all discussion among participants. 
Nevertheless, several training activities funded by the programme have enabled a better 
use of the EIS for customs and in this way indirectly contributed to these objectives.     

44   Regulation  (EU)  No  517/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014  on 
fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006 (OJ L 150, 20.5.2014). 
45   Figure based on search for the  words ‘third’ and ‘3rd’ in the  ART extract of the Customs 2020 joint 
actions  and  their  objectives,  then  only  keeping  those  with  a  third  country  mentioned  in  the  title, 
excluding (potential) candidate countries, and including intergovernmental processes such as the Asia-
Europe Meeting (ASEM). There is indeed no clear distinctions between (potential) candidate countries 
(“participating” countries), third countries and third parties in the ART. 

21 

 
                                                           
4.1.2.  To  what  extent  has  the  programme  supported  the  preparation,  coherent 
application, and effective implementation of Union law in the field of customs and 
related matters? 

As  presented  in  the  intervention  logic,  the  programme  aimed  to  address  shortcomings 
related  to  the  uniform  implementation  of  the  EU  law  by  customs  authorities,  including 
difficulties  in  uniform  implementation  of  interconnected  IT  systems  and  incoherent 
application of EU policies related to safety and security. More generally, it also pursued 
to  support  a  modern  customs  that  responds  and  adapts  to  changing  policy  context  and 
environment. In this vein, the evaluation analysed the contribution of the programme to 
the preparation, effective implementation and coherent application of EU law in the field 
of customs and related matters.  

The  three  types  of  activities  contributed  to  and  complemented  each  other  in  the 
preparation,  implementation  and  application  of  customs  legislation  and  related  matters. 
While joint actions particularly supported the preparation of Union law, the IT capacity 
building activities were instrumental  to  the implementation of the UCC and the human 
competency building activities favoured its coherent application, as explained below.  

Joint actions played a crucial role in supporting the preparation of Union law in the 
field  of  customs  and  related  matters.  They  led  in  some  cases  to  tangible  results,  in  the 
form  of  specific  proposals.  In  others,  the  joint  actions  contributed  to  the  discussion  of 
legislative issues, and the identification of changes and adaptations needed.   

The case studies and the interviews provided the following examples: 

The Financial risk management project group (CPG/076) provided an important input for 
the drafting of the Financial Risk Criteria (FRC) Implementing Decision46, adopted by 
the Commission in May 2018.  

The  preparation  of  the  Proposal  for  a  Regulation  establishing  the  EU  SWE-C47  was 
supported  through  different  joint  actions48,  which  gathered  the  input  from  Members 
States  and  economic  operators  and  served  as  target  consultation  activities  for  the 
initiative. In this particular case, the programme also funded an IT solution, the already 
mentioned EU CSW-CERTEX project that contributed to the legislative design of the EU 
SWE-C. The combination of the outputs of the related IT capacity building activities and 
joint actions ensured that the legislative proposal was based on solid grounds.  

46   Commission  implementing  decision  laying  down  measures  for  the  uniform  application  of  customs 
controls  by  establishing  common  financial  risk  criteria  and  standards,  available  only  on  a  need-to-
know basis to the persons duly authorised. 

47   COM(2020) 673 final. 

48   CPG/130 to study a possible framework to develop the EU Single Window environment for customs 
(EU-SW) including the legal context and High-level seminar on EU SW environment for customs and 
EU SW integrated environment (CSM/022). 

22 

 
                                                           
 
The  AEO  Network  in  its  turn  fed  into  the  preparation  of  Union  law  by  helping  the 
Commission  to  align  specific  legal  provisions  of  the  AEO  concept  with  the  civil 
aviation  trusted  trader  programme  for  regulated  agents  or  known  consignor. 
Furthermore, the AEO Network also actively supported the negotiation processes for the 
Mutual Recognition Agreement (MRA)49  

Project  groups  in  general  also  supported  the  preparatory  work  of  comitology 
committees, which assist the Commission in exercising implemented powers granted in 
EU  law.  For  example,  the  reports  issued  by  the  Classification  of  products  in  the 
Harmonised  System  and  Combined  Nomenclature  (HS/CN)  project  groups50  supported 
the work of the Customs Code Committee (CCC). Other project groups, worked directly 
with the CCC and Customs Expert group51 (CEG) through joint meetings52 supporting the 
process on e-customs legislation.  

More generally, certain joint actions aimed at gathering participants’ experiences on the 
implementation and application of the UCC fed into some of revisions of the UCC legal 
package.  This  was  for  instance  the  case  of  the  project  group  on  UCC  delegated  and 
implementing  acts  (UCC  DA/UCC  IA)  Data  Annexes  Revision  for  Harmonisation  of 
Customs Data Requirements (CPG/176)53 whose work contributed to the amendments of 
the  UCC  delegated  and  implementing  acts  adopted  in  early  2021.  Finally,  candidate 
countries consulted considered the joint actions as crucial for closing negotiation chapters 
in their accession process. 

The IT capacity building activities mainly supported the effective implementation of 
Union  law  and  in  particular  the  UCC,  enabling  the  development  and  operation  of 
multiple  IT  systems,  without  which  many  of  the  UCC  rules  would  not  have  become  a 
reality. The programme thus helped to modernise, computerise, and harmonise  customs 
procedures, as per the objectives of the UCC. As reflected in Table 4, most of the budget 
of the IT capacity building activities was indeed dedicated to UCC projects.  

49   Through project groups like Mutual Recognition of AEO – Negotiations with Canada (CPG/048) and 
Mutual Recognition of AEO – Negotiations with Hong Kong (CPG/108). 

50   Chemical chapters (CPG/001), Food chapters (CPG/021), Other classification issues (CPG/068), and 

Mechanical/Miscellaneous (CPG/069). 

51  The Customs Expert Group advises the Commission when drafting customs legislation and policies.  

52   This  was  the  case  for  instance  during  the  96th  meeting  of  the  CCC  –  General  Customs  Legislation 
section joint with the 57th ECCG and the 18th CEG – Data Integration and Harmonisation section and the 
Trade Contact Group (TCG) delegates. 

53   The main objective of the project group was to review the customs data annexes of the UCC DA and 
IA to prepare for and reach a formal agreement at the level of the CCC and CEG, based on the findings 
and proposals from ICS2, AES and NCTS-P5 projects.  

23 

 
                                                           
Although none of the stakeholders consulted questioned the importance of the Customs 
2020  programme  in  implementing  the  UCC,  there  were  delays  in  the  stipulated 
deployment timeframes, which led to the revision of the Code54.  

Table 4: UCC projects in the Customs 2020 budget dedicated to the development of Union 
components of the EIS 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Total 

3 846 623  8 631 000 

5 691 000 

6 676 537  14 429 997  9 547 000 

3 324 350  52 146 507 

5 646 623  10 431 000  7 941 000 

8 526 537  17 261 347  13 347 000  5 904 350 

69 057 857 

UCC 
projects 

Total 
customs 
projects 

Proportion 

68% 

83% 

72% 

78% 

84% 

72% 

56% 

76% 

Based on 2014-2020 e-customs annual progress reports 

A  2018  audit  from  the  European  Court  of  Auditors  (ECA)55  looked  at  whether  the 
Customs 2020 programme was likely to support the delivery of the IT systems necessary 
for  implementing  the  UCC  on  time.  According  to  the  audit,  the  delays  were  due  to 
several factors, including changing project scope, insufficient resources allocated by the 
EU and the Member States, and a lengthy  decision-making process  stemming from the 
multi-layered  governance  structure.  The  audit  also  noted  that  the  Commission  did  not 
report  appropriately  on  delays,  and  that  the  Customs 2020  programme  objectives  and 
reporting  arrangements  were  not  suitable  for  monitoring  the  implementation  of  the  IT 
systems  properly.  However,  it  should  be  noted  that  the  original  planning  for  the 
deployment  of  the  EIS  for  customs  were  extremely  tight  both  in  terms  of  time  and 
budget. 

The  Customs  2020  programme  therefore  did  support  the  implementation  of  the 
UCC,  but  not  within  the  timeframes  that  were  originally  planned.  The  UCC  was 
amended in 2019 to postpone the deadline for the deployment of three national systems 
to  2022  and  of  six  trans-European  systems56  to  2025.  This  implies  that  the 
implementation  of  the  UCC  is  not  yet  completed  and  the  new  iteration  of  the  Customs 
programme  will  have  to  cover  the  development  of  the  postponed  EIS  after  2020.  In 

54   Regulation  (EU)  No  2019/632  of  the  European  Parliament  and  of  the  Council  of  17  April 
2019amending  Regulation  (EU)  No  952/2013  to  prolong  the  transitional  use  of  means  other  than  the 
electronic  data-processing  techniques  provided  for  in  the  Union  Customs  Code  (OJ  L  111,  25.4.2019,  p. 
54). 

55   European Court of Auditors, Special Report No 26 – A series of delays in Customs IT systems: what 
went wrong? (2018). 

56   The  system  dealing  with  entry  summary  declarations,  the  system  dealing  with  external  and  internal 
transit,  the  system  dealing  with  goods  taken  out  of  the  customs  territory,  the  system  concerning 
guarantees for potential or existing debts, the customs status of goods and the centralised clearance. 

24 

 
                                                           
 
 
addition,  following  the  amendment  of  the  UCC,  the  Commission  has  to  inform 
annually  the  European  Parliament  and  the  Council  on  the  progress  in  the  IT 
implementation of the UCC. The 2020 progress report57 identified the risks associated 
with the developments of the UCC EIS and outlined the mitigating actions envisaged to 
address them.  

In addition to the UCC, some of the systems funded by the programme have supported 
(or will support) the implementation of other regulations, mainly related to non-customs 
formalities required for the import or export of goods. This is the case of the EU SWE-
C, including the EU CSW-CERTEX system, which, as explained before, supports the 
customs enforcement of regulatory formalities58 concerning animals and plants’ health, 
the import of timber and organic products. In addition, the Customs 2020 programme has 
funded the initial work to put in place an IT system to implement the new Regulation 
on the import of cultural goods.59   

Complementing  the  IT  capacity  building  activities,  the  joint  actions  that  were  most 
supportive of the effective implementation of Union law were those focused on the 
development  of  the  customs  EIS.  Interviewed  customs  authorities  stressed  the 
usefulness of project groups, as they served to discuss the technical aspects of the UCC 
and IT projects specifically. The case studies provided specific examples:  

  Member States considered that the project group for the Shared Trader Interface 
(STI) was crucial to prepare the effective phased deployment of ICS2, which they 
expect  to  play  an  important  role  in  ensuring  the  effective  implementation  of 
Union law (entry formalities) across the 27 Member States; 

  The  Project  Group  on  the  Import  of  Cultural  Goods  (CPG  185)  supported  the 
implementation  of  Regulation  (EU)  2019/880  on  the  introduction  and  import  of 
cultural  goods,  enabling  discussions  on  business  process  models  to  develop  the 
necessary IT solutions;   

  The High-Level Project Group (HLPG) on the implementation of the UCC and e-
Customs as crucial in supporting coordination of all the different activities linked 

57   Report from the Commission to the European Parliament and the Council pursuant to Article 278a of 
the Union Customs Code, on progress in developing the electronic systems provided for under the Code 
(COM/2020/806 final, 14.12.2020). 

58  These include: 1) Regulation (EU) 2017/625 on official controls and other official activities performed 
to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant 
protection products 2) Council Regulation (EC) No 2173/2005 on the establishment of a FLEGT licensing 
scheme for imports of timber into the European Community 3) Council Regulation (EC) No 834/2007 on 
organic production and labelling of organic products. 

59   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 (OJ L 151, 7.6.2019, P. 1). 

25 

 
                                                           
to the UCC and the e-Customs Decision60. It allowed for strategic oversight of the 
effects  of  the  implementation  of  the  UCC  on  the  governance  of  the  Customs 
Union; 

  Project  groups  on  Mutual  Recognition  of  AEO  –  Implementation  of  the  MRA 
with  China  (CPG/104),  Implementation  of  the  MRA  with  US  (CPG/125),  and 
Implementation  of  the  MRA  with  Japan  (CPG/141)  –  also  supported  the 
implementation of the agreements with these countries;  

  The  workshops  in  EU  Member  States  and  regional  seminars  in  the  Western 
Balkans on the AEO programme also supported the implementation of the latter, 
for example in Montenegro since 2019. 

indirectly  the  effective 
Human  capacity  building  activities  also  supported 
implementation  of  Union 
law  by  reinforcing  customs  officials’  skills  and 
competences  on  how  to  use  the  new  EIS  for  customs,  therefore  improving  their  use 
and  increasing  the  benefits.  Table  5  provides  an  overview  of  the  number  of  IT 
trainings organised as well as the feedback from participating customs officials, which 
was generally positive, both in terms of usefulness and expectations. 

Table 5: PMF indicators related to IT trainings (2014-2020) 

Target  2014  2015  2016  2017  2018 

2019 

2020 

Number of IT training 
sessions organised for given 
systems/ components 

Number of customs officials 
trained in IT trainings 

% of officials who found that 
the IT training  
met their expectations 'fully' 
or 'to large extent'61 

% of officials who found the 
IT training were 'very useful'  
or 'useful' 

Grow 
or 
stable 

Grow 
or 
stable 

Grow 
or 
stable 

Grow 
or 
stable 

22 

124 

95 

99 

45 

↗ 

58 

↗ 

40 

↘ 

39 

≈ 

46 

↗ 

6 

↘ 

293 

374 

472 

503 

722 

273 

↗ 

92.0 

87.0 

89.0 

92.1 

89.3 

↘ 

≈ 

↘ 

89.1 

98.0 

97.0 

97.0 

100 

98.3 

97.8 

≈ 

Source: Customs 2020 Programme Progress Reports for 2014-2020 

Customs  2020’s  activities  were  complementary  in  supporting  the  coherent 
application of Union law.  

60   European  Commission,  Register  of  Commission  Expert  Groups  and  Other  Similar  Entities  >  C2020 
CPG/082  –  High  Level  Project  Group  (HLPG)  on  the  implementation  of  the  Union  Customs  Code 
(UCC) and e-Customs (E03265). 

61   DG TAXUD launched a new format for the satisfaction survey towards the end of 2014. 

26 

 
 
                                                           
 
The  evaluation  identified  several  examples  of  the  important  role  that  the  EIS  for 
customs  played  in  supporting  Member  States’  coherent  application  of  Union  law.  For 
instance,  the  TARIC  central  database,  including  all  measures  related  to  EU  customs 
tariff,  commercial  and  agricultural  legislation,  automatically  updates  the  national 
systems, reducing human error, and strengthening the coherent and correct application of 
union law in the field of classification of goods. The CDS enables that all Member States 
customs authorities responsible for granting authorisations handle them in the same way, 
increasing consistency in the interpretation of the UCC. In addition, the CRMS has been 
recognised  as  important  in  ensuring  consistency  in  the  area  of  risk  management. 
Furthermore, the EU CSW-CERTEX system, which standardises processes for customs 
authorities to verify compliance with non-customs formalities is another example where 
the  EIS  for  customs  have  enabled  greater  coherence  in  the  enforcement  of  certain 
prohibitions and restrictions at the border.  

The programme’s joint actions were an important tool to provide practical guidance for 
the correct and harmonised interpretation of legal provisions. The guidance documents 
resulting from some of these actions, such  as the guidelines produced  by the  Project 
Group on Customs Debt and Guarantees under UCC (CPG/159), were indeed helpful 
in  ensuring  a  coherent  application  of  the  UCC  rules  and  would  not  have  been  possible 
without the collective knowledge of participating experts. The AEO Network is another 
example where outputs,  like the EU AEO Guidelines and various guidance material on 
different  aspects  of  the  AEO  programme,  proved  instrumental  to  support  the  coherent 
application  of  Union  law.  Expert  teams  and  working  visits  were  also  considered 
important  in  supporting  a  more  coherent  application  of  Union  law.  For  instance,  the 
expert team on binding tariff information decisions (BTI) resulted in clear definitions 
that can be applied in the same way by all Member States, and CELBET expert team led 
to  a  closer  harmonisation  of  customs  procedures  at  Eastern  and  South-Eastern  land 
border crossings. Officials from Czechia, for example, highlighted working visits under 
this  programme  as  a  vehicle  to  gain  a  clearer  understanding  of  how  another  Member 
State  applies  the  same  rules,  which  benefits  the  coherent  application  of  Union  law 
promoting greater consistency through the introduction of good practices learned. 

Human  competency  building  activities  are  key  to  promote  uniform  application  of 
Union  law.  Under  the  Customs  2020  programme,  the  eLearning  modules  were 
specifically aimed at promoting a common interpretation and coherent application of the 
new customs regulatory framework (UCC) throughout the EU.  

Looking  at  the  data  from  the  PMF  provided  in  Table  6,  2016  marked  a  change  in  the 
programme in terms of training, increasing by more than seven times the number of 
customs  officials  trained.  This  corresponded  to  the  entry  into  force  of  the  UCC  on 
1 May  2016,  and  to  the  introduction  of  related  training  material.  The  number  of 
eLearning  modules  produced  doubled  those  of  2015  (from  15  in  2015  to  30  in  2016). 
Generally,  customs  officials  appreciated  the  Customs  2020  programme’s  human 
competency building activities, especially in countries where there is no dedicated place 
to learn about Union law in the field of customs and related matters.  

27 

 
Table 6: PMF indicators related to eLearning modules (2014-2020) 

Target 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Number of EU e-learning 
modules produced62 

Grow 
or 
stable 

9 

0 

↘ 

3563 

12964 

3265 

4866 

10467 

↗ 

↗ 

↘ 

↗ 

↗ 

Number of customs 
officials trained using EU 
common training 
material 

Grow 

4 776 

Number of EU e-learning 
modules used by 
participating countries68 

Grow 

174 

Average training quality 
score by customs 
officials (on a scale of 
100) 

Grow 

73.369 

3 092 

23 685 

34 214 

17 547 

40 400 

18 109 

↘ 

↗ 

↗ 

↘ 

↗ 

↘ 

183 

305 

271 

279 

377 

321 

↗ 

↗ 

↘ 

↗ 

↗ 

↘ 

70.3 

74.3 

73.1 

72.9 

75.0 

78.6 

↘ 

↗ 

↘ 

↘ 

↗ 

↗ 

Source: External study on the Customs 2020 final evaluation based on Customs 2020 Programme Progress 
Reports for 2014-2020.  

Despite  of  the  effective  support  of  the  programme  to  the  coherent  application  of  the 
customs  law  presented  above,  there  is  evidence  of  discrepancies  in  the  application  of 
Union  law  in  areas  that  were  the  focus  of  some  Customs  2020  activities.  This  is 
particularly the case of customs controls, as recently pointed out by ECA in the Special 

62   This indicator counts the new modules as English (master version) and further localised versions in EU 
languages  as  requested  by  participating  countries,  as  the  resources  needed  to  develop  each  localised 
version request approximately 60% of the resources spent for the original English version. 

63   15 UCC modules, and 20 localised versions, adding up to 35. 

64   The  Customs  2020  Programme  –  Progress  Report  2017  refers  to  two  newly  produced  e-learning 

modules and 127 national language versions of existing modules.  

65   The  Customs  2020  Programme  –  Progress  Report  2018  states  that:  “The  number  32  relates  to  two 

newly produced modules and respectively 9 and 21 languages versions of each module.” 

66   The Customs 2020 Programme Progress Report 2019 states that: “The number 48 relates to two newly 

produced modules and the update of other courses and their localisations.”   

67   The  Customs  2020  Programme  Progress  Report  2020  states  that  during  2020,  three  new  e-learning 
modules  related  to  IT  systems:  INF  Special  procedures,  CLASS  and  Economic  Operator  System 
(EOS) were developed. Monitoring data provided by DG TAXUD nonetheless showed that there were 
nine  modules  developed  in  2020  (these  three  as  well  as  Radiation  and  nuclear  detection  Basic,  and 
Advanced, and four Car Search modules), and 95 localised versions, therefore adding up to 104. 

68   Combined number of all modules used in each country. 

28 

 
                                                           
 
 
report 04/2021 on customs controls70. While uniform application of controls is necessary 
to  prevent  fraudulent  importers  from  targeting  border  entry  points  with  lower  level  of 
controls, ECA found that Member States apply the financial risk framework71 in different 
ways,  resulting  in  a  lack  of  harmonisation  of  controls  that  hampers  the  EU  financial 
interests.  

4.1.3.  To  what  extent  has  the  Customs  2020  programme  supported  legitimate 
economic activities and prevented illegal ones 

It is challenging to measure the contribution of the programme to the long-term results it 
is  intended  to  achieve.  Firstly,  the  achievement  of  policy  objectives  is  incremental  by 
nature  because  it  is  the  result  of  many  subsequent  policy  actions  and  IT  developments 
and it is thus difficult to quantify the exact benefits of this cycle of the programme with 
precision, plus there are  conceptual challenges when translating certain type of benefits 
into quantifiable values. Secondly, even if these impacts could be quantified, it would be 
very  difficult  to  give  a  precise  indication  of  the  programme  contribution  to  them,  also 
because the programme is not implemented in isolation of other policy actions. For these 
reasons, the analysis is mostly supported by specific examples from the conducted case 
studies. The Commission intends to address these limitations under the next programme 
by establishing a policy structure framework for the programme actions (see the section 
“implementation  of  the  recommendations  from  the  mid-term  evaluation)  that  should 
allow the programme to be much more policy driven than activity driven.  

Support to legitimate economic activities 

The  evidence  collected  shows  that  the  Customs  2020  programme  has  primarily 
supported  legitimate  trade  by  developing,  maintaining  and  operating  the  EIS  for 
customs. The digitalisation of customs procedures has simplified and harmonised these 
procedures,  reducing  compliance  costs  and  increasing  legal  certainty  for  importers  and 
exporters.  Although  it  was  not  possible  to  quantify  these  impacts,  as  digitalisation  of 
customs  processes  is  complex  and  has  happened  progressively  for  more  than  20  years 
now, the following examples extracted from the case studies demonstrate these benefits.  

The  TARIC  and  QUOTA  databases  provide  economic  operators  with  a  clear  view  of 
measures  and quotas in  place when importing or exporting  goods into or from  the EU. 
They therefore support legitimate businesses by enabling economic operators to correctly 
codify their goods.  

The EBTI3 system stores binding tariff information decisions issued by national customs 
authorities  (BTIs)  and  contributes  to  eliminating  differences  in  the  application  of 

70   European  Court  of  Auditors,  Special  report  –  Customs  controls:  insufficient  harmonisation  hampers 

EU financial interests (04, 2021). 

71   The  Customs  2020  programme  (Financial  risk  management  project  group  CPG/076)  supported  the 
preparation  of  this  framework,  composed  by  the  FRC  Decision  adopted  in  2018  and  the  2019 
Guidance accompanying the Decision. 

29 

 
                                                           
classification  rules  amongst  different  economic  operators  within  the  EU,  thus  ensuring 
legal  certainty  for  the  operators  and  equality  among  them.  In  2019,  the  EBTI3  system 
was updated and linked to the Trader Portal, simplifying communication between the 
applicants and national customs authorities.  

The  updated  AEO  system,  with  the  implementation  of  the  EU  AEO  Direct  Trader 
Access,  allows  economic  operators  to  submit  requests  (and  additional  information)  and 
receive  notifications  from  the  decision-taking  customs  authority.  As  recognised  by 
national customs administrations, the central AEO system and its update have resulted in 
the  improvement  of  the  business  processes  for  granting  the  AEO  status  and 
contributed  to  more  efficient,  simplified,  and  standardised  customs  decision-making 
process. 

The  EU  CSW-CERTEX  project  has  also  brought  trade  facilitation  benefits  in  the 
participating  Member  States.  By  enabling  the  quick  sharing  of  electronic  data  between 
different  governmental  authorities  involved  in  goods  clearance,  this  system  has  largely 
replaced manual documentary controls, which are time and resource consuming for both 
authorities and businesses, by automated ones. 

Although  both  customs  authorities  and  economic  operators  interviewed  agreed  that  the 
programme  IT  capacity  building  activities  had  contributed  to  the  harmonisation  and 
simplification  of  customs  processes  and  therefore  the  facilitation  of  trade,  economic 
operators  also  noted  that  digitalisation  was  still  a  slow  and  ongoing  process.  Many 
benefits, like full digitalisation, harmonised data requirements and centralised clearance, 
have  not  materialised  yet72.  Furthermore,  economic  operators  also  raised  some 
challenges related to the more complex IT environment and the additional burden 
and technical difficulties that it represents. In particular, they referred to the increasing 
data  requirements  and  obligations.  These  have  been  especially  challenging  for  small 
companies which do not have the resources necessary to adapt to these changes quickly.  

In addition,  certain  economic operators  expressed concerns  that Member States did  not 
always  implement  the  new  EIS  for  customs  in  the  same  timeframe,  resulting  in 
differences  in  their  level  of  digitalisation  that  distorted  competition.  They  also 
highlighted the lack of updated information on the timeframe for the deployment of the 
customs EIS by Member States, and on the technical guidelines and specifications on the 
EIS  under  development.  However,  these  issues  are  beyond  the  scope  of  the  Customs 
2020 programme.  Indeed, the implementation  of national  components  of the EIS is the 
responsibility  of  Member  States,  and  they  can  make  use  of  a  deployment  window  that 
explains the referred timing differences. Also, it is the responsibility of Member States to 
communicate with economic operators on the deployment of IT systems at national level, 
together  with  their  technical  guidelines  and  specifications.  Beyond  the  notion  of 

72   This issue has also been raised in the interim evaluation of the UCC.  

30 

 
                                                           
responsibility, better engagement and information sharing with economic operators 
is an issue which could be addressed by the programme in the future.  

Although less prominently, joint actions and human competency building activities have 
also  contributed  to  support  legitimate  economic  activities.  Through  the  identification, 
development  and  application  of  best  working  practices  and  administrative  procedures, 
joint actions  have improved  the administrative capacity of the customs authorities 
and  the  conditions  and  procedures  for  undertaking  trade.  Both  national  customs 
authorities and economic operators pointed at the guidance and coordination in ensuring 
the correct interpretation of customs procedures and processes as the main benefit of joint 
actions.  They  also  highlighted  that  joint  actions  have  helped  to  arrive  to  a  common 
understanding  of  procedures  which  has  translated  into  the  design,  development  and 
functioning  of  the  related  EIS,  such  as  the  planned  Centralised  Clearance  for  Import 
system. The BTI Expert Teams project on divergent tariff classification, is another good 
example  of  this  contribution.  By  pooling  expertise  from  the  Commission  and  Member 
States  to  handle  cases  of  divergent  classification  of  BTIs,  the  project  contributed  to 
increasing the number of cases closed in the Committee, as well as reducing the average 
time it takes to close a case. This project group thus facilitated trade by increasing legal 
certainty.   

Finally,  the  Customs  2020  programme  provided  funding  for  eLearning  modules  and 
training  activities  to  enhance  and  align  the  competences  of  both  customs  officials  and 
economic operators. The latter accessed the eLearning courses on the Europa website and 
used  them  mostly  to  train  their  staff  involved  with  customs  matters.  Therefore,  these 
activities supported legitimate economic activities by ensuring that businesses have 
access  to  the  information  they  needed  to  operate  efficiently  and  effectively.  As 
explained in section 4.1.2, these activities also helped legitimate trade by enhancing legal 
certainty through improving the coherent application of customs law  

Evidencing the above, Table 7 shows that the number of eLearning courses downloaded 
by  economic  operators  and  others  multiplied  by  ten  between  2014  and  2020.  The 
increase  is  particularly  high  in  2016,  coinciding  with  the  entry  into  force  of  the  new 
customs legislative framework (UCC) on 1 May 2016 and also in 2020, coinciding with 
the launching of new courses especially relevant to traders, like UCC – Level 3: 'eAEO 
Trader Portal' and 'eBTI Trader portal'. Moreover, the improvements done on the Europa 
website  download  portal  allowed  the  download  of  multiple  courses  at  once.  The 
perception on the quality of the training also improved during this period and interviewed 
economic  operators  particularly  recognised  the  value  and  usefulness  of  e-learning 
courses, such as those on Brexit.  

31 

 
 
Table 7: PMF indicators related to publicly available e-learning courses73 (2014-2020) 

Target 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Number of 
downloaded e-
learning courses on 
the Europa.eu 
website 

Grow 
or 
stable 

3 219 

Average training 
quality score by 
other  
users (on a  
scale of 100) 

>70 

64 

3 202 

12 920 

11 807 

10 449 

10 529 

30 408 

≈ 

↗ 

↘ 

↘ 

≈ 

↗ 

69.2 

78.5 

73.1 

72.9 

75 

78.6 

↗ 

↗ 

↘ 

↘ 

↗ 

↗ 

Source: Customs 2020 Programme Progress Reports for 2014-2020 

Contribution to the prevention of illegal activities 

Although it is not possible to assess by means of quantitative analysis the extent to which 
the  Customs  2020  programme  has  contributed  to  prevent  illicit  activities,  some  of  the 
activities funded by the programme are preventive in nature and  it can be assumed that 
they  allowed to  detect  non-compliance, thus  contributing  to  fighting illicit activities.  In 
this regard, the digitalisation process supported by the programme provides as such the 
possibility  to  automate  checks  and  perform  data  validation,  cross-verification  and 
increasing  risk  management  and  control  capacities  of  customs 
analysis, 
administrations. National customs authorities also highlighted the benefit of the EIS for 
customs  in  ensuring  greater  harmonisation  and  the  coherent  application  of  Union  law, 
which supported the prevention of illegal activities. 

Certain EIS have specially contributed to the prevention of illegal activities by ensuring 
the  timely  and  secure  exchange  of  fraud-related  information  between  the  competent 
national and EU administrations, or the exchange, storage and analysis of relevant data. 
For instance, the Customs Risk Management System plays a key role in this regard and 
was  assessed  positively  by  interviewed  national  customs  authorities.  The  EU  CSW-
CERTEX, in its turn, contributes to enhancing the security and safety of the EU and the 
protection  of  the  environment,  by  enabling  customs  to  automatically  verify  compliance 
with a number of formalities required for the import or export of goods in different policy 
areas. SURV374 brings also important benefits in terms of data analysis capabilities at EU 
level, which are highly important in terms of fraud detection.      

73   Targeted at economic operators and individuals. 

74   Although the system has already been deployed, the data continues to be gathered in different formats 

until all Member States have aligned their national systems to the UCC data requirements.  

32 

 
 
                                                           
 
 
Joint actions were positively considered by interviewees as supporting the prevention 
of  illegal  activities.  Expert  teams  constitute  a  good  example  of  this.  CELBET  for 
instance coordinated controls in 174 crossing points throughout the EU and trained 300 
officers  from  all  CELBET  participating  Member  States  on  x-ray,  mobile  control, 
enhanced cooperation between Customs and border guards, car search, bus search, sniffer 
dogs  and  customs  control  process.  Interviewees  from  national  customs  authorities  all 
highlighted  the  positive  impact  of  the  work  of  CELBET  in  improving  the  control  of 
external  borders  and  preventing  illegal  economic  activities.  Customs  Laboratories 
Expert  Team  (CLET)  pooled  in  a  network  the  expertise  and  equipment  of  10  EU 
customs  laboratories,  to  analyse  samples,  share  results  of  analysis,  elaborate  an 
operational harmonised approach for analysis, contributing also to fight against fraud and 
contraband  on  the  basis  of  seizures.  By  sharing  the  identification  of  potential  noxious 
substances,  CLET  has  for  instance  helped  EU  customs  authorities  to  better  protect  the 
safety and security of the EU citizens. 

Finally,  human capacity building activities have also  contributed to the prevention 
of  illegal  activities  by  enhancing  the  competences  of  customs  officials  in  certain 
areas  (i.e.,  in-person  trainings  which  helped  participants  to  rummage  ships  and  cars 
better) 

Undervalued or counterfeit goods from China, specially linked to e-commerce, were 
highlighted by interviewed economic operators as an issue where the programme could 
play  a  stronger  role  by  proposing  more  cooperation  activities75  with  third  countries 
where these issues originate. The issue of e-commerce was  also  raised in a 2019 study 
from  the  European  Parliament  on  the  protection  of  EU  financial  interest76,  which 
recommended  the  development  of  an  IT  system  for  analysing  financial  transactional 
third-party data to detect fraud and in particular fraud related to e-commerce.  

4.1.4.   To  what  extent  have  the  Customs  2020  programme’s  resources  produced 
best possible results at the lowest possible cost? 

The external evaluation found it difficult to measure the extent to which the programme’s 
resources had produced the best possible results at the lowest possible cost. As it was not 
possible  to  monetise  the  benefits  of  the  Customs  2020  activities,  the  findings  on 
effectiveness presented above were considered alongside with the costs. Due to the high 
proportion  of  the  budget  spent  on  the  customs  EIS,  the  assessment  was  particularly 
focused on the funding of the functioning of existing customs EIS and the development 
of new ones. 

75   There are already several ASEM Joint Actions that aim to improve cooperation with third countries to 
increase safety and security and protect citizens and  the environment. These include  workshops (i.e., 
CWS/007),  working  groups  (i.e.,  CWS/022)  and  Director  Generals/Commissioners  meetings  (i.e., 
CSW/062). 

76   European  Parliament,  Study  requested  by  the  CONT  Committee  on  the  protection  of  EU  financial 
interest  on  customs  and  VAT:  Cooperation  of  national  tax  and  customs  authorities  to  prevent  fraud 
(2019). 

33 

 
                                                           
IT capacity building activities  

As mentioned before, the Customs 2020 Programme spent77 EUR  464.5  million on IT 
capacity  building,  accounting  for  87%  of  the  programme’s  budget  expenditure.  In 
addition to the budget spent at EU level, the Member States invested resources at national 
level to run the national components of the customs EIS. To assess the value for money 
of these activities, the external evaluation analysed the following systems in detailed, on 
the basis of the thematic case studies conducted: ICS2, SURV3, EBTI3, CDS, EU CSW-
CERTEX, and AEO upgrade.  

Table 8: Commission committed budget to the development of specific IT projects 

  2014 

2015 

2016 

2017 

2018 

2019 

2020 

Total 

Total IT 
projects 

5 646 623  10 431 000 

7 941 000 

8 526 537 

17 261 347  13 347 000  5 904 350  69 057 858 

ICS2 

N/A 

N/A 

N/A 

600 000 

3 250 000 

2 700 000 

1 080 000  17 313 087 

7% 

19% 

20% 

18% 

11% 

SURV3 

EBTI3 

CDS 

AEO 
upgrade 

EU CSW-
CERTEX 

200 000 

400 000 

800 000 

800 000 

300 000 

200 000 

2 700 000 

4% 

4% 

10% 

5% 

2% 

3% 

4% 

N/A 

350 000 

300 000 

200 000 

500 000 

300 000 

200 000 

100 000 

1 950 000 

6% 

3% 

3% 

6% 

2% 

1% 

2% 

3% 

800 000 

2 750 000 

750 000 

500 000 

2 200 000 

1 600 000 

600 000 

8 600 000 

14% 

26% 

9% 

6% 

13% 

12% 

10% 

13% 

100 000 

100 000 

18% 

1% 

N/A 

N/A 

N/A 

N/A 

N/A 

200 000 

0% 

N/A 

N/A 

N/A 

200 000 

924 350 

650 000 

1 450 000 

3 224 350 

2% 

5% 

5% 

25% 

5% 

Source: e-Customs annual progress reports 2014-2020 

Most  of  the  information  used  to  evaluate  these  systems  was  gathered  through  a  survey 
targeting national authorities. It is important to take into consideration that the cost data 
provided  by  the  respondents  varied  widely  across  national  authorities  and  the  response 
rate  remained  low.  This  data  was  also  complemented  with  high-level  cost  information 
available  at  Commission  level  and  with  the  input  from  interviews  conducted  with  both 
national  authorities  and  Commission  DGs.  The  table  below  shows  the  programme 

77 As the programme is still implementing activities funded, final data on payment appropriations budget is 
not yet available. Therefore, the expenditure of the programme presented in this evaluation is based on the 
data  on the  committed budgets. For Joint Actions, this data  is complemented by actual expenditure data, 
which was extracted from ART.   

34 

 
 
 
                                                           
 
expenditure on the development of the specific customs EIS covered in the case studies 
and their percentage of the total Commission committed budget for the development of 
these systems78.  

The costs of the customs EIS seem to be reasonable for national authorities79, as most of 
them are covered by the European Commission through the Customs 2020 programme. 
According  to  the  survey  results,  the  ICS2  system  is  the  costliest  for  Member  States  in 
general  and,  in  particular,  in  relation  to  one-off  development  costs80  and  one-off  and 
ongoing support costs81. One-off development costs were higher than average also for the 
CDS.  Meanwhile, SURV3 is  the most expensive in  terms  of infrastructure costs82, both 
one-off  and  ongoing.  However,  this  has  to  be  put  into  context  with  the  scope  of  the 
different  EIS,  their  size  and  complexity.  ICS2  and  CDS  for  instance,  are  complex 
systems,  implementing  many  functional  requirements,  and,  therefore,  imply  different 
costs from a database such as the SURV3.   

Customs authorities that responded to the cost-benefit survey considered all systems 
to be moderately cost-effective83, except the SURV3, which appears to be only partly 
cost effective. This perception could be influenced by the intrinsic nature of this system, 
which records and centralises import and export data transmitted by the national customs 
authorities and therefore, unlike other systems, is not meant to reduce costs of customs 
administrations or to support their work but to increase data analysis capabilities at EU 
level. In addition, the system is not yet delivering its full potential as data continues to be 
gathered in different formats until all Member States align their systems to the UCC data 
requirements by end 2022 as provided by the UCC as amended in 2019.   

The  survey  confirmed  that  all  selected  EIS84  have  brought  relevant  benefits  to 
national authorities. As presented in Figure 7, and in line with what has been explained 
earlier  in  the  section  (see  4.1.1,  4.1.2  and  4.1.3),  the  benefits  experienced  by  most 
national authorities are:  

78   These  amounts  do  not  take  into  consideration  the  development  costs  related  to  the  Common 

Communication Network 2. 

79   In addition to the budget spent at EU level, the Member States invest resources at national level to run 
some  of  the  national  elements/components  of  the  EIS  for  customs  (more  information  is  provided  in 
Annex VIII). 

80   Analysis  and  process  re-engineering,  coding,  project  management,  test,  configuration  and  change 
management, deployment. 

81   Helpdesk, operations to support the system, its users, and end-users. 

82   Required  to  develop,  support,  operate  and  maintain  the  systems,  including  hardware  costs  (network, 
server, storage)  for running the systems and  software  costs of applications, licenses, libraries required to 
operate the systems. 

83   See scale in Figure 7 

84   Information  on  the  EU  CSW-CERTEX  was  not  collected  through  the  survey,  as  it  was  already 
available in the impact assessment of the initiative for developing an EU Single Window environment for 
customs.  

35 

 
                                                           
  Automated processes contributing to more efficient, simplified, and standardised 

customs procedures; 

  More effective implementation and coherent application of Union law in the field 

of customs; 

 

Increased interoperability and information sharing between customs authorities. 

Figure 7: key benefits deriving from selected Customs EIS 

The answers provided by respondents were rated following a 1-5 rating scale: 1=Not at all; 2=To a limited 
extent; 3= To some extent; 4=To a moderate extent; 5=To a great extent. Eight of the benefits are system-
specific, which explains why the figure presents values only for one system.  

Source: Based on the survey to national customs authorities.  

According  to  the  respondents,  the  benefits  of  SURV3,  EBTI3,  CDS  and  the  AEO 
upgrade, outlined above have not resulted in increased or decreased costs regarding 
the time staff dedicated to their tasks and other costs associated with the processes that 
the EIS supported. 

Meanwhile, the benefits of ICS2 have resulted in an increase in costs of up to 25% in 
comparison with the previous situation for most respondents (33% of responses, 5 of 
15) regarding labour costs and other operating costs associated with the system. 

36 

 
 
 
 
 
 
 
 
The  main  benefits  associated  with  the  EU  CSW-CERTEX  as  identified  in  the 
evaluation of the project included in Annex 14 of the impact assessment of the EU SWE-
C initiative85 are: 

 

 

the time savings in the clearance of goods (for both authorities and economic 
operators)  derived  from  the  exchange  of  electronic  data  between  competent 
authorities that enables to automate documentary controls, and; 

the more effective implementation and coherent application of Union law in 
the  field  of  customs  and  related  matters  (namely  the  non-customs  regulatory 
formalities covered), and the subsequent increase in safety and security.  

In  conclusion,  although  it  is  not  possible  to  determine  whether  the  analysed  EIS  for 
customs have achieved value for money, the findings related to the cost-effectiveness 
of  the  six  EIS  for  customs  and  the  respondents’  perceived  benefits  of  these  systems, 
provide a positive picture of their efficiency. This positive assessment is also reinforced 
by the fact that the EIS for customs have contributed to economies of scale, compared to 
a  situation  where  the  Member  States  would  have  developed  their  own  systems.  In 
addition, certain of the realised benefits would not have been achieved in that case. For 
instance,  the  possibility  to  apply  for  and  authorise  multi-Member  States  customs 
decisions, which would not be possible without the CDS.  

Joint actions  

The  Customs  2020  Programme  spent  EUR  56.8  million  on  joint  actions  (including 
external  experts),  accounting  for  around  11%  of  the  programme’s  expenditure.  The 
breakdown  of  this  expenditure  by  main  type  of  joint  action  (expert  teams,  external 
experts, studies and communication,  and  “other types of joint  actions”86) is  provided  in 
Figure 8 below.  

The analysis of the efficiency of joint actions was particularly focused on expert teams 
and “other type of joint actions”, which accounted for 93% of the expenditure under this 
category  and  represented  activities  directly  aimed  at  bringing  together  participating 
countries to cooperate towards the programme’s objectives.  

85   Commission  Staff  Working  Document  Impact  AssessmentEU  Single  Window  Environment  for 

Customs (europa.eu) 

86  “other  types  of  joint  actions”  consist  of  seminars  and  workshops,  project  groups,  working  visits, 
monitoring activities, capacity building and supporting actions. 

37 

 
 
                                                           
 
Figure 8: Distribution of programme expenditure on joint actions by type of action (2014-2020) 

Source: Data on committed budgets 

Expert  teams  are  a  new  type  of  joint  action  introduced  by  the  Customs  2020 
programme.  The  first  one  was  launched  in  2016  and  since  then,  there  have  been  nine 
expert teams covering four topics87. The entire expenditure on expert teams amounted to 
EUR  7  million  (12%  of  joint  actions’  expenditure).  As  previously  highlighted  (see 
sections  4.1.1,  4.1.2  and  4.1.3),  expert  teams  have  been  perceived  positively  by 
stakeholders  for  their  contribution  to  the  programme’s  objectives.  They  have 
provided a place for national customs authorities to work together towards solutions in a 
practical way on a regional or thematic basis. CLET, CELBET and ETCIT expert teams 
are  good  examples  of  this  cooperation.  Although  the  different  nature  of  this  newly 
implemented  activity  (and  therefore  different  monitoring  data)  makes  it  difficult  to 
conclude  on  their  cost-effectiveness  in  comparison  to  other  joint  actions,  the  cost 
efficiency of expert teams  was  highlighted by  some stakeholders interviewed,  as they 
provide  the opportunity for Member States  to pool  resources  and expertise rather 
than acting separately. 

Most of the programme expenditure on joint actions (71%) relates to the category 
“other”,  which  includes  seminars  and  workshops,  project  groups,  working  visits, 
monitoring activities, capacity building and supporting actions. The total expenditure on 
these types of actions amounted to EUR 40.4 million.  

Between 2014 and 2020, 1.117 joint actions were set up of which 948 incurred costs. The 
monitoring data extracted from ART88 (Table 9) reveal that most of the budget was spent 
on project groups (76%), followed by workshops (9%) and seminars (6%).  

While  in  absolute  terms  the  most  expensive  “other”  joint  action  type  is  project  groups 
(EUR 120 800 per project group), this is mainly due to the high number of participants. 

87 BTI 1 and 2, CELBET 1, 2 and 3, CLET 1 and 2, ETCIT 1 and 2. 

88  These  data  are  not  fully  comparable  with  the  committed  budget  figures  as  they  represent  payment 
appropriation data and do not include all third countries participating in the programme.  

38 

 
 
                                                           
 
By  contrast,  the  average  cost  of  a  project  group  meeting  by  participant  was  only 
EUR 67689, which represents the lowest cost per participant of all joint actions.   

The average expenditure by participant of the different actions is about the same or up to 
10%  less  than  what  was  reported  in  the  mid-term  evaluation,  with  the  exception  of 
project groups which on average cost 22% less than what was reported at mid-term (EUR 
676  instead  of  EUR  868).  This  reduction  in  cost  may  partially  be  due  to  the  cost 
reduction from April 2020 onwards as meetings were held online due to the COVID-19 
restrictions. 

Table 9: Joint actions expenditure, number, and participants (2014-2020) 

Type of joint 
action 

Total 
budget 
spent (€) 

% 
budge
t 
spent 

Numbe
r of 
joint 
actions 

% of 
joint 
action
s 

Averag
e 
budget/ 
action 
(€) 

Number of 
participant
s 

% 
of 
tota
l 

Average 
expenditure/participa
nt (€) 

Project groups 

22 350 02
8 

76% 

185 

20 

120 811 

33 043 

83 

Workshops 

2 788 777 

9% 

100 

11 

27 888 

2 816 

Working visits 

1 933 100 

7% 

605 

64 

3 195 

1 641 

Seminars 

1 777 891 

6% 

28 

Capacity 
building 

Communicatio
n 

381 276 

1% 

12 

206 637 

1% 

5 

Monitoring 

134 768 

0% 

13 

3 

1 

1 

1 

63 496 

1 620 

31 773 

371 

41 327 

251 

10 367 

97 

7 

4 

4 

1 

1 

0 

676 

990 

1 178 

1 097 

1 028 

823 

1 389 

Total 
expenses 

29 572 
477 

100% 

948 

100 

31 195 

39 839 

100 

742 

Source: Budgetary data extracted from ART as provided by DG TAXUD 

One of the issues raised by consulted stakeholders was the need for invitations to be sent 
out  more  in  advance.  The  short  notice  makes  it  difficult  for  the  participating 
countries  to  find  the  right  expert(s)  and  increase  the  travelling  cost.  In  addition, 
national  authorities  bear  certain  expenses  (i.e.,  the  VAT  incurred  by  the  organising 
Member  State,  interpretation  costs,  participation  of  additional  participants,  informal 
activities linked to  the formal  event) or burdens  (i.e., complexity of declaring  expenses 
for  expert  teams  or  time  spent  by  administrative  staff  overseeing  the  programme 
budget  and producing  final  reporting)  that  they  would like to  see either  covered by the 
programme or reduced.  

Despite these observations, and as evidenced in sections 4.1.1, 4.1.2 and 4.1.3, the joint 
actions  have  produced  a  great  amount  of  added  value,  enhancing  cooperation  and 

89   Excluding organisational costs, but including expenses for daily allowance, hotel, and travel. 

39 

 
                                                           
 
 
working  relationships  among  participants.  They  have  also  supported  the  preparation  of 
Union  law  and  the  effective  implementation  of  the  legislation  in  force  through  the 
development  of  the  customs  EIS  and  best  working  practices  for  administrative 
procedures.  They  have  ultimately  contributed  to  the  support  of  legitimate  trade  and,  in 
certain  cases,  the  prevention  of  fraud.  The  overall  opinion was  that  the cost  of  these 
actions was proportionate to the generated benefits.  

Human competency building activities 

Overall, the Customs 2020 programme spent  EUR 10.4  million on human competency 
building, accounting for only 2% of the programme budget. These activities included 
the  development  of  eLearning  modules,  face-to-face  training  courses  intended  for 
different  audiences  (customs  officials  and  economic  operators)  as  well  as  the 
development of the EU Customs Competency Framework and Training Curricula.  

Table 6 (see section 4.1.2) and 7 (see section 4.1.3) provide an overview of the reported 
outputs.  As  evidenced  in  those  sections,  the  main  benefits  of  Customs  2020  training 
activities are linked to  a more  coherent application of customs law and ultimately  a 
more effective and efficient functioning of the Customs Union, as they enhance the 
capacity of customs officials to perform their duties, as well as the understanding of 
customs rules by economic operators.  

Most stakeholders did  not  specifically  comment  on the value for money  of the training 
organised  and/or  eLearning  modules  produced.  Nevertheless,  as  presented  in  previous 
sections,  the  participants  in  the  activities  perceived  them  as  useful.  Some  national 
customs officials even highlighted human competency building as one of the key benefits 
of  the  programme,  due  to  its  important  role  in  supporting  and  reinforcing  the  skills  of 
customs authorities. Although this type of activity only consumes about 2% of the total 
programme budget, it can be considered to have one of the highest value for money, 
as it has produced a great number of training materials that can be used over and 
over  without  incurring  any  additional  cost  (with  the  exception  of  making  the 
necessary updates). 

In  response  to  the  mid-term  evaluation  recommendation  to  “Refine  the  strategy  for 
development  and  promotion  of  eLearning  modules”,  the  Commission  has  reinforced 
structured consultations with national administrations to identify training needs and  has 
developed  an  EU-level  learning  management  system  (Customs  &  Tax  EU  Learning 
Portal)90. These developments are expected to improve the value for money of training 
activities under the next iteration of the programme.  

90   Customs & Tax EU Learning Portal (europa.eu) 

40 

 
 
                                                           
4.1.5.  To  what  extent  is  the  Customs  2020  programme  coherent  with  broader  EU 
policies? 

While the results of the mid-term evaluation on the strong internal coherence between the 
different levels and components of the programme and its design remain valid, the final 
evaluation  has  focused  on  the  external  coherence  of  the  programme  in  the  broader  EU 
policy context.   

The  Customs  2020  programme  is  designed  to  support  specific  policies  in  the  customs 
area and is therefore coherent with the priorities of the Customs Union. Beyond that, the 
programme  has  supported  the  work  of  other  Commission  services  in  EU  policies  and 
priorities  outside  the  customs  sphere.  This  is  particularly  the  case  of  policy  areas  that 
impose regulatory requirements91 for the import and export of certain goods, in order to 
protect the environment, human, animal and plant health, cultural and economic interests 
or  other  public  policies  in  the  area  of  safety  and  security.  Customs  authorities  conduct 
customs controls, whereby the enforcement of these measures and the cooperation with 
the  respective  governmental  authorities  becomes  crucial.  It  was  therefore  important  to 
ensure that the programme aligned with and supported these policies.  

The impact assessment for establishing the next Customs programme, as well as the mid-
term  evaluation  of the Customs 2020 programme and the interviews conducted for this 
final  evaluation,  lead  to  multiple  examples  in  which  the  programme,  through  its 
different activities, has contributed to or benefited from other EU initiatives: 

  By  supporting  the  development  of  the  EU  SWE-C92,  the  programme  has 
enhanced coherence with multiple policy areas imposing regulatory requirements 
for  the  import  and  export  of  specific  goods,  as  explained  before.  This  has 
improved  the  implementation  of  the  specific  non-customs  measures,  facilitating 
their consistent application and enforcement at the border;  

 

In line with the above, the programme supported the prevention of illegal trade 
of fluorinated greenhouse gases (F-gases), which pose a significant risk to the 
environment,  by  bringing  together  customs,  environmental  and  surveillance 
national  authorities  in  a  project  group  on  these  substances  (CPG/183).  One 
concrete  output  of  this  group  was  a  checklist  for  customs  authorities  with 
concrete instructions on what they need to do when confronted with the import of 
F-gases. The checklist has proved to be a useful tool for customs officials and is 

91   These requirements are listed in “EU Prohibitions and Restrictions for Customs, June 2018”. Available 
at:https://ec.europa.eu/taxation_customs/sites/default/files/prohibition_restriction_list_customs_en.pdf. 

92   The programme funded several activities to support the development of the EU SWE-C: IT capacity 
building – EU CSW-CERTEX project and joint actions – project group to study a possible framework 
to develop the EU SWE-C including the legal context (CPG/130), Customs Business Group meetings 
on SWE-C (CBG-CPG/031), Portugal working visit on implementation of a national Customs Single 
Window  (CWV/433),  high-level  seminar  on  EU  SWE-C  (CSM/022)  and  project  Group  on  the 
EUSWE-C examination and concretisation of the B2G dimension and functionality (CPG/208). 

41 

 
                                                           
being broadly used.93 The work of the project group also supported the review of 
the 2015 F-gases Regulation and the follow-up legislative proposal to update it94, 
with  the  aim  to  make  the  enforcement  by  customs  easier  and  more  effective, 
ultimately  supporting  the  EU  broader  policy  objectives  related  to  protecting  the 
environment and combating climate change; 

  The Structural Reform Support Programme (coordinated by DG REFORM)95 
provided tailor-made support to Member States, contributing to develop national 
customs  administrations’  capabilities  needed  for  delivering  the  Customs  2020 
objectives,  especially  in  the  areas  of  anti-fraud  activities  and  customs  controls. 
This includes, for example, equipment for border customs officials and funds for 
feasibility  studies  and  mandatory  IT  systems.  At  the  same  time,  the  Customs 
programme also contributed to boosting capabilities of Member States through its 
own capacity building activities and therefore there are strong complementarities 
and linkages between the two programmes; 

  By  managing  with  similar  structures  both  Customs  and  Fiscalis  2020 
programmes, DG TAXUD optimises efficiency and achieves complementarity 
and  synergies  between  the  two  programmes.  Furthermore,  both  programmes 
share some operational features that they co-fund and which are available for both 
customs  and  tax  administrations  (i.e.,  the  CCN  network).  The  mid-term 
evaluation  pointed  at  some  opportunities  for  coordination  and  cross-fertilisation 
in  areas  like  excise  duties  as  well  as  for  shared  approaches  to  human  capacity 
building and training;  

 

In the case of Hercule III programme administered by the European Anti-Fraud 
Office  (OLAF),  both  the  interviews  conducted  under  this  evaluation  and  the 
evidence  collected  in  the  mid-term96  and  final97  evaluation  of  that  programme 
confirmed  that  there  are  both  formal  and  informal  mechanisms  across  DG 
TAXUD and OLAF to avoid overlaps and facilitate synergies between the two 
programmes.  Their  respective  Annual  Work  Programmes  are  subject  to  inter-
service consultation and there are fora, such as the Customs Cooperation Working 
Party  (CCWP)98,  where  representatives  of  both  Commission  services  are 

93   Through  the  PARCS  Expert  Group,  the  checklist  was  also  distributed  to  customs  administrations  in 

other Member States that were not part of the project group. 

94   See EU legislation to control F-gases (europa.eu) 

95   This has recently been replaced by the Technical Support Instrument (TSI). 

96 Mid-term Evaluation of the Hercule III Programme - Final Report, November 2017. 

97 Fraud prevention – final evaluation of the Hercule III programme (2014-20) (europa.eu) 

98   The  CCWP  is  a  Council  Working  Party  that  handles  work  regarding  operational  cooperation  among 
national  customs  administrations  with  a  view  to  increasing  their  enforcement  capabilities.  It  defines 
strategic and tactical objectives for joint customs operations and focuses on achieving results in terms 
of seizures, identification of new threats and disruption of criminal gangs. 

42 

 
                                                           
involved,  allowing  for  opportunities  to  exchange  information,  reduce  potential 
overlaps  and  look  for  synergies  across  the  Customs  and  Hercule  programmes.99 
New  measures  have  also  been  taken  to  ensure  future  coherence  and  avoid 
potential  overlap  between  the  successor  programmes100.  Nevertheless,  the 
mechanisms  established  have  been  more  effective  in  avoiding  overlaps,  but, 
reportedly,  there  is  still  some  room  for  improvement  in  terms  of  ensuring 
synergies,  for  instance  by  developing  repositories  of  data  that  are  useful  for  the 
two programmes as well as analysing the data jointly.  

Overall, the evaluation identified the following mechanism as currently used to ensure 
the external coherence of the Customs 2020 programme: 

  Inter-DG  meetings  and  inter-service  consultations,  which  have  strengthened 

cooperation and communication between relevant DGs;  

  Project and expert groups, such as PARCS101 bringing together Commission 
officials and Member States authorities from different policy areas. In areas 
where  both  customs  and  other  governmental  authorities  are  competent  for  the 
enforcement  of  specific  legislation,  mixed  project  groups  proved  to  be  very 
fruitful.  They  have  enabled  sharing  of  best  practices,  development  of  joint 
documents  and  guidelines  in  cooperation  with  other  authorities  or  provision  of 
customs  expertise  and  advice  in  the  application  and  review  of  non-customs 
legislation when needed; 

  Participation of Commission officials as observers in customs project group 
meetings and activities. In cases where the DGs are not formal members of the 
project groups, they were still able to participate in several project group meetings 
as observers, bringing advice and knowledge;  

  Assessment  of  project  proposals  by  officials  from  different  DGs.  To  avoid 
overlaps of funding and maximise synergies and efficiencies, projects submitted 
to  DG  REFORM  by  Member  States  are  reviewed  by  staff  from  other  DGs 
(TAXUD,  ECFIN).  This  also  ensured  that  projects  served  the  Commission 
common priorities; 

Despite the positive outcomes presented above and apart from the observations raised in 
relation  to  Hercule  III,  this  evaluation  (and  previous  analysis102)  also  found  room  for 
improvement in:  

99   Mid-term Evaluation of the Hercule III programme, Op. Cit. 

100   Final Evaluation of the Hercule III programme, Op. Cit. 

101   Prohibitions and Restrictions Customs Controls Strategy expert group. 

102   Mid-term  evaluation  of  the  Customs  2020  and  impact  assessment  establishing  the  next  Customs 

programme.  

43 

 
                                                           
  Reinforcing  the  cooperation  with  third  countries’  authorities,  especially  for 
supporting  the  delivery  of  EU  environmental  goals  and  related  multilateral 
environmental  agreements  and  strengthening  coherence  between  Member 
States and the Commission’s positions at international fora such as the World 
Customs Organization (WCO), as suggested by some customs administrations; 

  Enhancing  complementarities  with  the  Internal  Security  Fund  and 
Instrument  for  Border  Management  and  visa,  looking  into  a  more  joined-up 
and cross-sectoral approach at operational level, including through better use and 
interoperability between electronic systems or the development of synergies and 
technologies  for  joint  operations  and  controls,  as  identified  in  the  impact 
assessment for the next iteration of the programme; 

  Further structuring or formalising cooperation with other Commission DGs, 
providing  a  more  formal  framework  for  discussions  between  DGs.  This  was 
suggested  by  Commission  interviewees  and  was  also  highlighted  as  an  area  for 
improvement during the mid-term evaluation;  

  Raising  the  visibility  of  the  programme  and  of  complementary  EU  funding 
instruments  within  the  Member  States.  National  authorities  consulted  both  in 
the context of the final and the mid-term evaluation pointed at room to strengthen 
cooperation  between  DGs  for  raising  the  visibility  of  the  Customs  programme 
and  for  providing  more  information  about  other  complementary  EU  funding 
instruments to national customs authorities and economic operators. IT synergies 
with  other  EU  programmes  that  run  significant  electronic  systems,  in  particular 
those  impacting  on  business,  could  also  be  exploited  by  the  Customs  2020 
programme.  

4.2.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE? 

The Customs Union is an essential and integral element of the functioning of the Single 
Market. By virtue of being an exclusive EU competency, customs legislation is adopted 
at  the  EU  level,  but  it  is  implemented  by  the  Member  States.  Thus,  cooperation  is 
required to ensure a harmonised implementation and application.  

The  programme’s  role  in  the  development,  maintenance  and  operation  of  the  customs 
EIS  has  particularly  contributed  to  the  simplification  and  harmonisation  of  customs 
processes  and  procedures  at  EU  level.  The  upgraded  paperless  environment  has 
significantly  increased  efficiency  and  effectiveness.  Customs  EIS  have  enabled  the 
implementation of the new customs legislative framework (except for those systems and 
related provisions that were delayed), leading to economies of scale that would not have 
been possible if each Member State had developed similar IT systems on its own. Table 
10 provides a number of examples evidencing that Member States working alone could 
not have achieved the same result.   

44 

 
Table 10: Examples of EU added value of the Customs EIS 

EIS for customs 

IT Systems added value 

TARIC: 
multilingual 
database  that  centralises  all 
measures  relating  to  EU 
customs  tariff,  commercial 
and agricultural legislation.  

Increase  in  effectiveness:  The  most  effective  way  of  securing  a  uniform 
presentation and coherent application of the customs Union law is for these 
measures to be integrated and coded at central level. Through TARIC and 
the  Customs  2020  programme,  the  Commission  provides  all  economic 
operators and customs officials within the EU a clear view of the measures 
to be undertaken when importing/exporting in/from the EU.  

Increase  in  efficiency:  The  day-by-day  changes  in  Union  legislation  are 
recorded  in  the  TARIC  central  database  which  is  continuously  updated. 
The  Member  States  are  given  prompt  daily  electronic  updates  which  feed 
into  their  national  systems  for  customs  clearance,  with  the  goal  of 
maximising automatic clearance.  

All stakeholders recognised  the EU added value of the TARIC central 
database.  Interviewees  highlighted  the  reduction  in  errors,  the  increase  in 
speed  and  the  reduction  in  burden  and  cost  as  contributing  factors  to  the 
added  value  of  TARIC.  Stakeholders  consulted  also  recognised  the 
coherent  and  harmonised  application  of  EU  law,  the  provision  of 
harmonised  and  compatible  data  (which  would  not  be  the  case  if  each 
Member  State  were  to  rely  on  national  TARIC  systems  alone)  and  the 
collection of EU wide statistics. 

EBTI3: 
centralises 
and 
stores  all  binding 
tariff 
applications 
information 
and decisions across the EU 
and  acts  as  a  reference 
point for Member States. 

The EBTI supports the uniform tariff classification of goods in the EU and 
the  application  of  the  customs  legislation  which  would  not  be  possible 
without  the  existence  of  a  central  system  at  the  EU  level.  It  reduces  the 
potential for issuing divergent BTI decisions and facilitates communication 
between stakeholders to a greater extent than could be achieved by Member 
States acting alone.  

EU  CSW-CERTEX  links 
customs 
Member  State 
EU 
to 
systems 
systems/databases 
managing 
requirements, 
as TRACES  

non-customs 
such 

The  EU  CSW-CERTEX  provides  quicker  and  more  efficient  sharing  of 
electronic data  between customs and other competent authorities involved 
in  goods  clearance  at  the  border.  It  increases  efficiency  by  enabling 
customs  authorities  to  automatically  verify  the  compliance  with  EU  non-
customs  formalities.  It  also  improves  the  effective  enforcement  of  non-
customs  policies  by  allowing  national  authorities  to  properly  monitor  and 
control the quantities of authorised goods imported or exported in the EU 
(EU  wide  quantity  management),  which  could  not  be  achieved  by 
Member States acting alone  

UUM&DS:    ensures  the 
uniform  authentication  and 
authorisation  of  economic 
their 
operators,  enabling 
direct  unified  access  to  a 
number  of  central  Customs 
federating  MS 
EIS,  by 
Access 
and 
Identity 

The UUM&DS links to central systems, such as the CDS, EORI or AEO 
systems,  which  are  operated  at  the  EU  level.  Its  development  required 
extensive  cooperation  between  Member  States,  which  was  only  possible 
thanks to the Customs 2020 programme. Similarly, to other systems, it is an 
EU level central tool,  which  Member States could not  have  built alone in 
an interoperable way across the Customs Union.  

45 

 
Management systems.   

Customs Decision System 
(CDS): harmonises the 
processes for application 
and management of 
customs decisions across 
the EU 

The centrally developed CDS brings EU added value compared to what 
Member Sates acting alone could achieve, as it allows economic operators 
to apply for and manage their customs decisions through a single EU 
interface and enables national customs authorities to consult each other on 
the granting and management of authorisations that are valid in more than 
one Member States. It provides system-to-system access for import, export 
and transit systems to authorisation data, allowing to automatically check 
their existence and validity.  

Customs Risk 
Management System 
(CRMS) and Import 
Control System 2 (ICS2) 

The CRMS and ICS2 facilitate the exchange of information for risk 
management purposes. The added value lays at their potential to generate a 
concerted and coordinated EU-wide approach to risk management that 
would otherwise not be achieved by a single Member State acting 
independently. 

SURV3: collects 
information provided in the 
customs declarations and 
stores it in a central 
database.  

According to the survey results, the most relevant benefit and added value 
of  SURV3  is  the  improvement  of  existing  data  mining  capabilities  at  EU 
level. It centralises in one place the relevant information related to imports 
and  exports  in  the  EU,  supporting  the  identification  of  fraud  trends  and 
patterns,  providing  insights  on  trade  flows  to  better  understand  relations 
between  the  EU  and  other  trading  blocks,  collecting  statistics  on  specific 
goods requested by other DGs, etc.   

Source: External study to support the final evaluation of the Customs 2020 Programme and DG TAXUD  

In  the  context  of  joint  actions,  the  programme  has  regrouped  the  expertise  of 
participating countries, providing the opportunity for Member States to  access  a wider 
pool  of  knowledge  and  experts  than  if  they  had  acted  at  individual  level,  particularly 
smaller Member States. The project group on enhancing the uniform tariff classification 
throughout  EU  and  improving  the  functioning  of  the  BTI  system  was  highlighted  as  a 
successful example in this regard.   

Increased  cooperation  and  communication  provided  Member  States  with  valuable 
insights  into  the  functioning  of  the  other  Member  States’  customs  and  introduced  a 
forum  for  the  exchange  of  best  practices  and  solutions  for  a  more  efficient  and 
effective  Customs  Union.  This  added  value  was  highlighted  by  all  interviewees.  This 
was  particularly  relevant  for  certain  topics  or  activities  which  might  not  have  had 
received  the  same  level  of  attention  at  a  national  level.  For  instance,  the  Canine  Unit 
Network  (CUN)  enabled  Member  States  with  a  small  number  of  customs  dogs  and/or 
limited  experience  in  the  field  of  customs  dogs  to  participate  and  learn  from  other 
Member States’ experiences.  

Joint  actions  have  also  ensured  the  uniform  application  of  EU  legislation  in  all 
Member  States,  such  as  the  rules  of  origin,  and  classification  of  goods.  The  Customs 
Project  Group on the classification of products  in  the  HS/CN nomenclature serves as  a 
good example. It enabled the sharing of information and knowledge between the Member 

46 

 
 
 
States  and  the  Commission,  leading  to  a uniform  application  of  common  provisions, 
which would have been more difficult to achieve without the programme’s activities.  

Human  capacity  building  activities  have  in  its  turn  contributed  to  a  better 
understanding of EU customs legislation and related EIS and therefore to enhance 
uniformity, ultimately improving effectiveness and efficiency of customs throughout the 
EU.  ELearning  modules  accessed  by  a  wide  range  of  customs  officials  and  economic 
operators have been critical for this. These are benefits that would not have been possible 
to achieve by national administrations acting on their own.  

Building  on  the  previous  analysis,  the  evaluation  looked  at  the  consequences  of 
discontinuing  the  programme.  Consulted  stakeholders  found  it  difficult  to  imagine 
alternative  ways  of  operating  and  cooperating,  in  particular  with  regard  to  the 
management of the customs EIS and the central role that they play in the Customs Union. 
In  their  view,  these  are  the  main  potential  impacts  of  discontinuing  the  programme’s 
support: 

  The  discontinuation  of  the  programme  would  require  Member  States  to  replace 
customs EIS systems that are managed by DG TAXUD through the programme. 
It  would  entail  stopping  the  operation  of  the  common  IT  infrastructure  and 
components, which are the backbone of customs procedures, therefore causing a 
major disruption of EU international trade. Moreover, it will increase the cost and 
burden  on  Member  States  and  reduce  the  effectiveness  of  having  central 
harmonised IT systems. 

  The cooperation element of the Customs programme’s joint actions is critical in 
enhancing  the  uniform  application  and  implementation  of  customs  legislation, 
processes and procedures. The discontinuity of the programme and therefore, of 
its joint actions would considerably affect this harmonisation, eventually resulting 
in an uneven playing field for economic operators and distortion of competition in 
the internal market. 

  More  generally,  the  absence  of  co-funding  mechanisms  as  currently  provided 
through  the  Customs  2020  programme  would  increase  the  burden  and  cost  on 
Member  States,  reducing  economies  of  scale  and  resulting  in  a  less  efficient 
Customs Union.  

4.3. 

IS THE INTERVENTION STILL RELEVANT? 

As  indicated  previously,  the  Customs  Union  is  an  area  of  exclusive  Union  competence 
where the Union shares the responsibility for its implementation with the Member States. 
The  direct  needs  to  make  the  Customs  Union  work  seamlessly  are  therefore 
predominantly  on  the  side  of  customs  administrations,  which  operate  in  conditions  of 
increased  necessity  to  exchange  information,  cooperate  and  build  their  administrative 
capacity.  Secondary  target  audiences  whose  needs  should  be  considered  are  also 
economic operators. 

47 

 
The  relevance  of  the  Customs  programme  was  confirmed  by  the  mid-term 
evaluation,  which  concluded  that  the  programme’s  specific  and  operational  objectives 
were  relevant  to  the  needs  of  stakeholder  and  that  ambitious  policies  would  not  have 
been possible without the programme.  The final  evaluation has  therefore  focused on 
continued  relevance  in  light  of  the  developments  that  happened  since  the  mid-term 
review,  in  particular  Brexit  and  the  COVID-19  pandemic.  This  asssessment  is 
particularly important as needs may have evolved and new needs may have emerged due 
to  these  events.  Moreover,  the  evaluation  examined  whether  the  programme  is 
aligned  with  the  problems  and  actions  identified  in  the  2020  Customs  Action  Plan 
“Taking  the  Customs  Union  to  the  next  level”103  which  proposes  a  revised  Customs 
Union strategy.  

During  the  final  evaluation  of  the  programme,  all  different  groups  of  stakeholders 
consulted  agreed  that  the  programme  continues  to  be  both  relevant  and  necessary 
and that stakeholders’ needs have remained largely unchanged since the mid-term 
evaluation.  The  Impact  Assessment  for  the  post-2020  customs  programme,  also 
confirmed these needs. Adding to this, the 2020 Customs Action Plan proposed a set 
of  actions  that  link  to  the  specific  and  operational  objectives  of  the  programme, 
therefore corroborating their continued relevance. The proposed actions, which align well 
to the objectives of the programme, were in the areas of risk management, management 
of e-commerce, promotion of compliance, and operational cooperation between customs 
authorities104. 

There  was  overall  consensus  among  stakeholders,  and  especially  among  customs 
authorities,  that  the  programme  was  relevant  to  addressing  the  needs  related  to  the 
problems mentioned above. The continued relevance of the programme was particularly 
highlighted  in  relation  to  the  need  to  harmonise  the  application  and  effective 
implementation  of  the Customs  Union  rules.  Customs  authorities,  but  also  economic 
operators, considered that Member States were increasingly “on the same page” and that 
this was due to a large extent to the programme’s activities. Networking and exchange of 
ideas were seen as important aspects of all programme activities, as well as the customs 
EIS  which  enable  the  exchange  of  information  required  by  EU  law,  and  ultimately  its 
practical implementation. 

In  particular,  according  to  customs  authorities,  the  guidance  documents  produced  in 
project groups, which clarify different aspects of the legislation and illustrate them with 
concrete examples, have played a major role in addressing the need to harmonise the 
application  of  customs  rules  by  Member  States.  Customs  authorities  also  considered 
that  the  formulation  and  definition  of  common  standards  has  been  critical  to  align  the 
different approaches that Member States have applied to date. 

103   Communication  from  the  Commission  to  the  European  Parliament,  the  Council  and  the  European 
Economic and Social Committee “Taking the Customs Union to the Next Level: A Plan for Action”, 
COM(2020) 581 final. 

104   In the Action Plan, this area is referred to as “customs authorities acting as one”. 

48 

 
                                                           
Moreover,  customs  authorities  confirmed  the  continued  need  for  the  programme  to 
support  Member  States  in  the  digitalisation  and  modernisation  of  customs 
procedures  such  as  updating  customs  IT  systems  and  adapting  them  to  new 
requirements, for which they need the support of the programme. Indeed, digitalisation is 
an ongoing process and therefore the programme’s focus on IT systems is still very much 
relevant and necessary.  

On the side of economic operators, customs rules and procedures are mainly associated 
with  administrative burdens, which need to  be minimised. At the same time, they need 
legal  certainty  to  be  maximised.  In  the  interviews,  economic  operators  in  general 
demanded even further simplification and harmonisation of customs legislation and 
processes,  confirming  that  this  is  a  continued  need.  Finally,  in  relation  to  the 
programme’s  management,  some  economic  operators  called  for  a  more  proactive 
engagement and communication with the business sector, as well as better provision 
of  information  to  business,  earlier  on  in  the  process.  In  line  with  this,  one  national 
administration  indicated  that  further  cooperation  with  the  business  sector  could  help  to 
align  new  technological  developments  (e.g.,  detection  technologies)  to  customs 
requirements.  It  is  worth  recalling  that  improving  the  engagement  with  economic 
operators was a recommendation of the mid-term evaluation, which will be addressed in 
the next funding period.   

The  evaluation  also  explored  whether  the  programme  was  sufficiently  flexible  to 
respond  to  new  and  evolving  needs  of  customs  authorities  and  economic  operators, 
stemming  from  unexpected  developments  such  as  Brexit  and  the  COVID-19  outbreak, 
and in the context of new policy initiatives such as the Customs Action Plan. 

In principle, the programme structure and the development of Work Programmes on an 
annual basis, provides flexibility for the programme to adapt to changing needs and tailor 
actions to national authorities’s demands. In addition, the wide range of activities which 
can be funded under the programme allows it to be flexible.  

Although Brexit added a layer of complexity to the programme, causing delays in some 
projects  and  absorbing  a  significant  amount  of  resources,  there  was  general  agreement 
across the different groups of stakeholders consulted that  Brexit did not seem to have 
affected  the  relevance  of  the  programme’s  objectives.  On  the  contrary,  the 
programme’s activities contributed to preparing the ground for the UK’s departure 
from  the  EU,  showing  its  flexibility  to  address  unforeseen  developments.  For 
instance, customs authorities consulted indicated that they were regularly updated by DG 
TAXUD  about  progress  on  Brexit  and  that  they  participated  in  various  meetings  and 
seminars105 on the matter, which helped them prepare for the changes, as well as prepare 
economic  operators  and  passengers  for  the  new  situation.  Adding  to  this,  the  annual 
progress  reports  indicated  that  under  the  objective  of  supporting  the  preparation, 

105   An example of this is the Technical expert seminar (EU27) on the impact of withdrawal of the United 
Kingdom  from  the  EU  on  Customs  IT  (CPG/054/047)  held  on  13  February  2019. This meeting  was 
addressed to experts regularly attending the Electronic Customs Coordination Group (ECCG). 

49 

 
                                                           
application and implementation of Union law, some of the 114 joint actions ongoing in 
2018  were  in  key  areas  such  as  Brexit.  Specific  training  support  was  also  provided  in 
2019  in  the  context  of  the  preparation  for  Brexit106  and  all  courses  and  materials  have 
been  adapted  and  updated  to  include  Brexit-related  considerations.  Also,  the  changes 
required  to  the  trans-European  systems  such  as  Export  Control  System  (ECS),  New 
Computerised Transit System (NCTS) and others,  were prepared and implemented in  a 
timely and coordinated manner and meeting the requirements of the political agreements, 
even  if  not  initially  planned  at  the  start  of  the  2020  programme.  Despite  this  positive 
assessment,  some  customs  authorities  indicated  that  further  support  from  the 
programme was still needed on this matter (e.g. more training activities), especially to 
harmonise  the  way  in  which  Member  States  deal  with  VAT-  and  classification-
related issues after Brexit.  

In  relation  to  the  COVID-19  pandemic,  customs  authorities  consulted  agreed  with  the 
assessment  of  the  Customs  Action  Plan  that  the  Commission’s  customs  services 
reacted  swiftly  to  the  crisis,  adopting  legislation,  issuing  guidelines  and  actively 
supporting  Member  States  and  businesses  to  ensure  flexibility  in  relation  to  customs 
obligations and customs clearance. Interviewed economic operators also recognised that 
the there was flexibility in the application of the customs legislation, as well as sufficient 
guidance from the Commission. 

In terms of the programme activities, primarily in April-May 2020 the pandemic caused 
interruptions  or  delays  in  some  joint  actions  (e.g.  suspension  of  working/monitoring 
visits, practical demonstrations, ‘hands on’ training sessions), as well as testing of new 
IT  systems.  However,  despite  these  initial  difficulties,  consulted  customs  authorities 
considered  that  the  programme  adapted  well  to  the  new  reality.  Most  interviewees 
expressed though that virtuality had nevertheless affected networking opportunities. 
In  addition,  some  customs  authorities  considered  the  programme’s  management 
systems,  in  particular  the  Programmes  Information  and  Collaboration  Space  (PICS) 
and ART, to be outdated and not adapted to the new reality of increased virtuality 
and  demanded  more  advanced  technical  support  from  the  programme,  for  instance  by 
providing  a  stable,  secure  and  user-friendly  platform  for  online  meetings,  exchange  of 
data and collaboration between customs authorities.  

On  their  side,  economic  operators  pointed  at  new  or  evolved  needs  that  were  not 
sufficiently  addressed  by  the  Commission  and  the  Member  States  via  the 
programme.  These  were  mainly  related  to  e-commerce,  which  some  considered  as  a 
key  priority  for  the  future  programme,  and  technological  innovation  for  customs 
processes  that  should  be  further  promoted.  This  innovation  was  considered  to  be 
necessary  not  only  in  relation  to  IT  systems  but  in  transitioning  to  digital  documents, 
such  as  invoices  and  certificates  of  origin.  Exploring  the  use  of  highly  sophisticated 
tools,  like  blockchain  technology,  for  customs  clearance  was  also  suggested.  Some 

106   Through  the  development  of  fast-track  upskilling  and  on-boarding  customs  training  programmes  for 

direct use by national authorities. 

50 

 
                                                           
economic operators considered that working together and learning from trade processes 
and  systems  could  be  beneficial  for  having  more  technologically  advanced  customs 
processes. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

The Customs programme has been in place for already 30 years now, evolving with the 
single market. The latest iteration, Customs 2020, was set up for the years 2014-2020 as 
a multiannual action programme to facilitate and enhance cooperation between customs 
administrations.  The  present  evaluation  assessed  the  programme  in  terms  of  the 
effectiveness and efficiency in achieving its objectives, its relevance to the needs of the 
customs  administrations,  economic  operators  and  the  Customs  Union  as  a  whole, 
coherence  with  other  initiatives  and  its  EU  added  value.  This  evaluation  has  been 
supported  by  an  external  study,  in  line  with  Article  18(1)  of  Regulation  (EU)  No 
1294/2013.  

Here are the key conclusions and lessons learnt stemming from this exercise.  

With the core objective of UCC being to achieve more simplicity and uniformity in the 
application  of  customs  rules  and  to  provide  a  fully  electronic  environment  for  the 
completion of customs formalities, the Customs 2020 programme has been especially 
important in relation to the development and functioning of customs EIS, providing 
for their financial sustainability and ensuring the availability and sharing of supply chain 
data and risk-relevant  information. This  represented  87% of the programme’s budget 
dedicated to IT capacity building. The remaining budget was dedicated to joint actions 
(11%) and human capacity building activities (2%). The three types of actions played 
a specific role and complemented each other in pursuing the programme’s objectives.  

The  Customs  2020  programme  fostered  exchange  of  customs  data  and  information 
through the customs EIS. They provided the means for an automated, solid and reliable 
exchange of data between national customs administrations, but also with economic 
operators  and other governmental authorities. The number and volume of messages 
exchanged  over  the  Common  Communication  Network/Common  Systems  Interface 
increased continuously since 2014, reaching nearly 8.4 billion and 42.1 terabytes in 2020 
(35.8 billion and 140.95 terabytes in total during the programme’s period). Only in 2020, 
around 11.2 million of transit movements were released through the NCTS, 14.74 million 
indirect  export  movements  were  recorded  in  the  ECS  and  more  than  50  million  entry 
summary  declarations  were  lodged  through  the  ICS.  The  implementation  of  the  EU 
Customs Trader Portal and the e-AEO, EBTI and INF trader portals were important 
contributions  of  the  programme  to  improving  information  exchanges  with  economic 
operators,  while  the  EU  CSW-CERTEX  was  particularly  relevant  to  enhance  the 
data exchange with non-customs authorities. The programme also provided a platform 
for exchanging knowledge and good practices between customs authorities and their 
officials through the joint actions. They contributed to promoting working relationships 
and  knowledge/experience  exchanges  that  continued  beyond  the  specific  programme 
activities. 

51 

 
Although the evaluation found only limited evidence on how the use of customs EIS has 
enhanced cooperation between customs authorities (beyond the information exchanges), 
the development of such systems, supported by both IT capacity building and joint 
actions  activities,  represents  in  itself  a  tangible  result  of  that  cooperation.  The 
evaluation especially highlighted the role of joint actions in enhancing cooperation. They 
brought together an increasing number of customs officials from participating countries 
to  cooperate  in  different  areas.  Amongst  joint  actions,  the  new  action  type  “expert 
teams”  provided  the  best  examples  of  enhancing  operational  cooperation  (i.e. 
CELBET, CLET and ETCIT).  A challenge identified in  relation  to  expert teams  was 
the difficulty to  find participating countries to  lead them, because of the  administrative 
burden it represents,  and the lack of clarity surrounding the specificities of this type of 
joint  action.  This  may  point  at  the  convenience  of  refining  the  “expert  team”  concept, 
based  on  the  experience  gained,  to  ensure  that  this  type  of  activity  is  exploited  in  the 
most effective way under the next programme period.  

Customs  2020  largely  supported  the  preparation,  effective  implementation  and 
more  coherent  application  of  Union  law  in  the  field  of  customs.  The  different 
programme  activities  served  different  purposes  and  complemented  each  other  in  this 
regard.  Several  joint  actions  supported  the  preparation  of  Union  law  (e.g.  the 
proposal for a Regulation on the EU Single Window Environment for Customs adopted 
by the College in October 2019), while IT capacity building activities mainly served to 
implement the UCC, putting in place and operating the necessary systems. However, the 
development  of  some  of  these  systems  suffered  delays  that  affected  the  timely 
implementation of the Code. This was addressed by postponing the legal deadline and 
putting  in  place  a  proper  monitoring  and  reporting  mechanism  for  the  future.  In  turn, 
training activities were key to support the coherent application of the new legislative 
framework, facilitating its understanding among both customs authorities and economic 
operators. Despite this support, there is still evidence of divergences in the application 
of Union law in areas that were the focus of the programme activities. This is the case of 
customs controls and in particular, the application of the financial risk framework, 
which could be further tackled under the next funding period.  

The  programme  had  a  positive  impact  on  the  functioning  and  modernisation  of  the 
Customs  Union  and  the  internal  market,  supporting  legitimate  trade  and 
preventing illegal activities. Although it was not possible to monetise these impacts, the 
digitalisation  of  customs  procedures  funded  by  the  programme  has  simplified  and 
harmonised  such  procedures  to  a  certain  extent,  reducing  compliance  costs  and 
increasing  legal  certainty  for  traders,  ultimately  strengthening  competitiveness  of 
European businesses. Nonetheless, digitalisation is still an ongoing process and many 
of  the  expected  benefits  have  not  yet  materialised.  Consulted  economic  operators 
raised  challenges  related  to  the  complexity  of  the  IT  environment,  the  staggered 
development  of  national  components  by  Member  States  and 
insufficient 
communication  thereof,  which  reveal  that  engagement  and  information  sharing  with 
economic operators could be improved.  On the prevention of illegal activities, specific 
EIS, such as the CRMS and the EU CSW-CERTEX, have contributed to this goal by 

the 

52 

 
facilitating  the  exchange  of  relevant  information  to  better  target  controls.  Expert 
teams  like  CELBET  and  CLET  were  also  an  effective  instrument  in  that  respect. 
Economic operators pointed at fraud related to e-commerce as an outstanding issue. 
The issue of e-commerce had already been raised by the European Parliament in a 2019 
study on the protection of EU financial interest.  

From  an  efficiency  perspective,  the  impossibility  to  monetise  the  benefits  of  the 
programme made it difficult to assess the value for money of its activities. Nonetheless, 
qualitative evidence collected through the interviews, a dedicated survey  as well as the 
information  provided by the PMF indicators allowed  the external  study  to draw certain 
conclusions.  Regarding  IT  capacity  building  activities,  the  analysis  focused  on  six 
customs  EIS,  five  of  which  were  considered  by  consulted  customs  authorities  as 
moderately cost-effective. The EIS benefits experienced by customs authorities relate to 
the  automation  of  processes,  resulting  in  more  efficient  and  simplified  customs 
procedures,  the  more  effective  implementation  and  harmonised  application  of 
customs  law  and  the  increased  interoperability  and  information  sharing  between 
authorities. The economies of scale and specific benefits linked to the development of 
these  systems  at  EU  level  reinforce  this  positive  picture.  When  considering  joint 
actions,  the  overall  opinion  was  that  their  cost  was  proportionate  to  the  generated 
benefits. Cost-efficiency of expert teams was particularly highlighted for their ability 
to  pull  resources  and  expertise,  rather  than  acting  individually.  Finally,  human 
competency  building  activities  are  considered  to  generate  a  high  value  for  money, 
especially regarding eLearning trainings that can be used repeatedly without incurring in 
additional costs. In line with this and implementing the recommendation of the mid-term 
evaluation to “refine the strategy for development and promotion of eLearning modules”, 
the  Commission  has  developed  an  EU-level  Learning  Management  System,  that  is 
expected to increase the value for money of training activities under the next iteration of 
the programme.  

While  the  results  of  the  mid-term  evaluation  on  internal  coherence  of  the  programme 
remain valid, the final evaluation focused on its  external coherence and found that the 
Customs  2020  programme  has  both  supported  other  EU  initiatives  and  benefited 
from  them.  This  is  particularly  the  case  of  other  policy  areas  that  impose  regulatory 
requirements  for  the  import  and  export  goods  in  order  to  protect  the  EU,  its  financial 
interests,  its  citizens  and  the  environment  or  of  other  spending  programmes,  such  as 
Fiscalis  2020,  the  Structural  Reform  Support  Programme  or  Hercule  III.  Several 
mechanisms were used to ensure this coherence, such as inter-DG meetings, interservice 
consultations,  mixed  project  and  expert  groups,  participation  of  observers  from  other 
Commission  DGs  in  project  group  meetings  or  activities  or  the  assessment  of  project 
proposals  by  officials  from  various  DGs.  Despite  the  observed  positive  outcomes,  the 
assessment pointed at room for further complementarities and synergies in certain areas. 
For  instance,  additional  synergies  could  be  explored  with  the  successor  of  Hercule  III 
programme on the development of data repositories or on joint data analysis, or with the 
Internal  Security  Fund  and  Instrument  for  Border  Management  and  visa,  on  seeking  a 
more joined-up and cross-sectoral approach at operational level. Cooperation with third 

53 

 
countries  on  the  fulfilment  of  EU  and  international  environmental  goals  was  also 
highlighted as potential area for enhancing coherence. Finally, the evaluation suggested 
additional  ways  to  improve  coherence,  such  as  further  structuring  or  formalising 
cooperation between involved Commission DGs, raising the visibility of the programme 
and  its  complementarity  with  other  EU  funds  in  the  Member  States  or  exploring  IT 
synergies with other EU programmes that run significant electronic systems.   

The  evaluation  findings  confirmed  the  added  value  of  the  programme,  which 
constitutes a cooperation instrument to ensure the proper functioning and modernisation 
of  the  Customs  Union  and  its  harmonised  implementation.  In  this  regard,  the 
programme’s  role  in  the  development,  maintenance  and  operation  of  the  customs  EIS 
has  particularly  contributed  to  the  simplification  and  harmonisations  of  customs 
processes  and  procedures  at  EU  level.  The  upgraded  paperless  environment  has 
significantly increased efficiency and effectiveness. It has led to economies of scale and 
a  degree  of  integration  that  would  not  have  been  possible  if  each  Member  State  had 
developed  similar  IT  systems  on  its  own.  Similar  conclusions  can  be  drawn  on  joint 
actions  and  human  competency  building  activities.  By  regrouping  the  expertise  of 
participating  countries  in  joint  actions,  the  programme  provided  the  opportunity  for 
Member States,  especially the smaller ones, to  access a wider pool of knowledge and 
experts  than  at  individual  level.  Joint  actions  provided  a  vehicle  to  exchange  best 
practises and knowledge and to find common solutions, resulting in a more uniform 
application  of  EU  law,  which  would  have  been  more  difficult  in  their  absence. 
eLearning  modules  accessible  to  a  wide  range  of  customs  officials  and  economic 
operators  also  demonstrate  an  added  value,  contributing  to  a  better  and  uniform 
understanding of the new legislative framework and related EIS that would not have 
been possible through national action.  

Based  on  these  programme  contributions,  participating  countries  do  not  consider 
discontinuing  the  programme  as  a  plausible  option.  That  would  entail  stopping  the 
operation of the common  IT infrastructure and components, which are the backbone of 
customs procedures, therefore causing a major disruption of EU international trade. More 
generally, discontinuing the programme would likely result in increased burden and cost 
on  Member  States.  In  such  a  scenario,  harmonisation  in  the  application  of  Union  law 
would be challenging, and potential divergences would result in an uneven playing field 
and  distorted  competition  in  the  internal  market,  impacting  negatively  on  economic 
operators, for whom compliance would be more burdensome. 

Underpinning  the  conclusions  of  the  mid-term  evaluation,  the  final  evaluation 
corroborated  the  continued  relevance  of  the  Customs  programme,  especially  in 
relation  to  the  needs  of  national  customs  administrations,  who  are  its  main 
beneficiaries.  Overall,  the  programme  continues  to  respond  to  stakeholders’  needs, 
adapting  well  to  unforeseen  events  (such  as  COVID-19  and  Brexit)  and  addressing 
problems  and  priorities  identified  in  the  impact  assessment  of  the  next  customs 
programme  and  in  the  2020  Customs  Action  Plan.  There  was  consensus  on  the 
continued relevance of the programme particularly in relation to the need to harmonise 
the application and effective implementation of the Customs Union rules. Moreover, 

54 

 
customs administrations confirmed the continued need for the programme to support the 
ongoing  digitalisation  and  modernisation  of  customs  procedures.  Economic 
operators,  in  general,  advocated  further  simplification  and  harmonisation  of 
customs  legislation  and  processes  and  some  of  them  called  for  a  more  proactive 
engagement  and  communication  with  the  business  sector,  coinciding  with  the 
recommendation  of  the  mid-term  evaluation  on  improving  the  engagement  with 
economic operators that the next programme intends to address.  

The programme proved to be sufficiently flexible in view of new or changing needs. 
The  programme  activities  satisfactorily  contributed  to  prepare  stakeholders  for  Brexit. 
However, customs authorities still pointed to additional training needs in this matter. In 
terms of the COVID-19 pandemic, there were some initial challenges in adapting to the 
new  reality  but  overall,  the  programme  did  it  well  and  continued  to  respond  to 
stakeholders’  needs.  Nevertheless,  there  is  a  general  perception  of  decreased 
networking opportunities, which are considered as a key element of the programme and 
a  consequent  demand  from  customs  administrations  of  continued  support  of  the 
programme in the new reality through better adapted means and channels that can 
ensure networking even through virtual means.  Finally,  economic operators pointed at 
the  management  of  e-commerce  and  the  technological  innovation  for  customs 
processes, as two evolved needs, thus confirming its continued relevance.   

The evaluation considered that the Customs Programme is still a relevant support tool at 
EU  level  to  strengthen  cooperation  and  coordination  between  countries  in  support  of  a 
well-functioning and modern Customs Union. This is especially important in a world that 
is  fast  changing  in  terms  of  trade  (e-commerce)  and  technology,  posing  challenges  to 
custom systems and administrations. In this context, the programme remains relevant to 
fund the development, implementation and operation of IT infrastructure and systems in 
the  field  as  they  are  resource  intensive  and  can  benefit  from  economies  of  scale  and 
scope. It also is important to ensure regular cooperation and mutual learning, improving 
the  capacity  of  customs  authorities.  As  such,  the  programme  would  continue  to  be 
relevant in support of effective implementation and coherent application of Union law in 
the field of customs as a result of the UCC reform planned for 2022. 

55 

 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

1.  Lead DG, Decide reference 

The final evaluation is a non-major initiative (PLAN/2020/8197) organised in accordance 
with article 18(1)(3) of Regulation (EU) No 1294/2013 of 11th of December 2013 setting 
up Customs 2020 as a multiannual action programme for customs in the EU, to facilitate 
and enhance cooperation between national administrations.  

The lead Directorate General for the evaluation was the Directorate General for Taxation 
and Customs Union (DG TAXUD).  

2.  Organisation and timing 

The  Commission  carried  out  the  present  evaluation  with  the  help  of  an  external 
consultant. The evaluation study  was commissioned to  a consortium led by Economisti 
Associati Srl107. The specific contract was signed on the 14th of October 2020 for a period 
of 12 months.  

The  evaluation  was  supported  by  an  inter-service  group  (ISG)  with  the  following 
Commission’s services who expressed their wish to participate in the group:  

DG Budget (BUDG) 

DG Economic and Financial Affairs (ECFIN) 

DG Environment (ENV) 

DG Health and Food Safety (SANTE)  

DG Migration and Home Affairs (HOME)  

DG Informatics (DIGIT) 

DG Justice and Consumers (JUST) 

DG Secretariat General (SG) 

DG Structural Reform Support Service (REFORM) 

DG Trade (TRADE) 

European Anti-Fraud Office (OLAF) 

The  ISG  met  four  times  on  17th  of June  2020,  12th  of  November  2020,  15th  of January 
2021 and 9th of July 2021. In the last meeting the external consultant presented the draft 

107   Framework Contract TAXUD/2019/CC/150; 

56 

 
 
                                                           
introducing 

Final  Report 
the  conclusions  and 
recommendations. These were discussed with the group, which confirmed their validity 
and credibility.   

the  findings  of 

the  evaluation, 

3.  Evidence, sources and quality 

The present evaluation SWD is based on the works carried out by the external consultant. 
The material informing this evaluation consisted of (1) programming documentation, (2) 
the  Performance  Measurement  Framework  (PMF),  (3)  previous  studies,  reports  and 
evaluations  and  (4)  other  DG’s  IT  systems,  as  detailed  in  Table  11,  which  presents  as 
well  the  intended  purpose  of  use.  The  evaluation  gathered  also  primary  data  on  the 
programme’s implementation, functioning, results and use directly from the best-placed 
stakeholders:  EU  representatives,  the  customs  administrations  from  Member  States, 
candidate  and  potential  candidate  countries  and,  to  a  smaller  extent,  from  economic 
operators.  That  evidence  was  collected  through  in-depth  interviews,  a  benchmarking 
exercise, and a series of five thematic cases studies, which are described in more detail in 
Annex II.  

The  details  of  the  stakeholder  consultation  strategy  containing  stakeholders  mapping, 
engagement methods and feedback can be found in Annex V. 

Table 11. Sources of information used for final evaluation of Customs 2020 programme 

References 

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f

E

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a
r
e
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e
G

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e
i
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i
f
f

E

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c
n
a
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e
R

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c
n
e
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e
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o
C

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u
l
a
v
d
e
d
d
a
U
E

Customs 2020 Regulation:  

  Regulation (EU) No 1294/2013 of the European Parliament 
and of the Council of 11 December 2013 establishing an 
action programme for customs in the European Union for the 
period 2014-2020 (Customs 2020) 

X 

X 

X 

X 

57 

 
 
 
 
 
 
 
 
 
 
 
 
Previous programmes: 

  Decision No 624/2007/EC of the European Parliament and of 

the Council of 23 May 2007 establishing an action 
programme for customs in the Community (Customs 2013) 

  Decision No 253/2003/EC of the European Parliament and of 

the Council of 11 February 2003 adopting an action 
programme for Customs in the Community (Customs 2007) 

  Decision No 105/2000/EC of the European Parliament and of 
the Council of 17 December 1999 amending Decision No 
210/97/EC adopting an action programme for customs in the 
Community (Customs 2000) and repealing Council Decision 
91/341/EEC 

X 

  Decision No 210/97/EC of the European Parliament and of 
the Council of 19 December 1996 adopting an action 
programme for customs in the Community (Customs 2000) 

 

91/341/EEC: Council Decision of 20 June 1991 on the 
adoption of a programme of Community action on the subject 
of the vocational training of customs officials (Matthaeus 
programme) 

Future programme: 

  Regulation (EU) 2021/444 of the European Parliament and of 
the Council of 11 March 2021 establishing the Customs 
programme for cooperation in the field of customs and 
repealing Regulation (EU) No 1294/2013 

Other DG TAXUD programmes: 

  Regulation (EU) 2021/1077 of the European Parliament and 
of the Council of 24 June 2021 establishing, as part of the 
Integrated Border Management Fund, the instrument for 
financial support for customs control equipment 

e-customs and UCC: 

  Report from the Commission to the European Parliament and 
the Council pursuant to Article 278a of the Union Customs 
Code, on progress in developing the electronic systems 
provided for under the Code 

  Regulation (EU) No 2019/632 of the European Parliament 

and of the Council of 17 April 2019 amending Regulation 
(EU) No 952/2013 to prolong the transitional use of means 
other than the electronic data-processing techniques 
provided for in the Union Customs Code 

  Commission Implementing Decision (EU) 2016/578 of 11 

April 2016 establishing the Work Programme relating to the 
development and deployment of the electronic systems 
provided for in the Union Customs Code 

  Regulation (EU) No 952/2013 of the European Parliament 

and of the Council of 9 October 2013 laying down the Union 
Customs Code (recast) 

  Decision No 70/2008/EC of the European Parliament and of 
the Council of 15 January 2008 on a paperless environment 
for customs and trade 

  Proposal for a Regulation of the European Parliament and of 
the Council amending Council Regulation (EEC) No 2913/92 
establishing the Community Customs Code 

58 

X 

X 

X 

X 

X 

X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Union law in matters related to customs: 

  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 

  Council Directive (EU) 2018/2057 of 20 December 2018 

amending Directive 2006/112/EC on the common system of 
value added tax as regards the temporary application of a 
generalised reverse charge mechanism in relation to supplies 
of goods and services above a certain threshold 

  Regulation (EU) 2017/625 of the European Parliament and of 
the Council of 15 March 2017 on official controls and other 
official activities performed to ensure the application of food 
and feed law, rules on animal health and welfare, plant health 
and plant protection products, amending Regulations (EC) 
No 999/2001, (EC) No 396/2005, (EC) No 1069/2009, (EC) 
No 1107/2009, (EU) No 1151/2012, (EU) No 652/2014, (EU) 
2016/429 and (EU) 2016/2031 of the European Parliament 
and of the Council, Council Regulations (EC) No 1/2005 and 
(EC) No 1099/2009 and Council Directives 98/58/EC, 
1999/74/EC, 2007/43/EC, 2008/119/EC and 2008/120/EC, 
and repealing Regulations (EC) No 854/2004 and (EC) No 
882/2004 of the European Parliament and of the Council, 
Council Directives 89/608/EEC, 89/662/EEC, 90/425/EEC, 
91/496/EEC, 96/23/EC, 96/93/EC and 97/78/EC and Council 
Decision 92/438/EEC (Official Controls Regulation) 

  Regulation (EU) 2016/2031 of the European Parliament of 
the Council of 26 October 2016 on protective measures 
against pests of plants, amending Regulations (EU) No 
228/2013, (EU) No 652/2014 and (EU) No 1143/2014 of the 
European Parliament and of the Council and repealing 
Council Directives 69/464/EEC, 74/647/EEC, 93/85/EEC, 
98/57/EC, 2000/29/EC, 2006/91/EC and 2007/33/EC 

  Commission Implementing Regulation (EU) 2016/1842 of 14 

October 2016 amending Regulation (EC) No 1235/2008 as 
regards the electronic certificate of inspection for imported 
organic products and certain other elements, and Regulation 
(EC) No 889/2008 as regards the requirements for preserved 
or processed organic products and the transmission of 
information 

  Regulation (EU) 2016/429 of the European Parliament and of 

the Council of 9 March 2016 on transmissible animal 
diseases and amending and repealing certain acts in the 
area of animal health (‘Animal Health Law’) 

  Regulation (EU) No 517/2014 of the European Parliament 

and of the Council of 16 April 2014 on fluorinated 
greenhouse gases and repealing Regulation (EC) 
No 842/2006 

  Regulation (EU) No 995/2010 of the European Parliament 
and of the Council of 20 October 2010 laying down the 
obligations of operators who place timber and timber 
products on the market 

  Commission Regulation (EC) No 1235/2008 of 8 December 
2008 laying down detailed rules for implementation of 
Council Regulation (EC) No 834/2007 as regards the 
arrangements for imports of organic products from third 
countries 

  Council Regulation (EC) No 2173/2005 of 20 December 2005 

on the establishment of a FLEGT licensing scheme for 
imports of timber into the European Community 

  Council Regulation (EC) No 1/2005 of 22 December 2004 on 

the protection of animals during transport and related 
operations and amending Directives 64/432/EEC and 
93/119/EC and Regulation (EC) No 1255/97 

  Regulation (EC) No 178/2002 of the European Parliament 
and of the Council of 28 January 2002 laying down the 
general principles and requirements of food law, establishing 
the European Food Safety Authority and laying down 
procedures in matters of food safety 

59 

  Regulation No 515/97 of 13 March 1997 on mutual 

assistance between the administrative authorities of the 
Member States and cooperation between the latter and the 
Commission to ensure the correct application of the law on 
customs and agricultural matters 

X 

X 

X 

 
 
 
 
Other legal acts: 

  European Commission, Legal bases and technical 

adjustments, available at: 
https://ec.europa.eu/info/publications/legal-bases-and-
technical-adjustments_en 

  Proposal for a regulation of the European Parliament and of 
the Council establishing the EU Anti-Fraud Programme. 
COM/2018/386 final 

  Regulation (EU) No 250/2014 of the European Parliament 
and of the Council of 26 February 2014 establishing a 
programme to promote activities in the field of the protection 
of the financial interests of the European Union (Hercule III 
programme) 

  Proposal for a regulation of the European Parliament and of 

the Council establishing the programme for single market, 
competitiveness of enterprises, including small and medium-
sized enterprises, and European statistics. COM (2018) 441 
final 

  Proposal for a regulation of the European Parliament and of 
the Council establishing the Internal Security Fund, COM 
(2018) 472 final 

  Proposal for a regulation of the European Parliament and of 

the Council establishing the Digital Europe programme for 
the period 2021-2027, COM/2018/434 final   

  European Commission, Report from the Commission to the 
European Parliament and the Council, Protection of the 
European Union’s financial interests — Fight against fraud 
2014/2015/2016/2017/2018/2019, Annual Reports 

  OLAF, 2019, Fighting fraud: 31st Annual Report on the 

Protection of the EU's financial interests 

  Commission Staff working Document SWD (2020) 160 final, 
Statistical evaluation of irregularities reported for 2019: own 
resources, agriculture, cohesion and fisheries policies, pre-
accession and direct expenditure 

  European Parliament, 2019, Protection of EU financial 

interest on customs and VAT: Cooperation of national tax 
and customs authorities to prevent fraud 

  European Court of Auditors, 2019, E-commerce still 

vulnerable to VAT and customs duty evasion, say EU 
Auditors 

Strategic documents: 

  Communication from the Commission to the Council, the 
European Parliament and the Economic and Social 
Committee of 8 February 2001 concerning a strategy for the 
Customs Union 

  Communication from the Commission to the Council, the 
European Parliament and the Economic and Social 
Committee – A simple and paperless environment for 
Customs and Trade 

  Communication from the Commission to the Council, the 
European Parliament and the Economic and Social 
Committee on the role of customs in the integrated 
management of external borders 

  Communication from the Commission to the Council, the 
European Parliament and the Economic and Social 

60 

X 

X 

X 

X 

X 

 
 
 
 
 
 
 
 
Committee – Strategy for the evolution of the Customs Union 

  Communication from the Commission to the European 

Parliament, the Council and the European Economic and 
Social Committee – Taking the Customs Union to the Next 
Level: A Plan for Action 

Other programming documentation: 

  Annual work programmes (Annex I to the Commission 

implementing decision – Budget line 140201: Customs 2020 
Work Programme for 2017/2018/2019/ 2020) 

  Multi-Annual Strategic Plan for Customs (including annexes 

and different revisions)  

  Documents detailing internal procedures associated with the 
Customs 2020 programme, including those shared on PICS 

Performance Measurement Framework: 

  Commission staff working document: Customs 2020 

Programme – Progress Report 2014/2015/2016/2017/2018, 
and Draft Customs 2020 Programme Progress Report 2019 

  Raw data collected through the Action Follow-up Forms and 

the ART 

  PMF management and design documentation Monitoring of 

human competency building activities 

Previous programme evaluations: 

  Report from the Commission to the European Parliament and 
the Council on the mid-term evaluation of the Customs 2020 
programme, 2019 

  Mid-term evaluation of the Customs 2020 programme, final 

report, 2018 

  Report from the Commission to the European Parliament, the 

Council, the European Economic and Social Committee and 
the Committee of the Regions – Final evaluation of the 
Customs 2013 programme, 2015 

 

Final evaluation of the Customs 2013 programme, Final 
report, 2014; Customs 2013 Final evaluation results 

  European Commission, Mid-term evaluation of the Customs 

2013 programme, Final report 

  Commission staff working paper – Impact Assessment 

Accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing an 
action programme for customs and taxation in the European 
Union for the period 2014-2020 (FISCUS) and repealing 
Decisions N°1482/2007/EC and N°624/2007/EC 

  Commission staff working document – Impact Assessment 
Accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the 
‘Customs’ programme for cooperation in the field of customs  

  Study contributing to an Impact Assessment concerning a 

possible legislative proposal for an EU action programme for 
Customs for the period post-2020, Final report, 2018 

  European Court of Auditor (2018), Special report no 26/2018: 
A series of delays in Customs IT systems: what went wrong? 

61 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 
 
 
 
 
 
  Study on Performance Measurement Framework (Oct 2020) 

  Evaluation of the electronic customs implementation in the 

EU 

  Study on Performance Measurement Framework (Oct 2020) 

  Evaluation of the electronic customs implementation in the 

EU 

  European Commission (2015), Evaluation of the electronic 

customs implementation in the EU, Final report 

Other DGs’ IT systems 

  World Horse Welfare comments to the consultation 
amending Regulation (EU) No 2019/1715 (2021) 

  Commission Implementing Regulation (EU) 2019/1715 of 30 
September 2019 laying down rules for the functioning of the 
information management system for official controls and its 
system components (the IMSOC Regulation) 

  Directive (EU) 2019/884 of the European Parliament and of 
the Council of 17 April 2019 amending Council Framework 
Decision 2009/315/JHA, as regards the exchange of 
information on third-country nationals and as regards the 
European Criminal Records Information System (ECRIS), 
and replacing Council Decision 2009/316/JHA 

  Regulation (EU) 2019/816 of the European Parliament and of 

the Council of 17 April 2019 establishing a centralised 
system for the identification of Member States holding 
conviction information on third-country nationals and 
stateless persons (ECRIS-TCN) to supplement the European 
Criminal Records Information System and amending 
Regulation (EU) 2018/1726 

  Regulation (EU) 2018/1726 of the European Parliament and 
of the Council of 14 November 2018 on the European Union 
Agency for the Operational Management of Large-Scale IT 
Systems in the Area of Freedom, Security and Justice (eu-
LISA), and amending Regulation (EC) No 1987/2006 and 
Council Decision 2007/533/JHA and repealing Regulation 
(EU) No 1077/2011 

  Regulation (EU) 2018/1862 of the European Parliament and 

of the Council of 28 November 2018 on the establishment, 
operation and use of the Schengen Information System (SIS) 
in the field of police cooperation and judicial cooperation in 
criminal matters, amending and repealing Council Decision 
2007/533/JHA, and repealing Regulation (EC) No 1986/2006 
of the European Parliament and of the Council and 
Commission Decision 2010/261/EU 

  Regulation (EU) 2018/1861 of the European Parliament and 

of the Council of 28 November 2018 on the establishment, 
operation and use of the Schengen Information System (SIS) 
in the field of border checks, and amending the Convention 
implementing the Schengen Agreement, and amending and 
repealing Regulation (EC) No 1987/2006 

  Regulation (EU) 2018/1860 of the European Parliament and 
of the Council of 28 November 2018 on the use of the 
Schengen Information System for the return of illegally 
staying third-country nationals / Proposal for a Regulation of 
the European Parliament and of the Council on the use of the 
Schengen Information System for the return of illegally 
staying third-country nationals), COM/2016/0881 

62 

X 

X 

 

 
 
 
  
  Report from the European Union and the Council on the state 

of play of preparations for the full implementation of the new 
legal bases for the Schengen Information System (SIS) in 
accordance with Article 66(4) of Regulation (EU) 2018/1861 
and Article 79(4) of Regulation (EU) 2018/1862 

  Wavestone, Feasibility study and cost assessment of the 
establishment of a centralised ECRIS TCN solution, June 
2017 

  Proposal for a Regulation of the European Parliament and of 
the Council on the use of the Schengen Information System 
for the return of illegally staying third-country nationals 

  Report from the European Union and the Council on the 

evaluation of the second-generation Schengen Information 
System (SIS II) in accordance with art. 24 (5), 43 (3) and 50 
(5) of Regulation (EC) No 1987/2006 and art. 59 (3) and 66 
(5) of Decision 2007/533/JHAl 

 

Feasibility study on the inclusion of pseudonymised 
fingerprints in ECRIS TCN exchanges, June 2016 

  Report from the European Union and the Council on the 

implementation of Council Framework Decision 
2009/315/JHA of 26 February 2009 on the organisation and 
content of the exchange of information extracted from 
criminal record between Member States 

  Council Framework Decision 2009/315/JHA of 26 February 
2009 on the organisation and content of the exchange of 
information extracted from the criminal record between 
Member States 

 

Impact Assessment Accompanying the proposal for a 
Directive of the European Parliament and of the Council 
amending Council Framework Decision 2009/315/JHA, as 
regards the exchange of information on third country 
nationals and as regards the European Criminal Records 
Information System (ECRIS) and replacing Council Decision 
2009/316/JHA 

Additional Sources 

  Presentation of the European Commission at the 69th 
Electronic Customs Coordination Group (ECCG) 

  World Customs Organisation, Annual reports 2014-2015, 

2015-2016, 2016-2017, 2018-2019 

  European Court of Auditors, Special Report No 26 – A series 
of delays in Customs IT systems: what went wrong? (2018). 

  European Commission, 96th Customs Code Committee 

General Customs Legislation section joint with 57th ECCG, 
18th CEG-DIH AND TCG – Adopted Meeting minutes 
(Ares(2020)1469163, 10.3.2020). 

Source: ‘Study on the final evaluation of the Customs 2020 programme’  

63 

X 

X 

X 

 

 
  
 
 
 
 
 
  
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

Approach and method 

The  evaluation  followed  a  two-pronged  approach  that  allowed  to  examine  the 
programme from different angles and levels of detail, as well as engaging with different 
groups  of  stakeholders.  The  figure  9  below  depicts  the  methodology  used  for  this 
evaluation.  

Figure 9: Overview of the methodology of the final evaluation of Customs 2020 programme 

Tasks 

Data collection method 

Description 

1. Desk review 

Programme 
level 
assessment 

2. In-depth interviews (43) 

3. Benchmarking exercise 

Contribution 
analysis 

4. Case studies 

Legal acts 
Strategic and programming documents 
Management documentation 
Performance Measurement Framework (PMF) 
Previous evaluations, impact assessments and other 

studies 

DG TAXUD officials (12) 
Officials from DG CLIMA, OLAF and DG REFORM (4)  
National authorities (17) 
Economic operators (10) 

Desk review 
In-depth interviews with officials from DG JUST and 

DG SANTE (3) involved in three selected IT systems 
(SIS, ECRIS, TRACES) 

Desk review 
In-depth interviews with: 

DG TAXUD (17) 
National customs officials (47) 
Economic operators (12) 
 Other DGs (4) 

Costs and benefits survey of national customs authorities 

(36 responses) 

Source: ‘Study on the final evaluation of the Customs 2020 programme’ 

No public consultation was carried out as the programme only targets specific audience 
within the customs administrations and is only known to these who are expected to use it. 
The broader public is only very indirectly affected by the programme’s results and these 
will  not  be  directly  felt  by  a  non-specialised  audience.  The  previous  experience  with 
public consultation at the time of the mid-term evaluation of the programme did not yield 
much  usable  information.  The  public  may  have  an  opinion  on  the  broader  policies 
supported by the Customs 2020 programme but collecting these will not contribute to the 
assessment of the programme’s performance.   

The  programme  assessment  served  to  collect  and  analyse  data  on  the  Customs  2020 
programme  as  a  whole.  It  focused  on  what  the  programme  was  doing  in  terms  of 
implementation and performance towards objectives. This assessment was comprised of 
three main methods as shown:  

64 

 
  Desk research: The purpose of the desk research was to  collect  information on 
the  programme’s  design,  implementation  and  performance  to  answer  the 
evaluation  questions.  The information  was collected from  multiple sources such 
as programming documents, the PMF, the ART and previous studies, reports and 
evaluations. 

  In-depth  interviews:  In  total  45  in-depth  interviews  were  conducted  to  collect 
the  views  and  opinions  of  stakeholders  directly  or  indirectly  involved  in  the 
programme. More specifically, interviews were organised with 20 representatives 
from  DG  TAXUD  and  other  6  Directorates  General  (DGs),  customs  authorities 
from  14  EU  Member  States  and  6  candidate  and  potential  candidate  countries, 
and 10 economic operators. 

  Benchmarking exercise: A benchmarking exercise was conducted with the aim 
to provide suggestions and guidelines for the management of the EIS for customs. 
For  this  exercise,  three  EU  IT  systems  that  are  comparable  in  scale  and 
complexity with those funded under the Customs 2020 programme were selected, 
namely:  
o 
o 
o 

the Schengen Information System (SIS) – DG HOME 
the European Exchange of Criminal Records system (ECRIS) – DG JUST 
the Trade Control and Expert System (TRACES) – DG SANTE 

The benchmarking exercise included both a desk review and in-depth interviews 
with IT officials. The objective was to identify the: i) challenges and constraints 
faced  by  the  initiatives  when  implementing  and  operating  the  systems;  ii)  the 
strategies  and  resources  employed;  iii)  the  key  outcomes  of  the  IT  systems;  iv) 
best practices that could be useful for the EIS for customs. 

that  complemented 

The  contribution  analysis 
the  programme-level  assessment 
contained  the  development  of  five  thematic  case  studies.  The  case  studies  aimed  to 
examine  how  a  set  of  Customs  2020  activities  contributed  to  progress  towards  the 
objectives  of  the  programme.  The  themes  of  the  case  studies  were:  i)  customs  risk 
management;  ii)  classification  of  goods;  iii)  customs  decisions  through  the  lens  of 
imports;  iv) economic operator management and the EU Customs Trader Portal; v) the 
EU Single Window environment for customs. These themes were selected based on the 
IT capacity building activities to allow for insightful analysis of the EIS for customs in 
the  context  of  the  objectives  they  serve  and  in  conjunction  with  other  Customs  2020 
activities.  The  case  studies  therefore  looked  at  the  Commission’s  committed  budget  to 
select  those  EIS  for  customs  that  were  particularly  significant  in  terms  of  resource 
allocation. 

The methodology used for the cases studies involved the following elements: 

  Sampling of activities and of participating countries: As a first step, based on 
the  agreed  set  of  case  study  themes,  preparatory  work  included  the  selection  of 
relevant  joint  actions  and  human  competency  building  activities  for  each  case 

65 

 
study  topic.  The  second  step  was  to  sample  the  participating  countries.  The 
elements that were taken into consideration for the sampling of the participating 
countries  included:  i)  the  usage  of  the  EIS  for  customs  and  any  national 
specificities: ii) the geographical coverage of all the consultation activities of the 
study  to  give  the  opportunity  to  all  the  Member  States  to  contribute  to  the 
evaluation.   

  Desk research: As part of each case study, the available documentation, data on 
the IT capacity activities, joint actions, and human competency building activities 
sample was collected.  

  Case  study  interviews:  In  total  74  in-depth  interviews  with  stakeholders  were 
conducted  to  fill  in  the  data  gaps  and  to  complete  the  evidence  base  for  the 
different case studies.  

  Online survey on costs and benefits of selected EIS: Each case study included 
a  cost-benefit  assessment  of  the  main  EIS  for  customs.  For  this,  the  costs 
associated to the Customs 2020 programme, as well as costs for national customs 
authorities  and  economic  operators  (to  the  extent  possible)  were  taken  into 
consideration.  As  regards  the  data  on  the  costs  associated  with  the  IT  capacity 
building  activities  linked  to  EIS  for  customs  and  on  their  benefits,  these  were 
collected  through  a  survey  targeting  national  authorities.  The  survey  allowed  to 
collect information on the costs of implementing the EIS for customs at national 
level,  namely  those  that  the  Customs  2020  programme  did  not  cover,  and  the 
benefits  associated  with  both  Union  and  national  components  of  the  EIS  for 
customs.  The  survey  was  open  on  ALCHEMER®  from  10  to  31  May  2021.  In 
total  36  responses  were  received  from  18  Member  States,  out  of  which  31 
responses  were  received  through  the  online  tool  and  5  responses  were  sent  in 
writing via email.  

For each of the EIS covered in the case studies, the following cost categories were 
examined: 

o  Infrastructure costs: required to develop, support, operate and maintain 

the system: 

  hardware  costs: 

total  (anticipated)  costs  of 
(network, server, storage) for running the systems. 

the  hardware 

  software  costs:  total  (anticipated)  costs  of  applications,  licenses, 

libraries required to operate the systems. 

o  Development  costs:  analysis and process  re-engineering,  coding, project 
management, test, configuration and change management, deployment. 
o  Maintenance  costs:  including  additional  activities  related  to  both 
corrective and evolving maintenance (in person days per year to maintain 
the system). 

o  Support costs: helpdesk, operations to support the system, its users, and 

end-users. 

o  Training costs: to train the systems’ users. 

66 

 
 
 
ANNEX  III.  EVALUATION  MATRIX  AND,  WHERE  RELEVANT,  DETAILS  ON  ANSWERS  TO 
THE EVALUATION QUESTIONS (BY CRITERION) 

This  annex  presents  the  evaluation  questions  matrix  used  for  the  study  on  the  final 
evaluation of the Customs 2020 programme. 

Effectiveness 

Sub-question 

Judgement 
criteria 

Indicators 

Information source and tools 

EQ1: To what extent has the Customs 2020 programme contributed to facilitating and enhancing 
cooperation and exchange of information between customs authorities and their officials within the 
European Union? 
1.1. To what 
extent has the 
programme 
contributed to 
facilitating and 
enhancing the 
exchange of 
information 
between 
customs 
authorities and 
their officials? 

(Change in) number of 
programme-funded IT 
systems allowing automatic 
information sharing 
Reliability of the common 
infrastructure (CCN/CCN2) 
Use of key systems aimed at 
increasing interconnectivity 
and exchanging information 

Desk review of the MASP-C and its 
annex (IT project fiches) 
Case study interviews with national 
customs officials 

(Change in) number of 
participants and countries 
represented in programme-
funded activities 

Desk review of ART data and 
Annual progress reports 

The 
programme 
played a role in 
bringing about 
the 
improvements 
in capacity that 
enabled greater 
electronic 
information 
sharing 
between 
customs 
authorities. 
Customs 
authorities’ 
participation 
rate in 
programme 
activities 
increased 
There was an 
observable 
increase in 
instances of 
customs 
authorities 
working 
together to 
tackle common 
challenges. 

1.2. To what 
extent has the 
programme 
contributed to 
facilitating and 
enhancing 
cooperation 
between 
customs 
authorities and 
their officials 
within the EU? 

Evidence of customs 
authorities collaborating to 
tackle common challenges 
through formal means, such 
as joint actions 
Views of customs authorities 
regarding the programme’s 
contribution to increasing 
their capacity to collaborate in 
tackling common challenges 

Joint actions analysed for the 
thematic case studies based on PICS 
groups, feedback gathered through 
the EEF and AAF and interviews 
(regarding specific instances of 
programme support leading to 
increased capacity) – contribution 
analysis 
Programme assessment interviews 
(regarding the extent to which 
customs authorities consider the 
programme more widely has 
increased their capacity to 
collaborate in tackling common 
challenges) 
Programme assessment interviews 
with national customs officials 
Case study interviews with national 
customs officials 
Desk review of PMF raw data and 
Annual progress reports, of 
documents linked to the joint actions 
analysed as part of the thematic case 
studies and of those shared on PICS 
Programme assessment interviews 

The 
programme 
played a role in 
bringing about 
the increase in 
instances of 

Documentary evidence of 
customs authorities formally 
working together, through 
formally established joint 
actions or other official 
channels, such as PICS 

67 

 
with national customs officials 
Case study interviews with national 
customs officials 

customs 
authorities 
working 
together 

Degree of networking 
generated through the 
programme 
Anecdotal evidence of 
cooperation and information 
sharing through personal links 
between customs officials 
Anecdotal evidence from 
customs officials regarding 
informal collaboration (for 
example picking up the phone 
to speak to a contact in 
another Member State as a 
connection made through a 
programme-funded activity) 
Anecdotal evidence from 
customs officials regarding 
informal cooperation in ‘real 
world’ situations (namely 
outside of programme 
actions) 

EQ2: To what extent has the Customs 2020 programme supported the preparation, coherent 
application, and effective implementation of Union law in the field of customs and related matters? 

2.1. To what 
extent did the 
programme 
support the 
preparation of 
Union law in 
the field of 
customs and 
related 
matters?108 

The 
programme 
supported the 
preparation of 
Union law in 
the field of 
customs and 
related matters 

Number of programme 
outputs contributing to the 
legislative process 
Extent and quality of 
contribution 
Coherence between new law 
and existing rules 
Anecdotal evidence of 
instances in which the 
programme can reasonably be 
said to have improved the 
(identified aspects of the) 
legislative process 

Desk review of programme outputs 
linked to the preparation of EU law 
Programme assessment interviews 
with national customs officials 
Thematic case studies, for example 
the one on the Single Window, 
which can show the contribution of 
the Customs 2020 programme’s 
contribution to the legislative process 
on the matter 

2.2. To what 
extent did the 
Customs 2020 
programme 
support the 
effective 
implementation 
of Union law 
in the field of 
customs and 
related 
matters? 
2.2. From the 
perspective of 
customs 
authorities, 
economic 

Evidence of effective 
implementation of Union law 
in the field of customs 

Desk review of Union law in the 
field of customs and related matters, 
and documents related to the EIS 

The 
programme 
supported the 
effective 
implementation 
of Union law 
in the field of 
customs and 
related matters 

There were 
objective 
improvements 
in the 
coherence of 

Evidence of improvements in 
application of Union law and 
policy in the field of customs: 
- 
of 

consistency 
interpretation 

Desk review of databases-related 
documents 
Thematic case studies, such as the 
one on classification of goods 
Programme assessment interviews 

108  Original  question  was:  From  the  consultation  process  through  to  the  passage  of  legislation,  to  what 
extent did the programme contribute to supporting the preparation of Union law in the field of customs 
and related matters, therefore improving the legislative process? 

68 

 
  
 
 
                                                           
with national customs officials and 
economic operators 

Thematic case studies  
Programme assessment interviews 
with national customs officials and 
economic operators 

operators, and 
other users of 
customs 
processes and 
procedures, to 
what extent did 
the programme 
support the 
coherent 
application of 
Union law and 
policy in the 
field of 
customs and 
related 
matters?109 

Improved 
coherence of 
the application 
of Union law 
and policy in 
the field of 
customs across 
EU Member 
States 

application and 
in the 
enforcement of 
EU law during 
the 
programming 
period and 
across the 
Member States. 

The 
programme 
played a role in 
bringing about 
the 
improvements 
identified 

- 

clarity  among  customs 
authorities  applying  the 
economic 
law 
operators operating under 
the law 

and 

Evidence of improvements in 
application of Union law and 
policy in the field of customs, 
for example through a 
common approach to 
sanctions for those in breach 
of the law 
Evidence of acceptance of 
Union law across a varied 
group of stakeholders, and of 
programme-funded databases 
as references 
Anecdotal evidence of 
tangible improvements in the 
application of EU law 
Anecdotal evidence of 
instances in which the 
programme can reasonably be 
said to have improved to 
specific instances of 
improvements in the 
application and enforcement 
of EU law 
Anecdotal evidence from 
customs authorities regarding 
the programme’s contribution 
to improving the application 
and implementation of Union 
law and policy in the field of 
customs 

Customs 
processes 
within the 
scope of the 
programme 
were simplified 
and took less 
time to 
complete. 

There is evidence of 
simplified e-procedures for 
economic operators (number 
of steps, digitalisation and 
automatic electronic exchange 
of the documents required, 
etc.), a reduction in length of 
time taken to complete 
customs processes. 

EQ3: To what extent has the Customs 2020 programme supported legitimate economic activities and 
prevented illegal ones? 
3.1. To what 
extent did the 
programme 
contribute to 
facilitating 
legitimate 
trade, including 
through 
enabling legal 
certainty, the 
simplification 
and 
effectiveness 
of customs 
processes and 
procedures, the 
availability and 
access to 

Desk review 
Programme level interviews 
(national customs administrations 
and economic operators) 
Thematic case studies (analysis of 
benefits to economic operators 
including as part of the trader portal, 
Single Window environment for 
customs, and classification of goods 
case studies and associated joint 
actions supported) 

Desk review 
Programme assessment interviews 
with national customs officials and 
economic operators 
Thematic case studies, such as the 
one on good classification, trader 

Documentary evidence of 
programme support for trade 
facilitation  
Anecdotal evidence of the 
programme’s contribution to 
improving the application and 

The 
programme 
played a role in 
bringing about 
the 
improvements 

109  Original  question  read:  From  the  perspective  of  customs  authorities,  economic  operators,  and  other 

users of customs processes and procedures, to what extent did the programme contribute to…? 

69 

 
 
 
 
 
                                                           
information? 

identified. 

implementation of Union law 
in the field of customs  

Incidence of fraud cases and 
of wildlife crime, traffic of 
harmful and waste products 
poisoning the Earth, etc. 
Documentary evidence in 
relation to risk management, 
such as the UCC report 

Role of relevant EIS in the 
fight against fraud 
Anecdotal evidence regarding 
the programme’s contribution 
to improving the prevention 
and/or detection of fraudulent 
movements and infringements 
of customs law 

portal, Single Window environment 
for customs (analysis of contribution 
of programme to benefits realised) 
Desk review of risk management 
related documents, UCC reports, 
reports on the Protection of the 
European Union's financial interests 
– Fight against Fraud, documents 
related to the Hercule III programme 
Thematic case studies, especially the 
one on risk management, but also the 
one on the Single Window 
environment for customs 

Desk review of risk management 
related documents, UCC reports, 
reports on the Protection of the 
European Union's financial interests 
– Fight against Fraud, documents 
related to the Hercule III programme 
Programme assessment interviews 
with national customs officials, EC 
officials from other DGs (SANTE, 
ENV) and economic operators 
Thematic case studies, especially the 
one on risk management, but also the 
one on the Single Window 
environment for customs 

There was an 
increase in the 
prevention 
and/or 
detection of 
fraudulent 
movements 
and 
infringements 
of Union law 
in the field of 
customs. 
The 
programme 
played a role in 
bringing about 
the improved 
prevention 
and/or 
detection of 
fraudulent 
movements 
and 
infringements 
of Union law 
in the field of 
customs.  

3.2. To what 
extent can the 
Customs 2020 
programme be 
considered to 
have helped 
customs and 
other 
authorities 
involved in the 
detection and 
prevention of 
illegal cross-
border activity, 
in relation 
to…? 

  the 

fight 

against 
fraud 
the EU 

in 

  the 

the 

protection 
of 
security 
and  safety 
EU 
of 
citizens 

  the 

the 

protection 
of 
environme
nt 

Efficiency 

Sub-question 

Judgement 
Criteria 

Indicators 

Information Source 

EQ4: To what extent have the Customs 2020 programme’s resources produced best possible results 
at the lowest possible cost? 
4.1. To what extent 
have the Joint 
activities produced 
the best possible 
results at the lowest 
possible cost? 

The cost of the joint 
actions is justified, 
given the 
changes/effects they 
have achieved 

Answers to the Evaluation 
Questions for Effectiveness 
related to joint actions. 

Desk research (Budgetary data 
from DG TAXUD) 

Budget allocated/spent 
for joint actions funded 
for the period 2014-2020 
Number and type of joint 
actions funded 2014-
2020 
See indicators on effects 
of joint actions under 
Evaluation Questions 
related to the 
Effectiveness criteria. 

70 

 
 
Sub-question 

4.2 To what extent 
have the funded 
human capacity 
building activities 
produced the best 
possible results at 
the lowest possible 
cost? 

Judgement 
Criteria 
The cost of the 
human capacity 
building is justified, 
given the 
changes/effects they 
have achieved 

4.3. To what extent 
have the funded IT 
systems produced 
the best possible 
results at the lowest 
possible cost? 

The cost of the EIS 
is justified, given 
the changes/effects 
they have achieved 
The programme’s 
budget spent on IT 
capacity building is 
in line with the 
planned 
expenditures at EU 
level. 

Indicators 

Information Source 

Budget allocated/spent 
for human competency 
building funded for the 
period 2014-2020 
Number and type of 
human capacity building 
actions funded 2014-
2020 
See indicators on effects 
of human capacity 
building under 
Evaluation Questions 
related to the 
Effectiveness criteria. 
Budget allocated/spent 
EIS funded for the period 
2014-2020 
See indicators on effects 
of EIS under Evaluation 
Questions related to the 
Effectiveness criteria. 

Desk research (Budgetary data 
from DG TAXUD) 

Answers to the Evaluation 
Questions for Effectiveness 
related to human competency 
building. 

Desk research (Budgetary data 
from DG TAXUD) 
Case studies (survey and cost 
assessment) 
Answers to the Evaluation 
Questions for Effectiveness 
related to the funded EIS. 

71 

 
 
Sub-question 

Judgement 
Criteria 
The costs associated 
to the Customs EIS 
(infrastructure, 
development, 
maintenance, 
support, and 
training) are in line 
with the planned 
expenditures at 
national level and 
considered as 
proportionate by 
national authorities 
and economic 
operators 

Indicators 

Information Source 

Documentary and 
anecdotal evidence of 
costs (not monetised) 
associated to the 
Customs EIS 
(infrastructure, 
development, 
maintenance, support, 
and training) at national 
level 

Stakeholder perception 
of benefits (including 
reduced administrative 
burdens and cost 
savings) associated to the 
Customs EIS, including 
those generated by 
shared developments 
model and IT 
architecture 

Case studies: 
- Cost-assessment: Desk 
research on secondary sources to 
build upon cost data of Customs 
EIS already collected and 
analysed in previous or ongoing 
relevant studies 

since 

  Previous 

evaluations, 
impact assessments and 
other studies (assess the 
evolution 
the 
ECA’s  report  on  the 
delays  in  Customs  IT 
systems) 
  Previous 

evaluations 
and impact assessments 
of similar systems 
  Union  Customs  Code 
upcoming evaluation 

  Performance 
Measurement 
Framework 
related 
documentation (State of 
play) 

 

of 

  Legal  acts  (Recall  the 
the 
2020 

objectives 
Customs 
programme) 
e-Customs 
related 
documentation  (Assess 
behind 
rationale 
Customs  2020-funded 
IT systems) 
- Online survey on costs and 
benefits for the selection of EIS 
- Case study interviews with 
national custom authorities and 
economic operators 

Programme level interviews 
(TAXUD officials) 
Budgetary and accountancy data 
from DG TAXUD. 

The programme 
allowed budgetary 
flexibility when 
prioritisation was 
needed 

4.4 To what extent 
has the 
programme 
provided for a 
certain degree of 
budgetary 
flexibility to 
respond to changes 
in policy priorities? 

Confirmation by EU 
officials that plans could 
be changed when needed, 
and concrete examples of 
cases in which this was 
possible 
Number of activities 
funded where the budget 
initially allocated was 
reallocated to other 
programme activities / 
policy priorities  

72 

 
 
 
Sub-question 

4.6 To what extent 
can the 
design, 
development, 
governance, and 
implementation of 
the Customs EIS be 
improved in the 
context of the 
programme, 
learning from best 
practices across 
other trans-
European IT 
systems? 

Judgement 
Criteria 
There is scope to 
improve the design, 
development, 
governance, and 
implementation of 
the Customs EIS in 
the context of the 
programme, 
learning from best 
practices across 
other trans-
European IT 
systems.  

Indicators 

Information Source 

Budgetary and accountancy data 
from DG TAXUD. 
Findings on the cost of Customs 
EIS from the case study cost 
assessment 
Programme level interviews 
(TAXUD and other EC DGs 
officials) 

Benchmarking exercise: Desk 
research on the cost of the 
selected trans-European IT 
systems. 
Answers to the Evaluation 
Questions related to the 
Effectiveness criterion (for 
example 1.1 and 1.2) 
Benchmarking exercise: Desk 
research on secondary sources to 
collect data on lessons learnt and 
best practices across other trans-
European IT systems  
Programme level interviews 
(TAXUD officials) 
Case study interviews 

Programme level interviews 
(TAXUD officials) 
Case study interviews 

Comparison of relative 
costs associated to the 
Customs EIS compared 
to other European IT 
systems. 

Comparison of relative 
benefits associated to the 
Customs EIS against 
other European IT 
systems. 

Confirmation by 
stakeholders that they are 
satisfied with the 
management of the 
Customs EIS and/or 
suggestions from 
stakeholders on how to 
improve the design, 
development, 
governance, and 
implementation of the 
Customs EIS.  
Confirmation by 
stakeholders that the 
recommendations from 
the mid-term evaluation 
of the Customs 2020 
programme related to the 
customs EIS have been 
addressed  

Relevance 

Sub-question 

Judgement 
Criteria 

Indicators 

Information Source 

EQ5: To what extent does the Customs 2020 programme continue to respond to the needs of the 
customs administrations, businesses and, ultimately, the EU Customs Union? 

Q.5.1 In what 
ways do the 
Customs 2020 
programme’s 
specific 
objectives 
continue to 
respond to the 

The programme’s 
specific objectives 
correspond to the 
needs of the 
customs 
administrations 

Customs’ administrations confirm 
that the programme continues to 
support them in: 

the fight against fraud 
the protection of intellectual 

property rights 

increasing safety and security 
the protection of citizens and 

Desk review  
Scoping interviews (EU 
officials) 
Programme level interviews 
(national customs 
administrations) 
Case study interviews 
(national customs 

73 

 
 
 
 
 
 
Indicators 

Information Source 

Judgement 
Criteria 

Sub-question 

needs of the 
customs 
administrations 
and 
businesses? 

The programme’s 
specific objectives 
correspond to the 
needs of the 
businesses 
(‘economic 
operators’)  

The programmes’ 
specific objectives 
are sufficiently 
flexible to allow 
the programme to 
respond to the 
new/evolving 
needs of custom 
authorities and 
businesses 

the environment 
improvement of the 

administrative capacity of 
the customs authorities 

strengthening of the 

competitiveness of 
European businesses 
Existence of needs of national 
customs administrations that are not 
sufficiently addressed in the 
programme specific objectives 

Economic operators confirm that the 
programme continues to support 
them in: 

the fight against fraud, 
the protection of intellectual 

property rights 

increasing safety and security 
improvement of the 

administrative capacity of 
the customs authorities 

strengthening of the 

competitiveness of 
European businesses 

Existence of perceived needs of 
economic operators that are not well 
addressed in the programme specific 
objectives 

EU officials, custom authorities and 
economic operators confirm that the 
programmes’ specific objectives are 
sufficiently flexible to allow the 
programme to respond to 
new/evolving needs stemming from 
unexpected events such as COVID-
19 outbreak, Brexit, and/or new 
policy initiatives such as the 
Customs Action Plan 
Existence of actions supported by 
the programme that could be 
adapted to face the challenges/needs 
brought by unexpected events such 
as the COVID-19 outbreak, Brexit, 
and/or new policy initiatives such as 
the Customs Action Plan 

Q5.2 In what 
ways does the 
Customs 2020 
programme 
operational 
objectives 

The programme’s 
operational 
objectives 
correspond to the 
needs of the 
customs 

Customs’ administrations confirm 
that the programme continues to 
support them in: 
the preparation, coherent application 

and effective implementation 
of Union law and policy in the 

74 

administrations) 

Programme level interviews 
(national customs 
administrations) 
Case study interviews 
(national customs 
administrations) 
Desk review 
Scoping interviews (EU 
officials) 
Programme level interviews 
(economic operators) 
Case study interviews 
(economic operators) 

Scoping interviews (EU 
officials) 
Programme level interviews 
(economic operators) 
Case study interviews 
(economic operators) 
Scoping interviews (EU 
officials) 
 Programme level 
interviews (national 
customs administrations 
and economic operators) 
Case study interviews 
(national customs 
administrations and 
economic operators) 
Desk review 
Scoping interviews (EU 
officials) 
Programme level interviews 
(national customs 
administrations and 
economic operators) 
Case study interviews 
(national customs 
administrations and 
economic operators) 
Desk review 
Scoping interviews (EU 
officials) 
Programme level interviews 
(national customs 
administrations) 

 
Judgement 
Criteria 
administrations  

Sub-question 

continue to 
correspond to 
the needs of 
the customs 
administrations 
and 
businesses? 

The programme’s 
operational 
objectives 
correspond to the 
needs of the 
businesses 
(‘economic 
operators’)  

Indicators 

Information Source 

Case study interviews 
(national customs 
administrations) 

Programme level interviews 
(national customs 
administrations) 
Case study interviews 
(national customs 
administrations) 
Desk review 
Scoping interviews (EU 
officials) 
Programme level interviews 
(economic operators) 
Case study interviews 
(economic operators) 

field of customs 

the development, improvement, and 
operation of the European 
Information Systems for 
customs 

the development and sharing and 
application of best working 
practices and administrative 
procedures, especially further 
to benchmarking activities 
reinforcement of the skills and 

competences of customs 
officials 

improving cooperation between 
customs authorities and 
international organisations, 
third countries, other 
governmental authorities, 
including Union and national 
market surveillance authorities, 
as well as economic operators 
and organisations representing 
economic operators 
Existence of needs of national 
customs administrations that are not 
sufficiently addressed in the 
programme operational objectives 

Economic operators confirm that the 
programme continues to support 
them in: 
the preparation, coherent application 

and effective implementation 
of Union law and policy in the 
field of customs 

the development, improvement, and 
operation of the European 
Information Systems for 
customs 

the development and sharing and 
application of best working 
practices and administrative 
procedures, especially further 
to benchmarking activities 
reinforcement of the skills and 

competences of customs 
officials 

improving cooperation between 
customs authorities and 
international organisations, 
third countries, other 
governmental authorities, 
including Union and national 
market surveillance authorities, 
as well as economic operators 
and organisations representing 
economic operators 

Existence of needs of economic 

Programme level interviews 

75 

 
 
 
 
Sub-question 

Judgement 
Criteria 

Indicators 

Information Source 

operators that are not sufficiently 
addressed in the programme 
operational objectives 
EU officials, custom authorities and 
economic operators confirm that the 
programmes’ operational objectives 
are sufficiently flexible to allow the 
Programme to respond to 
new/evolving needs stemming from 
unexpected events such as COVID-
19 outbreak, Brexit, and/or new 
policy initiatives such as the 
Customs Action Plan 

(economic operators) 
Case study interviews 
(economic operators) 
Scoping interviews (EU 
officials) 
Programme level interviews 
(national customs 
administrations and 
economic operators) 
Case study interviews 
(national customs 
administrations and 
economic operators) 

The programmes’ 
operational 
objectives are 
sufficiently 
flexible to allow 
the Programme to 
respond to the 
new/evolving 
needs of custom 
authorities and 
businesses 

Priorities for programme funding set 
under the Annual Work Programmes 
responded to new/evolving needs 
(addressing Brexit-related issues in 
the AWP for 2017 and onwards and 
mentioning COVID-19 outbreak in 
AWP 2020) 
Existence of actions supported by 
the programme that could be 
adapted to face the challenges/needs 
brought by unexpected events such 
as the COVID-19 outbreak, Brexit, 
and/or new policy initiatives such as 
the Customs Action Plan 

Desk review 
Scoping interviews (EU 
officials) 

Desk review 
Scoping interviews (EU 
officials) 
Programme level interviews 
(national customs 
administrations and 
economic operators) 
Case study interviews 
(national customs 
administrations and 
economic operators) 

Coherence 

Sub-question 

Judgement 
Criteria 

Indicators 

Information Source 

EQ6: To what extent is the Customs 2020 programme coherent with broader EU policies? 

-Desk review  
-Benchmarking exercise  
-Programme 
(EC officials) 
-Case study interviews (TAXUD 
officials) 

interviews 

level 

6.1  To  what  extent 
by  which 
and 
mechanisms 
the 
programme remains 
coherent  to  broader 
EU policies? 

The programme has 
concretely 
specific 
supported 
initiatives 
EU 
outside of the direct 
sphere of ‘customs’ 

Practical  examples  of 
programme 
how 
the 
EU 
supported 
other 
the 
initiatives  beyond 
direct 
of 
purview 
customs  policy  (e.g.,  the 
European  Green  Deal 
and  its  Investment  Plan; 
to  shape 
the  Agenda 
Europe’s digital future)  
and 
Explanations 
evidence 
the 
mechanisms  in  place  to 
ensure  coherence  with 
such EU initiatives   
Gaps  identified  in  terms 
with 
coherence 
of 
specific  EU 
relevant 
(e.g., 
initiatives 

of 

76 

 
 
 
 
-Desk review  
-Benchmarking exercise  
-Programme 
(EC officials) 
-Case study interviews (TAXUD 
officials) 

interviews 

level 

The programme  has 
supported  the  work 
of 
other 
Commission 
services 
broadly 
relevant 
programmes 
managed  by  other 
DGs  and  agencies 
(OLAF))  

more 
(i.e., 

to 

and/or 

inconsistencies, 
duplications 
overlaps found)  
Practical examples of the 
programme’s 
/ 
contribution 
with 
synergies 
services 
Commission 
(e.g., 
Health 
the 
Programme,  the  Reform 
Programmes, 
Support 
Single 
Horizon2020, 
Market Programme)  
and 
Explanations 
evidence 
the 
mechanisms  in  place  to 
ensure  coherence  with 
such  programmes  (e.g., 
the  results  of  the  action 
plan  from  the  mid-term 
recommendations) 
Gaps  identified  in  terms 
of  coherence  with  other 
EU  programmes 
(e.g., 
inconsistencies, 
duplications 
overlaps found) 

and/or 

of 

EU added value 

Sub-question 

Judgement 
criteria 

Indicators 

Information Source 

EQ7: To what extent is the Customs 2020 programme  a vehicle to achieve more  than the Member 
States would do alone? 
7.1 To what 
extent and in 
what ways does 
the Customs 
2020 
programme 
deliver EU 
added value in 
the customs 
field?  

The programme 
allows national 
customs 
authorities to 
work more 
efficiently ‘as 
one’ than 
individually  

  Case study reports  
  Programme 
interviews 
officials) 
  Desk review 

Summary of findings from 
efficiency, from:  

level 
(Customs 

Examples of reduced 
administrative burden and costs 
for national customs 
administrations due to 
interventions supported by the 
programme (e.g., economies of 
scale of EU wide infrastructure 
for communication and 
exchange of data – or ‘common 
components’ of IT systems; 
provision of databases 
/reference material for the 
correct application of EU 
customs law, etc.)  
Examples of limits to efficiency 
savings (e.g., reticence of larger 
Member States to join EU-wide 
solutions to common problems 
and therefore develop / invest in 
national systems) and areas 
where national systems or 
solutions are preferred by 
certain/all Member States over 
EU systems/solutions 
Examples of how the 
programme enabled national 

77 

The programme 
allows national 

Summary  of 
effectiveness, from:  

findings 

from 

 
 
 
customs 
authorities to 
work more 
effectively ‘as 
one’ than 
individually  

7.2 What would 
be the most 
likely 
consequences of 
discontinuing 
the 
programme’s 
support today? 

The programme 
is unique in its 
capacity/ 
function to 
support 
collaboration 
between EU 
customs 
authorities  

by 

administrations to achieve better 
and quicker results than would 
have been possible without 
Customs 2020 (e.g., quick 
sharing of data / knowledge to 
inform more effective decision-
making, development of 
systems that require common 
usage to be effective) 
Examples of limits to the results 
achieved 
the  Customs 
programme  (e.g.,  areas  where 
collaboration or uptake is low or 
(e.g., 
stagnates) 
and  why 
sensitivities  of  data, 
legacy 
systems, etc.) 
Key  informants  agree  that  the 
discontinuation 
the 
programme 
leave 
customs  authorities  without  an 
equivalent structure or means to 
collaborate 
in  an  area  of 
exclusive EU competence 
Areas where collaboration could 
of 
continue 
programme support (if any) 

of 
would 

irrespective 

  Case study reports  
  Programme 
interviews 
officials) 
  Desk review 

level 
(Customs 

Summary  of  findings  from  7.1 
and relevance (5) 

78 

 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

79 

 
 
Table 1. Overview of costs and benefits identified in the evaluation110 

Citizens/Consumers  

Businesses 

Administrations 

[Other
…] _ 
specify 

Quantitati
ve  

Comment  Quantitati

Comment 

ve  

Quantitativ
e 

Comment  

[Cost or Benefit description]: 

Mark the type of 
cost/benefit, each 
on a separate line: 

Costs: 

IT capacity 
building 

(EIS for customs) 

NA 

NA 

464.5 
million 
(Programm
e budget) 

861 million 
(Member 
States 
investments
) 

56.8 
million 

10.4 
million 

NA 

NA 

Joint Actions 

Human 
competency 
building 

Benefits: 

NA 

NA 

IT capacity 
building (EIS for 

Time 
savings in 
customs 
clearance 

Automated 
processes 
contributing to 
more efficient, 

Automated 
processes 
contributing to 
more efficient, 

110 Where there is a prior impact assessment, the table should contain as a minimum the costs/benefits identified in the 
IA with the information gathered on the actual cost/benefit. As available, the table should include the monetisation 
(€)  of  the  costs/benefits  based  on  any  quantitative  translation  of  the  data  (time  taken,  person  days,  number  of 
records/equipment/staff etc. affected or involved represented in monetary  value   – see Standard cost  model, for 
example).  For  all information  presented,  it  should  be  included  in  the  comments  section  whether  it  relates  to  all 
Member States or is drawn from a subset. An indication of the robustness of the data should be provided in Annex 
II on Methodology and analytical models used. 

80 

 
                                                           
                        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
simplified and 
standardised 
custom procedures 
(4.5 average, scale 
1-5) 

More effective 
implementation and 
coherent 
application of 
Union law in the 
field of customs 
(4.8 average score 
scale 1-5) 

from the 
EU CSW-
CERTEX 
(annual 
estimates 
provided 
in the 
impact 
assessme
nt of the 
EU SWE-
C111 
initiative 
for four 
of the 
participat
ing 
countries 
amounted 
around 
EUR 
44.000)   

simplified and 
standardised 
custom procedures 
(4.5 average, scale 
1-5) 

More effective 
implementation and 
coherent 
application of 
Union law in the 
field of customs 
(4.8 average score 
scale 1-5) 

Increased 
interoperability and 
information sharing 
between customs 
authorities (4.4 
average, scale 1-5) 

customs) 

Direct Benefits 

Indirect Benefits 

Increased 
safety and 
security 
thanks to 
the better 
implemen
tation of 
non-
customs 
regulator
y 
formalitie
s (EU 
SWE-C) 

111   Commission  Staff  Working  Document  Impact  AssessmentEU  Single  Window  Environment  for 

Customs (europa.eu) 

81 

 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Joint Actions 

Human 
competency 
building 

82 

 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

Outline of the consultation strategy 

Consultation objectives 

A stakeholder consultation was necessary to: 

  Capture  stakeholders’  needs  and  experiences,  and  their  evolution  since  the  last 
consultation  conducted  in  the  framework  of  the  midterm  evaluation  of  the 
Customs 2020 programme. 

  Ensure the pertinence of the findings of the final evaluation of the Customs 2020 
programme  in  relation  to  developments  not  captured  in  the  documentation,  or 
which require interpretation. 

Identified stakeholders 

In  line  with  the  Better  regulation  guidelines112,  the  following  stakeholder  groups  were 
identified as relevant to the Customs 2020 programme: 

  European Commission officials 

o  Directorate-General  for  Taxation  and  Customs  Union  (DG  TAXUD),  as 

decision-makers, managers, and users of the programme 

o  Other  Directorate-Generals  (DGs),  as  other  EU  authorities  that  engaged 
with  the  Customs  2020  programme,  such  as  DG  for  climate  action 
(CLIMA),  DG for  health  and  food  safety  (SANTE),  and  the  European 
Anti-Fraud Office (OLAF) 

  Customs  authorities  from  participating  countries,  as  beneficiaries  of  the 

programme 

o  EU Member States 

o  Candidate and potential candidate countries   

  Economic operators 

o  Organisation  representing  economic  operators,  namely  Trade  Contact 
Group  (TCG)  members,  as  external  experts  participating  in  certain 
activities 

o  Individual  economic  operators,  as  users  of  certain  outputs  of  the 

programme 

  Customs officials from third countries and international organisations 

112 European Commission, Better regulation guidelines: Chapter II – Stakeholder Consultation. 

83 

 
                                                           
Consultation methods and tools 

The  consultation  was  designed  to  be  of  minimal  burden  to  stakeholders  and  therefore 
focused on those who were directly involved in the programme113. 

The study followed a two-pronged approach with an overall programme assessment and 
a  contribution  analysis  through  thematic  case  studies.  The  study  team  in  charge  of  the 
external  study  conducted  in-depth  interviews  for  both  elements  of  the  approach,  which 
allowed them to interpret and qualify data gathered through the desk research. 

In total, the study team consulted 123 stakeholders directly or indirectly involved in the 
programme (43 for the programme assessment and 80 as part of the case studies): 

  37  European  Commission  officials:  16  officials  were  interviewed  for  the 
programme  assessment,  including  two  from  DG  CLIMA,  one  from  OLAF,  and 
one from  DG REFORM, and 21 as part of the case studies, including two from 
DG CLIMA and two from DG SANTE 

  64 national customs officials: 17 national customs officials were interviewed for 
the  programme  assessment  (from  14  Member  States114  and  three  candidate  and 
potential  candidate  countries115),  and  47  for  the  case  studies  (from  21  Member 
States116  and  two  (potential)  candidate  countries117).  Overall,  all  participating 
countries had the opportunity to contribute to the study, through the programme 
assessment and/or the case studies. 

In addition, a survey targeting national authorities allowed to collect data on the 
costs associated with the IT capacity building activities linked to the sampled EIS 
for customs and on their benefits. The survey was open on ALCHEMER® from 
10  to  31 May 2021  and  received  a  total  of  36  responses  from  18  Member 
States. 

  10  representatives  of  organisations  representing  economic  operators  at  EU 
level  as  part  of  the  programme  assessment,  and  12  individual  economic 
operators from eight Member States118 as part of the case studies. 

113 In addition to individual economic operators that although did not directly engage with the programme, 

were consulted as part of the case studies. 

114 Belgium, Bulgaria, Estonia, Finland, France, Germany, Greece, Italy, Luxembourg, Malta Netherlands, 

Romania, Spain, Slovakia 

115 Montenegro, Serbia, Turkey 

116 Austria, Cyprus, Croatia, Czech Republic, Denmark, France, Germany, Greece, Hungary, Italy, Ireland, 

Lithuania, Latvia, Malta, Netherlands, Poland, Portugal, Slovenia, Spain, Sweden, Romania. 

117 Bosnia and Herzegovina, Republic of North Macedonia 

118 France, Germany, Ireland, Lithuania, Luxembourg, the Netherlands, Sweden, and the UK. 

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No officials  from third countries, apart from the  two (potential)  candidate countries, or 
representatives of international organisations were consulted. No public consultation was 
conducted. 

Results of consultation activities 

This section presents the results of the consultations by stakeholder category. 

European Commission officials 

  Contributions from the in-depth interviews with DG TAXUD officials 

o  Effectiveness 

Most  DG  TAXUD  officials  interviewed  were  highly  positive  about  the  Customs  2020 
programme’s  contribution  to  facilitating  and  enhancing  cooperation  and  exchange  of 
information between customs authorities and their officials within the EU. They provided 
examples of programme activities in their area that facilitated and enhanced cooperation 
and/or exchange of information between participating customs authorities. DG TAXUD 
officials  qualified  cooperation  on  the  development  of  the  EIS  common  components  as 
part of IT capacity building activities as “very good”. Several cited ICS2 as an example 
of  “exceptional  cooperation”  between  Member  States.  The  Customs  2020  programme 
also facilitated and enhanced cooperation on a national component119 through the Expert 
team  on  new  approaches  to  develop  and  operate  Customs  IT  systems  (ETCIT).  DG 
TAXUD officials also highlighted the importance of the networking opportunities taking 
place before and after the meetings (before COVID-19). 

According to  DG TAXUD officials  consulted,  all the Customs 2020 activities aimed to 
support  the  preparation,  implementation,  or  coherent  application  of  Union  law  whether 
directly  or  indirectly.  Customs  law  and  policy  units  (from  Directorate  A)  specifically 
used the outputs of the joint actions to support their work, which eventually fed into the 
preparation  of  Union  law.  For  example,  one  interviewee  considered  the  work  of  the 
Financial  risk  management  project  group  (CPG/076)  as  “invaluable”  to  ensure  the 
appropriate drafting of the Financial Risk Criteria Implementing Decision120. Some joint 
actions’ outputs also reportedly eased the work of the Customs Code Committee. 

Officials  from  Directorate  B  (Digital  delivery  of  customs  and  taxation  policies)  were 
vocal about the EIS for customs effectively allowing to implement Union law. For them, 
the delivery of the policy objectives happens through the EIS for customs and implicitly 
requires the existence of the Customs programme, as there are no other means to develop 
the systems that implement Union law. While alignment with Union law is fully part of 

119 For UCC Notification of Arrival, Presentation Notification and Temporary Storage. 

120  Commission  implementing  decision  laying  down  measures  for  the  uniform  application  of  customs 
controls  by  establishing  common  financial  risk  criteria  and  standards,  available  only  on  a  need-to-
know basis to the persons duly authorised (not published). 

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the IT capacity building activity, associated joint actions also contributed to ensuring the 
effective implementation, by improving user-friendliness and supporting the revision of 
some  functionalities.  For  example,  the  project  group  on  the  Customs  Decision  System 
(CDS)  helped  Directorate  B  to  solve  the  issues  of  alignment  with  Union  law  when 
deployed in 2017, by regularly inviting participating countries to discuss the issues they 
encountered.  In  addition,  the  EU  Customs  Single  Window  Certificates  Exchange  (EU 
CSW-CERTEX) system supported both the effective implementation and the preparation 
of  Union  law.  The  Customs  2020  programme  served  to  set  up  the  pilot,  building  the 
concept of single window presented in the e-customs decision121. DG TAXUD officials 
indicated  that  the  Proposal  for  a  Regulation  establishing  the  EU  Single  Window 
Environment  for  Customs122  was  based  on  this  experience,  in  addition  to  discussions 
with  Member  States  through  joint  actions.  Moreover,  the  databases  maintained  and 
operated  through  the  Customs  programme  also  supported  the  coherent  application  of 
Union law. For example, TARIC includes all legislation related to the import activities, 
namely  everything  an  importer  needs  to  know  regarding  Union  law  in  customs  and 
related  matters,  like  prohibition  and  restrictions  for  instance.  Most  importantly  for  law 
and  policy  units,  joint  actions  supported  the  production  of  guidance  documents,  which 
were  useful  tools  for  participating  countries  to  apply  Union  law  more  coherently.  For 
them,  all  the  joint  actions  and  human  competency  building  activities  increased 
participants’ knowledge and understanding to apply Union law more consistently. 

DG  TAXUD  officials  consulted  agreed  that  the  Customs  2020  programme  largely 
supported  legitimate  economic  activities  through  the  EIS  for  customs,  which  reduced 
compliance burden and  ensured economic operators are treated in  the same way across 
the EU. 

According  to  DG  TAXUD  officials,  the  Customs  2020  programme  prevented  illegal 
activities by supporting risk analysis and contributing to the fight against fraud. Specific 
EIS  allow automation in performing checks,  which help  to  identify  inconsistencies and 
discrepancies,  reducing  the  scope  of  the  fraud  and  supporting  the  risk  analysis.  More 
generally,  for  DG  TAXUD  officials,  digitalisation,  and  the  real  time  exchange  of 
information  between  Member  States  help  avoid  fraud  linked  to  the  use  of  paper 
documents. One recalled that the first EIS for customs123 was set up specifically to fight 
fraud. By financing the operation and maintenance of such systems, which is a big part of 
the Customs programme, it contributes to preventing illegal activities. 

o  Efficiency 

121  Decision  No  70/2008/EC  of  the  European  Parliament  and  of  the  Council  of  15  January  2008  on  a 

paperless environment for customs and trade (OJ L 23, 26.1.2008). 

122  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  establishing  the  European 
Union Single Window Environment for Customs and amending Regulation (EU) No 952/2013 (COM 
(2020) 673 final 2020/0306 (COD, 28.10.2020). 

123 Now the new computerised transit system (NCTS). 

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It  was  difficult  for  DG  TAXUD  officials  to  indicate  whether  the  Customs  2020 
programme’s resources produced the best possible results at the lowest possible cost as 
they indicated not having sufficient analytical data that would allow them to assess this, 
especially  in  relation  to  the  IT  capacity  building  activities.  For  example,  while  their 
financial tools allow to  control the overall expenditure per contract or unit, they do not 
have the accounting to analyse each system as the data are available per EIS only for the 
development costs. In addition, officials from Directorate B (Digital delivery of customs 
and taxation policies) highlighted that as the datacentres support the EIS for customs and 
taxation,  it  is  difficult  to  assign  the  amount  of  budget  from  the  Customs  programme 
specifically124. Even so, they indicated that the processes in place for the development of 
the customs EIS ensures that the programme funding is well spent, since each IT project 
starts  with  a  business  case  providing  analysis  of  the  costs  and  benefits  of  the  proposed 
customs EIS, which is reviewed and approved at different levels.125. They also mentioned 
that  the  Customs  2020  programme  has  allowed  to  operate  and  maintain  more  systems. 
Directorate B highlighted their ability to work on more systems in parallel than ten years 
ago,  thanks  to  the  methodology  they  optimised  over  the  years.  Yet,  since  they  also 
depend  on  Member  States’  own  IT  development,  setting  and  meeting  deadlines  for  the 
launch of the EIS for custom can remain challenging. 

While  DG  TAXUD  officials  saw  the  potential  for  further  efficiency  gains  for  some 
centralised  EIS  for  customs,  in  cases  where  Member  States  still  chose  their  national 
components,  this  would  only  be  possible  if  they  gave  them  up.  As  such,  DG TAXUD 
officials  believed  the  Customs  2020  programme’s  resources  produced  the  best  possible 
results under the constraints linked to accommodating Member States’ choices. 

DG TAXUD officials  who managed joint  actions  thought  these provided a good  return 
on investment, as they led to better approaches and solutions. Some noted however that 
face-to-face  meetings  could  be  organised  in  a  timelier  manner,  to  ensure  the  lowest 
possible  cost  (especially  in  Brussels,  where  dates  are  important  in  terms  of  prices  and 
facilities). 

o  Relevance 

For DG TAXUD officials consulted, the Customs 2020 programme continues to respond 
to customs administrations’ needs through the joint actions. Indeed, they allow them to 

124 The Fiscalis programme (for taxation) also funds the datacentres. 

125 First the business case is reviewed by the Electronic Customs Coordination Group (ECCG), which is 
made up of national customs authorities and organisations representing economic operators at EU level. On 
this basis a preferred implementation option is chosen, which is reviewed and approved by the DG 
TAXUD IT Steering Committee and the ITC Board. The project methodology for UCC electronic systems 
then includes several other steps, including the development of a vision document, business process 
modelling, the development of the technical specifications to the project rollout (from preparation and 
development to construction, conformance testing, migration, and operations). 

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get information on customs administrations’ needs specifically. Many were also set up to 
address specific needs. 

o  Coherence 

DG  TAXUD  officials  consulted  thought  the  Customs  2020  programme  was  generally 
coherent with broader EU policies. They indicated that they have strong cooperation with 
and  directly  contribute  to  several  policy  areas.  For  example,  EU  CSW-CERTEX  has 
linkages with phytosanitary, climate, environmental, product safety, and maritime policy. 
DG TAXUD also cooperates with DG BUDG on guarantees. 

o  EU added value 

DG TAXUD officials considered the Customs 2020 programme as a vehicle to achieve 
more than the Member States would do alone, noting that without it there would be 27 
customs authorities and no Customs Union. Some even went as far as saying without the 
programme  there  would  be  no  international  trade,  as  it  relies  on  the  EIS  for  customs 
operated and maintained through the programme.  

DG TAXUD officials further highlighted that the programme allows for informal contact 
and therefore open discussion about problems participating countries are facing unlike in 
other  fora.  Consequently,  discontinuing  the  programme  would,  according  to  DG 
TAXUD, create “insurmountable” barriers on accomplishing their mission. 

  Contributions from the in-depth interviews with officials from other DGs 

o  Effectiveness 

Consultations  with  other  DGs  confirmed  that  the  Customs  2020  programme  has 
indirectly supported the prevention of illegal economic activities in their policy areas. For 
example, DG CLIMA noted the positive contribution the programme has had in terms of 
the prevention of illegal trade in Fluorinated gases (‘F-gases’). 

o  Efficiency 

Consultations  with  other  DGs  also  confirmed  that  the  Customs  2020  programme’s 
resources produced the best possible results at the lowest possible costs in relation to the 
activities  they  participated  in.  DG  CLIMA  highlighted  that  they  achieved  a  lot  in  only 
three meetings. 

o  Coherence 

Officials from other DGs consulted thought the Customs 2020 programme was coherent 
with their policies. DG CLIMA’s F-gas Regulation126 and quota system require import 
controls.  So,  they  have  been  working  in  close  contact  with  DG  TAXUD,  including 
through a Customs 2020 project group, in which OLAF also participated. This created a 
positive  avalanche  of  cooperation  outside  the  framework  of  the  Customs  2020 
programme,  including  common  customs  surveillance  exercises  for  instance.  DG 

126  Regulation  (EU)  No  517/2014  of  the  European  Parliament  and  of  the  Council  of  16  April  2014  on 
fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006 (OJ L 150, 20.5.2014). 

88 

 
                                                           
REFORM  also  indicated  that  there  are  complementarities  between  the  Customs 
programme  and  the  Technical  Support  Instrument.  They  can,  for  example,  provide 
feasibility studies  to  develop  specific aspects  of the EIS for customs. Yet, according to 
the  DG  REFORM  official  consulted,  there  is  potential  for  improvement  regarding 
synergies. 

o  EU added value 

Finally, consultations with other DGs confirmed that the Customs 2020 programme is a 
vehicle to achieve more than the Member States would do alone regarding their policy. 
The  exchange  of  best  practices  and  the  discussions  regarding  what  customs  authorities 
needed  to  perform  their  responsibilities  in  their  respective  policy  areas  would  not  have 
happened otherwise. 

  Consideration for the evaluation 

The  information  gathered  and  feedback  received  through  consultation  of  Commission 
officials helped to better understand the programme and its functioning. That fed into the 
answer  to  all  the  evaluation  questions.  Nevertheless,  their  views  on  the  success  of  the 
programme  needed  confirmation  from  the  other  stakeholder  groups.  Two  DG  TAXUD 
officials  specifically  indicated  that  they  could  not  comment  on  whether  participating 
countries eventually apply Union law more coherently, noting that they could not know 
what happened on the ground. For example, they noted that although they are aware of 
the exchange of information, they have less visibility on customs authorities’ use of such 
information.  More  generally,  two  other  DG  TAXUD  officials  also  indicated  that  they 
could  not  answer questions related to  impacts  of the programme (EQ3) simply because 
they are not the right stakeholders to ask about these. In addition, programme activities 
are still ongoing, and it was too early for them to identify and assess long term impacts. 
For broader EU policies, not linked either to customs or taxation, it was difficult for most 
DG  TAXUD  officials  to  further  comment.  They  mainly  mentioned  cooperation  on 
customs or taxation-related policies, such as the e-commerce initiative. 

When  consulted  for  the  case  studies,  DG  TAXUD  officials  generally  provided 
information  and  feedback  on  the  activities  within  the  scope  of  the  case  studies 
specifically.  Where  relevant,  this  fed  into  the  general  assessment  of  the  programme  as 
well. 

National Customs Officials 

  Contributions  from  the  in-depth  interviews  with  national  customs  officials 

from EU member states 

o  Effectiveness 

Officials  from  national  customs  authorities  considered  that  the  programme  played  a 
significant  role  in  building  IT  capacity  that  enabled  greater  electronic  exchange  of 
information between customs authorities as well as with other governmental authorities 
and  economic  operators.  For  them,  this  increase  in  real-time  exchange  of  information 
resulted in greater cooperation and coordination between customs officials, and with the 

89 

 
Commission. It also supported legitimate economic activities and helped prevent illegal 
ones. 

Customs  officials  also  considered  that  the  EIS  for  customs  played  an  important  role  in 
supporting  Member  States’  coherent  application  of  Union  law.  For  instance,  national 
customs officials interviewed as part of the risk management case study cited the design 
of the CRMS as important for ensuring consistency in its usage and thus a more coherent 
application of relevant law. 

Moreover, customs officials agreed that the IT capacity building activities supported the 
simplification, modernisation and harmonisation of the import and export processes. For 
instance,  they  considered  the  changes  in  the  management  of  applications  and 
authorisations in the AEO system as particularly positive in that regard. 

Customs  officials  highlighted  that  the  joint  actions  were  particularly  useful  for  the 
exchange  of  information  and  expertise  and  an  important  platform  for  communication 
between  the  Commission,  EU  national  customs  officials,  and  authorities  from  third 
countries.  This  resulted  in  enhanced  cooperation  between  these  stakeholders.  Customs 
officials  also  highlighted  that  joint  actions  were  a  good  opportunity  to  expand  their 
network  and  contacts.  They  noted  that  they  liaise  regularly  with  the  contacts  they 
developed through the joint  actions and that the exchange of information has happened 
not only during and within the joint actions, but also beyond them. 

Customs officials also mentioned that the joint actions were a means to examine issues in 
the  legislation  and  identify  adaptations  needed.  Customs  officials  indicated  that  project 
groups  were  particularly  useful  during  the  last  five  years  of  the  programme,  as  they 
served  to  discuss  the  technical  aspects  of  the  UCC  and  IT  projects  specifically.  In 
addition,  customs  officials  considered  that  joint  actions  had  supported  the  coherent 
application  of  Union  law  by  promoting  a  common  interpretation  of  the  related 
procedures.  They  highlighted  the  guidance  documents  developed  as  part  of  the  joint 
actions as particularly helpful in that regard.  

In  their  view,  expert  teams  also  contributed  to  the  exchange  of  relevant  information, 
increased cooperation and supported the coherent application of Union law. 

Customs  officials  provided  positive  feedback  on  the  IT  training  in  terms  of  usefulness 
and expectations. They appreciated the human competency building activities in general, 
especially officials from countries where there are no (or very few) places to learn about 
customs  Union  law  and  processes.  Customs  officials  also  appreciated  the  in-person 
training components such as in the case of car search training. Lastly, customs officials 
noted that training activities continued during the pandemic, through video conferences 
and  online  courses.  They  considered  that  virtuality  had  allowed  more  officials  to 
participate  in  the  training  which  they  viewed  as  a  positive  outcome  emerging  from  the 
pandemic. They appreciated this flexibility. 

o  Efficiency 

Overall, national officials considered that the costs of the customs EIS were reasonable 
and explained that these were covered mostly by the Customs 2020 programme. Customs 

90 

 
officials considered that the development of the EIS for customs had reduced duplication 
of efforts, time, and costs for Member States. 

In terms  of design and  management of the EIS for customs, most customs officials  did 
not  mention  any  specific  areas  for  improvement.  Instead,  they  said  they  were  satisfied 
with  DG  TAXUD’s  management  and  coordination  tasks.  Only  a  few  customs  officials 
highlighted issues related to the complexity of the systems and the division between EU 
and  national  components;  the  need  for  a  more  holistic  approach  to  the  Commission’s 
management  of  the  IT  systems;  and  the  need  to  further  streamline  the  Commission’s 
communication  by  considering  one  single  channel  of  information  for  national 
administrations.  

Customs officials considered the costs associated with their participation in joint actions 
to  be  proportionate  to  the  benefits  they  generated.  However,  several  customs  officials 
reported  issues  related  to  the  reimbursement  of  expenses  such  as:  VAT  not  being 
reimbursed;  reimbursement  being  covered  for  only  one  expert;  the  lack  of  funding  for 
informal  networking  or  social  gathering  following  an  official  event;  and  the  lack  of 
comprehensive reimbursement for working visits. A few national customs officials also 
highlighted  the  need  for  the  programme  to  cover  the  costs  of  translation  and 
interpretation to allow their staff to participate in the joint actions.  

In relation to training activities, two customs officials noted that they would like to see 
their  national  experts  being  paid  for  their  time  when  training  other  national  authorities 
(on a voluntary basis), as they are currently only reimbursed for travel, accommodation, 
and basic costs. 

Summary of responses to the cost benefit survey 

With regards to the survey on costs and benefits on the case study EIS, a total of 36 responses 
from  18  Member  States  were  received.  Of  those  18  Member  States  that  responded  to  the 
survey, national authorities from only 5 to 8 Member States (depending on the IT system) 127 
reported detailed breakdown of costs of the systems assessed.  

Costs:  For  those  5-8  Member  States  for  which  this  data  was  available,  the  authorities 
considered ICS2 as the costliest, especially in relation to one-off development costs and one-
off and ongoing support costs. While SURV3 was considered the most expensive in terms of 
both one-off and ongoing infrastructure costs. However, this needs to be put into context with 
the scope of the different EIS, their size and complexity.  

Benefits:  The  national  authorities  that  responded  to  the  survey  noted  relevant  benefits  for 
each of the selected EIS for customs, most notably (1) the automated processes contributing 
to  more  efficient,  simplified,  and  standardised  customs  procedures,  (2)  more  effective 
implementation  and  coherent  application  of  Union  law  in  the  field  of  customs,  and  (3) 

127 Five Member States provided information on EBTI3; five on the AEO upgrade; six on CDS; seven on 

ICS2; eight on SURV3. 

91 

 
                                                           
increased interoperability and information sharing between customs authorities. 

Cost effectiveness: Most national authorities that responded to the survey believed the costs 
borne at national level were reasonable and considered most of the systems to be moderately 
cost-effective. Only SURV3 was considered less cost-effective. However, it should be noted 
that, SURV3, like other EIS, is not meant to reduce costs of customs administrations, but to 
bring  important  benefits  in  terms  of  data  analysis  capabilities  at  EU  level.  In  addition  the 
system  is  not  yet  delivering  its  full  potential  (as  data  continues  to  be  gathered  in  different 
formats  until  all  Member  States  align  their  systems  to  the  UCC  data  requirements),  which 
may influence survey respondents’ perception of its partial cost-effectiveness. 

o  Relevance 

Customs officials highlighted the continued relevance of the programme, noting that their 
needs  had  remained  largely  unchanged  since  the  mid-term  evaluation.  They  confirmed 
the continued need for the programme to  1) harmonise the application of Union law in 
the field of customs and 2) support Member States in the digitalisation and modernisation 
of customs procedures, including updating national IT systems and adapting them to new 
requirements. 

Customs officials also noted that Brexit and the COVID-19 pandemic did not affect the 
relevance  of  the  programme  and  its  objectives.  On  the  contrary,  they  noted  that  the 
programme’s  activities  had  contributed  to  preparing  the  ground  for  the  UK’s  departure 
from the EU and that the Commission had reacted swiftly to the challenges imposed by 
the pandemic by adopting relevant legislation, issuing guidelines, and actively supporting 
Member  States  and  economic  operators  to  ensure  flexibility  in  relation  to  customs 
obligations and customs clearance. 

Nevertheless, they noted that the increased virtuality of exchanges and meetings brought 
by  the  pandemic  had  affected  networking  opportunities  which  were  easier  during  the 
face-to-face  exchanges.  Adding  to  this,  some  customs  officials  pointed  to  the 
programme’s  management  systems,  for  example,  PICS  and  ART,  as  being  outdated, 
namely not adapted to the new reality of increased virtuality. They, therefore, demanded 
more  advanced  tools  and  support  from  the  programme,  for  example  by  providing  a 
stable,  secure,  and  user-friendly  platform  for  online  meetings,  exchange  of  data  and 
collaboration between national customs authorities. 

o  Coherence 

Customs  officials  acknowledged  that  the  programme  aligned  well  with  broader  EU 
initiatives  and  mentioned  for  instance  the  European  Green  Deal,  Horizon  2020,  the 
European  Neighbourhood  Instrument  (ENI),  and  the  Internal  Security  Fund  (ISF). 
Customs officials also claimed that there is scope to strengthen cooperation between DGs 
for  raising  the  visibility  of  the  Customs  programme  and  other  complementary  funding 
instruments  within  the  Member  States,  (meaning  both  across  different  levels  of 
management in the central administration and across the country). Customs officials also 
suggested  increasing  cooperation  with  third  countries’  authorities,  especially  for 

92 

 
supporting  the  delivery  of  EU  environmental  goals  and  the  prevention  of  illegal 
activities, in relation to e-commerce for instance. 

o  EU added value 

Customs officials generally reported that the EIS for customs led to increased efficiency 
and  effectiveness  linked  to  the  automated  procedures  and  paperless  processes.  They 
considered that Member States working alone could not have achieved the same results. 

Similarly,  customs  officials  also  noted that the  establishment of joint  actions was more 
cost–effective  than  having  each  Member  State  setting  up  cooperation  frameworks  with 
other Member States, either on a bilateral or multilateral basis. In addition, by gathering 
the  expertise  of  different  participating  countries  in  the  joint  actions,  the  programme 
provided the opportunity for participating countries to access a wider pool of knowledge 
and experts than they would otherwise have had access to at an individual level (this was 
the case particularly for smaller Member States). 

Lastly,  they  highlighted  that  the  access  by  a  wide  range  of  customs  officials  to 
standardised and comprehensive information  through the  eLearning modules was a key 
factor contributing to a better understanding of Union law and therefore, a more coherent 
application through the IT systems. 

  Contributions  from  the  in-depth  interviews  with  national  customs  officials 

from candidate and potential candidate countries 

o  Effectiveness 

Customs  officials  from  (potential)  candidate  countries  highlighted  the  exchange  of 
information,  networking,  and  cooperation  between  customs  authorities  as  the  most 
important benefits of the programme. They all mentioned joint actions and working visits 
specifically as beneficial in raising awareness of technical issues and possible solutions, 
and in ensuring the correct implementation of the EIS for customs. 

Lastly,  in  their  view,  the  programme  supported  the  implementation  of  national  laws  in 
line  with  the  UCC.  Participation  in  project  groups  enabled  them  to  align  their  national 
laws in the field of customs with Union law. 

o  Efficiency 

Officials from (potential) candidate countries considered the programme to be efficient. 
One official reported that the costs related to the programme’s activities were negligible 
in view of the benefits that the programme activities bring. However, one official from a 
candidate  country  also  noted  that  the  2020  programme  had  set  up  new  and  more 
complicated rules and procedures for joint actions than in previous iterations. While this 
did not have an impact on the level of participation in joint actions, it had increased the 
administrative burden. 

o  Relevance 

Officials  from  (potential) candidate countries considered the programme to be relevant. 
They  noted  that  while  the  COVID-19  pandemic  had  created  issues,  notably  regarding 

93 

 
networking  and  working  visits,  the  programme  had  been  flexible  in  its  response  and 
mitigated  the  effects  of  the  pandemic  by  adopting  virtual  modalities  such  as 
videoconferencing and moving most of the events to an online format. 

Regarding  needs  that  the  programme  has  found  more  challenging  to  respond  to,  one 
official  highlighted the increase in  e-commerce fraud while another mentioned the lack 
of flexibility of IT solutions for coordinators notably regarding ART and PICS. 

  Consideration for the evaluation 

Officials  from  national  customs  authorities  are  the  main  beneficiaries  of  the  Customs 
2020  programme  and  were  therefore  consulted  on  all  the  evaluation  criteria  and  their 
feedback integrated into findings of the evaluation. More limited feedback was collected 
from officials from the candidate and potential candidate countries given that they were 
less involved in the programme activities and therefore were less aware of their results. 

Economic Operators 

  Contributions from the in-depth interviews with representatives of EU level 
organisations representing economic operators (programme assessment) and 
individual economic operators (case studies) 

o  Effectiveness 

Both individual economic operators and EU-level organisations representing them were 
overall positive about the outcomes of the programme. They highlighted the support the 
programme had provided in  relation to  the development  of the EIS for  customs, which 
simplified and harmonised electronic procedures, reducing the time it takes to complete 
customs  processes  and  provided  legal  certainty  to  importers  and  exporters.  EU-level 
organisations representing economic operators  also positively  assessed the joint  actions 
noting  that  they  increased  cooperation,  communication,  and  information-sharing. 
However,  individual  economic  operators  were  less  aware  of  the  existence  of  joint 
actions.  Similarly,  not  all  were  aware  of  the  existence  of  the  eLearning  modules,  but 
those  who  were,  highlighted  the  eLearning  courses  as  valuable.  For  instance,  one 
economic  operator  referred  to  the  eLearning  courses  on  Brexit  as  being  particularly 
useful,  while  another  mentioned  having  integrated  all  programme  eLearning  modules 
into an internal university course. Despite overall positive feedback on the Customs 2020 
programme,  economic  operators  also  identified  several  areas  of  improvement,  as 
presented below. 

-  Several  individual  economic  operators  and  EU-level  organisations  representing 
economic operators highlighted that the increased digitalisation has resulted in a 
more  complex  IT  environment  that  has  been  challenging  for  smaller  economic 
operators  to  manage.  In  addition,  the  increased  focus  on  risk  management  has 
resulted  in  additional  requirements  for  the  economic  operators  and  therefore 
increased administrative burden. 

-  More  than  a  third  of  EU-level  organisations  representing  economic  operators 
interviewed  reported  the  gradual  implementation  of  the  EIS  across  the  Member 

94 

 
States,  which  means  that  the  systems  are  deployed  at  different  times  across  the 
EU, as an issue distorting competition. Several individual economic operators and 
EU-level organisations representing economic operators also highlighted the lack 
of  adequate  and  timely  communication  and  information  received  from  the 
Member  States  on  the  EIS  to  be  implemented.  This  was  noted  as  creating 
uncertainty and leading to errors and delays. 

-  EU-level  organisations  representing  economic  operators  were  less  aware  of  the 
programme’s activities regarding the prevention of fraud and illegal activities but 
noted  that  economic  operators  and  society  in  general  were  well  protected. 
However,  they  also  highlighted  an  increase  in  e-commerce  fraud,  which 
economic  operators  are  liable  for128.  While  recognising  the  Commission  and 
Member States’ work on the latter, several economic operators still noted this as 
an issue to address. 

-  Lastly,  several  EU-level  organisations 

representing  economic  operators 
highlighted  that  some  Member  States  interpret  and  thus  apply  Union  law  in  the 
field of customs differently resulting in distortion of trade and unpredictability for 
improved,  but  different 
that 
economic  operators.  They  noted 
interpretation  can  still  be  found  both  between  Member  States  as  well  as  within 
Member States. 

this  has 

o  Efficiency 

Overall,  both  individual  economic  operators  and  EU-level  organisations  representing 
economic operators considered that the benefits of the Customs programme outweigh the 
cost and while the cost was high at the implementation phase of the EIS at the national 
level,  they  saw  it  as  an  investment  for  the  future.  They  noted  that  digitalisation  has 
resulted  in  increased  efficiency  and  speed  and  had  reduced  cost  and  administrative 
burden. It has also reduced errors and falsification by making processes more transparent. 
They  mentioned  automatic  clearance  as  an  important  development  in  that  regard.  Yet, 
economic  operators  also  noted  that  the  IT  environment  has  become  more  complex, 
resulting in additional burdens and technical difficulties. In particular, the increased focus 
on  risk  control  procedures  (that  stem  from  Union  law)  has  resulted  in  additional  data 
requirements and obligations.  

o  Relevance 

Both  individual  economic  operators  and  EU-level  organisations  representing  economic 
operators  agreed  that  the  programme  continues  to  be  both  relevant  and  necessary.  EU-
level organisations representing economic operators considered that Member States were 
increasingly  “on  the  same  page”  and  that  this  was  due  to  a  large  extent  to  the 

128 The economic operators are generally liable for the declarations, although there are cases where they are 
not aware of or have no expertise to assess whether goods had been undervalued or counterfeited. This 
was specifically linked to the issue of e-commerce, which exacerbated opportunities for fraudsters to 
abuse the small consignment exemptions. 

95 

 
                                                           
programme’s activities. They also recognised that there was flexibility in the application 
of Union law in the context of the COVID-19 pandemic and the UK’s departure from the 
EU.  However,  several  highlighted  that  the  situation  could  have  been  handled  more 
swiftly at the beginning. 

Both  individual  economic  operators  and  EU-level  organisations  representing  economic 
operators also noted that there was still a need to further simplify and harmonise customs 
processes and procedures to further reduce costs, confirming the continued need for the 
programme.  They  considered  that  the  EU  should  keep  being  a  frontrunner  in  customs 
legislation  and  controls,  but  that  it  also  needs  to  investigate  innovative  techniques  that 
would  improve  the  EIS  for  customs  by  making  them  faster  and  simpler  to  operate. 
Mobile  technology,  Bluetooth,  Wi-Fi  connectivity,  digital  documents  and  blockchain 
technology  were  among  the  tools  identified  as  needing  to  further  explore.  Economic 
operators  also  demanded  a  more  proactive  engagement  and  communication  with  the 
business  sector, as  well  as better provision of information  to  business,  earlier on in  the 
process. 

  Consideration for the evaluation 

Feedback  from  representatives  of  EU-level  organisations  representing  economic 
operators was integrated into the findings on the effectiveness, efficiency, relevance, and 
EU added value of the programme. However, some of the views above related to Union 
law  and  policy  more  generally,  and  therefore  only  indirectly  to  the  Customs 2020 
programme, and this caveat was made in the presentation of the findings where relevant. 
Some  of  the  “needs”  that  economic  operators  mentioned  in  relation  to  the  interview 
questions  on  relevance  have  been  integrated  into  the  answers  on  effectiveness  and 
efficiency  where  this  was  more  appropriate.  Moreover,  as  the  programme  has  been 
engaging  mostly  with  representatives  of  organisations  representing  economic  operators 
(TCG members), individual economic operators’ views were more critical in terms of the 
extent  to  which  they  had  been  able  to  engage  with  the  programme  or  had  a  limited 
awareness of it. This also led to the identification of some lessons learnt in relation to the 
engagement with economic operators.  

96 

 
 
 
 
ANNEX  VI.    ASSESSMENT  OF  THE  IMPLEMENTATION  OF  THE  RECOMMENDATIONS  OF 
THE MIDTERM EVALUATION  

Table 12: Implementation of the recommendations on programming and design 

RECOMMENDATION 

UNIT'S PROPOSED MEASURES 

STATE OF PLAY IN 
MARCH 2022 

PROGRAMMING AND DESIGN 

Summary: 
Make more practical use of the Annual Work 
Programme projects and consider multi-annual 
programming. In the short term this could mean 
more discussion of the projects, while in the 
longer-term (as is already proposed for the next 
funding period) multi-annual programming 
would help increase coordination. 

Detail: 
In the short term, DG TAXUD could make the 
projects come to life simply by referring to and 
discussing them more regularly (and based on ad-
hoc needs) with national coordinators, DG 
TAXUD officials and other users of the 
programme. Setting up common PICS groups for 
relevant actors could also be considered. 
Knowledge sharing around the identified policy 
projects could also increase their relevance.  

In the longer term (as is already proposed for the 
next period) we recommend that a multi-annual 
programming process is put in place that would 
correspond better to the nature the programme 
and the activities it supports. Such a multi-annual 
process could be flexible, setting broad priorities 
that are still operationalised in annual 
programmes, with some contingency for 
emerging needs. This would help further increase 
the coordination between activities, improving 
the quality of planning documents and their 
practical implementation as well as the 
programme’s coherence.   

1 

1.1  Reinforce the strategic, objectives-

Implemented 

oriented planning of actions, and consider 
more top-down actions planning.  

1.2  Communicate  clearly  on  the  strategic, 
objectives-oriented  planning  of  actions,  by 
setting  up  project-based  and  content-oriented 
newsletters on evolutions/highlights, including 
executive  summaries  and  activity  schemes 
(e.g.  quarterly,  or biannually)  within  TAXUD 
and to Participating Countries 

1.3 Establish multiannual work programmes in 
the  post-2020  Regulations  and  investigate  the 
options  for  breakdown  of  work  programme 
periods in the financing period of 7 years (e.g. 
2+3+2 or 2+2+3) 

Implemented 

Implemented 

1.4 Create national strategies and priorities for 
programmes’ 

participation 

in 

the 
activities.   

Partially implemented 

Summary:  
Designate long-term, platform-like joint actions as 
such, so that appropriate criteria can be defined for 
funding  applications  and  monitoring  of  such 
actions. 

2 

Detail: 

2.1 Identify current long-term (platform like or 
similar) activities and collect their key 
functions (by nature and content)  

Implemented 

97 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
are 

defined,  we 

the  operational  details  of 

the  next 
When 
programme 
recommend 
categorising  platform-like  project  groups  as  such, 
and  defining  and  applying  appropriate  criteria  for 
funding  applications  and  monitoring.  This  would 
make  it  easier  to  take  funding  decisions  about 
these actions, gauge success and learn lessons that 
can be used for future improvements.   

2.2 Establish a non-exhaustive list of platform-
like activity types including their definition, 
funding criteria and linked performance 
measurement structures (e.g. platform, 
network, steering group, etc.)  

Implemented  

3 

4 

Summary:  
Refine strategy for development and promotion 
of eLearning modules, so that the training 
programme addresses identified needs. 

Detail:  
We recommend developing a strategy based 
more on addressing identified training needs. A 
first step could be an initial survey conducted 
with the help of the Training Support Group to 
take stock of needs and interest. Leading from 
this, a strategy could be devised, ideally for 
multiple years, listing priorities to be taken up 
in future training modules and promotional 
plans. Importantly, this could mean prioritising 
those countries whose needs and likelihood to 
actually use the modules are greatest. 

3.1 Deepen consultation with national 
administration’s training managers (TSG and 
beyond) to identify specific national support 
needs in ‘training and staff development’ that 
go beyond the already established and agreed 
processes and topics. This may be realised 
through EU workshops/events (including 
online surveys) that are specifically dedicated 
to the exploration of such further-going 
national needs.  
In consequence, the roll-out and 
implementation of the current multi-annual 
Strategic EU Training Action Plan (2017 – 
2020) may be adapted to resulting findings.  

3.2 Integrate identified national training/staff 
development needs and topics (for eLearning 
development and other formats) strategically 
with the future-envisaged multi-annual work 
programmes of the post 2020 programmes. 

Summary:  
Investigate ways to improve the technological 
platform for the delivery of eLearning 
modules, based both on solutions on the 
market and best practices and synergies from 
other Commission services and initiatives.   

Detail:  
We recommend exploring alternative solutions 
that currently exist on the market which could 
meet national administrations’ needs in terms 
of security, limited distribution, central 
management and flexibility.   
Best practices and synergies could also be 
identified with other Commission services and 
initiatives such as for e.g. the World Customs 
Organisation’s Learning and Knowledge 
Community (for Customs) or the OECD 
(Fiscalis). 

4.1 Assess the feasibility of an EU-level 
electronic platform (type: Learning 
Management System – LMS) with regard to its 
potential added value in supporting the 
development and delivery/publication of EU 
eLearning materials. Compatibility with 
national LMS applications and e-training 
portals of other Commission 
services/initiatives will be a key criterion.  

4.2 Piloting a set of identified relevant online 
platform support functionalities on a pilot 
LMS application that has proven its suitability 
on the market, with national administrations 
and/or other Commission Services/Learning 
Institutes (e.g. Moodle). 

Postponed  

Postponed 

Implemented 

Implemented 

4.3 Develop and rollout an EU electronic 
Learning Environment (ELE) to support 
training and staff development of customs and 
tax professionals across the Union (post 2020 
programme).  

Implemented 

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
Implemented 

Partially implemented 

5.1 Introduce ‘central localisation’ concept as 
the by-default procedure for 
translation/localisation of EU eLearning 
modules. This way, translation costs and 
related efforts are shifted back from national 
administrations to the Commission services 
(under 2020 programmes), which is supposed 
to considerable lighten the work part of 
national administrations in 
translations/localisation projects and shorten 
drastically the duration the development of 
national versions of EU eLearning modules. 

5.2 Assess, test and introduce further resource-
friendly mechanisms, tools and processes that 
are best-suited to enhance the efficiency and 
effectiveness of the development and use of 
common EU eLearning modules and related 
translated/localised versions, such as e.g. use 
of electronic voice (versa current human actor 
voice) or short learning modules 
(micro/nanolearning modules) etc. 

5 

Summary:  
Improve the procedures for the translation, 
localisation and updates to eLearning modules. 
This could lead to quicker localisations and 
updates, and solutions that are more tailored to 
the needs of individual countries. 

Detail:  
We recommend prioritising an agile and 
flexible management of eLearning modules, 
focused on improving the procedures for the 
translation of the modules and on facilitating 
quick localisation and updates of the training 
material. In relation to translation of the 
eLearning modules, we suggest 
communicating more clearly that national 
administrations can request at any moment the 
localisation of an EU eLearning course through 
the signature of partnership agreements with 
the Commission, and that no requests have 
been turned down in the current programming 
period. If national administrations miss the 
window of opportunity for the translation of a 
given module, it is purely because of national 
limitations.  
In relation to localisation and updates to the 
eLearning modules, alternative strategies 
should be investigated to facilitate changes in 
the content of the modules to reflect local 
characteristics as well as emerging issues, such 
as new legislation, changes in IT systems and 
guidelines. 

IMPLEMENTATION 

Summary:  
Increase coordination with other EU 
programmes, both in terms of operational 
coordination with the Fiscalis programme and 
establishing a forum for working with other 
Commission Directorates-General. 

6.1 Investigate opportunities to streamline and 
simplify the establishment and implementation 
of cross Customs and Fiscalis programme 
actions, especially where similar 
methodologies can be followed (e.g.: 
competency framework for customs and 
competency framework for taxation). 

Implemented  

6 

Detail:  
In relation to Customs and Fiscalis 
cooperation, we recommend that the two 
programmes explore opportunities to enhance 
operational coordination and the sharing of 
information on shared components, including 
IT systems and approaches for human 
competency building and training. The Multi-
Annual Strategic Plan for Customs EIS and the 
EU Competency Framework for Customs 
should serve as baselines and examples for the 
development and implementation of these 
initiatives under Fiscalis. Flagship Fiscalis 
initiatives should also be identified that could 

6.2(a) Collect and examine all EU funding 
programmes and list those that have links with 
the Customs and Fiscalis programmes, 
including the future Customs Control 
Equipment Instrument (CCEI) 

Implemented 

6.2(b) Collect and examine all other 
programmes (e.g. by international 
organisations, Frontex, CCWP), including the 
future Customs Control Equipment Instrument 
(CCEI), and list those that have links with the 
Customs and Fiscalis programmes. 

99 

 
 
 
 
 
 
 
 
 
 
 
6.3 Flag the need for a COM-level network 
and steering body for customs and taxation 
related funding activities especially in view of 
the possibility for combined funding under the 
post-2020 funding period.  

Discarded 

be taken as examples in Customs.  
In relation to Customs/Fiscalis cooperation 
with other Commission DGs, while 
acknowledging that officials in DG TAXUD 
and other DGs are already burdened with 
meetings and other obligations, we recommend 
that a common coordination forum is 
established between relevant officials in DG 
TAXUD, DG GROW, DG HOME, TRADE 
DG ECFIN and OLAF in particular. This could 
start with a single meeting and evolve as 
appropriate, with a view to establishing more 
formal links and identifying and exploiting 
more links where possible. 

6.4 Set up bilateral and multilateral working 
arrangements within TAXUD and with other 
DGs regarding the implementation of the post-
2020 programmes 

Partially implemented 

6.5 Establish the Multi-Annual Strategic Plan 
for Taxation (MASP-T) on the example of the 
MASP-C 

Implemented 

6.6 Review TAXUD programme 
implementation coordination and governance 

Implemented 

Implemented 

7.1 Map and review programme processes for 
joint actions, with focus on the programing 
and implementation features and tasks, 
including financial management. Identify 
elements for streamlining, simplification and 
modernisation with a view to establishing 
proportionate administrative processes for all 
joint actions.  

7.2 Review the strategic coordination role and 
related positioning of the national programme 
coordinators in the participation of national 
administrations in the programme activities.  

7.3 Optimise the use of physical meetings: 
map options for virtual meetings, promote 
their use and set conditions for real-life 
meetings.  

7.4 Establish a change management plan, 
including communication activities.  

Implemented 

Implemented  

Partially implemented  

Summary:  
Optimise the procedures and resources for the 
implementation of joint actions, so that the 
workload for available human resources and 
administrative burdens on different actors are 
appropriate. 

Detail:  
We recommend that DG TAXUD, where 
appropriate involving the national 
coordinators, review the workload on the 
available human resources, the steps for 
applying for and reporting on joint actions, 
with the aim of establishing more effective and 
efficient administrative processes and reduce 
the workload on staff. This could involve the 
introduction of a project-based approach 
(replacing an event-based management) 
resulting in the reduction of micro management 
and related administrative burden. The central 
and national programme management levels 
could also produce easy-to-use guides and 
templates to lighten the burden. 

7 

100 

 
 
 
 
 
 
 
 
 
MONITORING AND REPORTING 

Summary:  
Streamline  the  monitoring  system  so  it  meets 
actual  needs  while  reducing  administrative 
burdens.  This  could  include  both  quick  fixes 
like simplified forms  and a study to refine and 
reduce the number of monitoring indicators. 

8.1  Simplification  of  the  Action  Follow-up 
Forms and Event Assessment Forms.  

Implemented 

8 

to 

on 

and 

and 

less 

lead 

should 

overlaps 

numerous 

time-consuming 

programme  managers 

Detail:  
A  simplified  framework  could  be  both  more 
useful 
for 
stakeholders.  In  the  short  term,  DG  TAXUD 
could  put  in  place  some  quick  fixes  to  reduce 
burdens 
and 
participants. For example, the action-follow-up 
form  and  event  assessment  form  could  be 
simplified  so  as  to  place  a  smaller  burden  on 
participants. DG TAXUD could also focus on a 
limited  number  of  core  indicators  rather  than 
reporting  equally  on  all  of  them,  especially 
given 
some 
inconsistencies.  
We also recommend that DG TAXUD conduct 
an evaluation of the performance measurement 
framework  to  assess  the  monitoring  system  in 
specific 
detail.  This 
recommendations  to  reduce  the  number  of 
indicators  and  eliminate  irrelevant  indicators 
and  overlaps  in  order  to  ultimately  lighten 
administrative  burdens  and  establish  firmer 
links  between  monitoring  and  performance 
management.   
Since  indicators  at  impact  level  relate  more 
directly  to  specific  customs/taxation  policies 
than  to  the  programme,  a  small  set  of  impact 
indicators  has  been  defined  for  data  collection 
during  monitoring  and  evaluation  of  these 
policies.  In  theory,  the  data  collected  should 
then  be  made  available  to  the  programme 
management  unit  to  feed  into  the  monitoring 
system.  However,  for  this  to  work,  the  impact 
indicators,  monitoring  and  evaluation  of 
relevant policies will need to be used to collect 
data  on 
regular  and 
sufficiently  frequent  intervals.  The  evaluation 
of  the  Performance  Measurement  Framework 
should  assess 
this  challenge  and  propose 
recommendations for tackling it.  
Other changes are also worth exploring. For 
example, some surveys and satisfaction forms 
could be replaced by less frequent (but more in-
depth) consultations with key stakeholders. 
Electronic tools for data collection, analysis, 
and presentation (such as automatically 
updating dashboards) could reduce the effort 
needed for these tasks while making the reports 
more timely and usable. Since much of the 
programme’s achievements rely on networking, 
coming up with indicators on this should be a 
priority. 

indicators  at 

these 

8.2  Share  the  feedback  from  participants  to 
an event (EAFs) with the action managers 
(from  participating  countries  or  from 
to  enable  a  more 
TAXUD’s  units) 
evidence-based 
at 
decision-making 
operational level. 

8.3  Launch 

a 

to 

study 

the 
Performance  Measurement  Framework 
(PMF)  with  a  view  to  simplify  it.  In 
particular, the study will consider: 

evaluate 

Implemented 

Implemented 

  Reduce 

the  number  of 

indicators, 
for 
the  most 
focusing  on 
monitoring  progress  of  the  programmes 
(e.g. EIS, networking) 

relevant 

  Reconsider  the  approach  for  measuring 

impact (see also point 8.4) 

  Revise  data  collection  tools:  forms  to 
from 
to  be 
and 

gather 
managers/participants 
streamlined; 
revise 
coverage 

  have 
frequency 

feedback 

  Adapt  the  PMF  to  the  new  approach  for 

actions (based on projects).  

8.4  Create  an  SG 

the  PMF  study 
for 
involving  all  associated  TAXUD  units 
and other DGs 

Implemented 

8.5  Communication  on  the  need  to  establish 
specific 
monitoring 
policy  measures  allowing 
for  more 
systemised  collection  of  policy-relevant 
indicators 

frameworks 

for 

8.6  Stronger emphasis for correct preparation 
of  the  future  monitoring  and  evaluation 
impact 
provisions  at 
assessments 
policy 
initiatives  supported  by  C2020  or  F2020 
programmes.  

the 
accompanying 

time  of 

Implemented 

Implemented  

101 

 
 
 
 
 
 
 
 
 
Summary:  
Develop a more coherent approach to assessing 
programme performance to reduce burdens and 
lead to more purposeful reports. 

Detail:  
While certain requirements are fixed, the 
options to minimise the burden on national 
administrations of providing information, data 
and other contribution should be explored. 
Such options include: 
- Combine the impact assessment / ex ante 
evaluation of future funding periods with the 
mid-term evaluation of the current period, 
which several DGs (such as DG Education and 
Culture) have done successfully.  
- Make the mid-term evaluation lighter, 
focused more on operational matters and 
implementation. This could be sensible, 
especially considering that many impacts 
cannot be identified at such an early stage of 
implementation.   
- Combine studies related to the Customs and 
Fiscalis programmes. This would build on the 
coordinated approach taken to the present mid-
term evaluations and further reduce overlap 
and the duplication of administrative and other 
work as well as helping to generate synergies 
between the programmes.  
- Undertake more evaluations focused on 
policy-related issues, and use their results to 
inform smaller, more focused evaluations of 
the programme. Each policy evaluation in the 
customs / taxation area, particularly areas that 
draw from the programme support, should 
regularly and specifically examine the role of 
the Customs / Fiscalis programme, including 
the programme-funded IT systems. Successive 
programme evaluations have provided 
evidence that the programme is successful and 
that major changes are not required. What 
could be more relevant would be the 
assessment of key policies and how well the 
various programme instruments and activities 
support them. 

9 

8.7  Mid-term  evaluations  of  the  programmes 
combined  with  impact  assessment  for  the 
future  proposals  (back-to-back  approach, 
tool  #52  of  the  BR).  However,  feasibility 
is  dependent  on  corporate  timelines  for 
these exercises. 

8.8  Use  the  synergy  between  the  Annual 
the  Mid-term 
Progress  Report  and 
evaluation for the year when the mid-term 
evaluation  should  be  carried  out  in  order 
to  avoid  duplication  of  efforts.  The  focus 
should  be  on  programmes’  management 
aspects and not on policy areas benefiting 
from the programme. This would result in 
producing  a  single  report  to  cover  both 
regular  monitoring  of  the  programme  as 
well as lessons learned from the first years 
of implementation.  

8.9  For  operational,  management  and 

IT 

infrastructure, 

the 
common 
consider 
combining studies touching upon both the 
Customs  and  Fiscalis  programmes  (for 
example  any  studies  on  the  Performance 
and  Monitoring  Framework,  the  training 
aspects  or  the  common  IT  tools).  Same 
approach  for  policy  areas,  where  relevant 
and feasible.   

8.10 Update  of  the  Evaluation  and  Impact 
Assessment Charter with a view to make it 
more  explicit 
that  policy  evaluations 
should  cover,  amongst  other  topics,  the 
measurement  of  the  effect  of  programme 
funded activities   

8.11 Update of: 
 

 

study 

the  collaborative  space  for  evaluations  to 
flag  out  the  importance  of  including 
aspects related to the Fiscalis and Customs 
programmes 
in  evaluations  of  policy 
measures supported by the programme 
the 
a 
include 
fiche 
“Customs/Fiscalis-financed/relevant”  box, 
in case the programmes have financed any 
activities  in  their  area  of  interest.  In  this 
way, the operational units would be aware 
from the start of the project that they need 
to  also  ask  the  contractors  to  look  at  the 
consequences of the financing provided by 
the programmes.  

to 

8.12 Regular 

the 

request 

inclusion  of 

to 
examine the Fiscalis and Customs role and 
support  in  the  Terms  of  Reference  for 
contracts  commissioning  evaluations  or 
impact  assessment 
related  studies  of 
policy  measures  supported  by  the  two 
programmes  

Relevance under the 2021-
2027 programming period’s 
interim evaluation in 2024-
2025 

Relevance under the 2021-
2027 programming period’s 
interim evaluation in 2024-
2025 

Partially implemented  

Implemented 

Postponed 

Implemented 

8.13 Communication  on  the  need  to  assess 
aspects related to the Fiscalis and Customs 
programmes 
in  evaluations  of  policy 
measures  supported  by  the  programme 
during the TAXUD training on evaluation 

Implemented 

10 

Summary: 

9.1  Map  all  programme  processes  and 
identify  elements  where  supporting  tools 

Implemented 

102 

 
 
 
 
 
are required 

9.2  Review and evaluate all functionalities of 
ART and PICS (and also CIRCABC, EU 
Survey, etc.)  

9.3  Improve the knowledge sharing via PICS 
evolutional  upgrades  in  short  term,  e.g. 
by  completing  the  Programmes  Output 
Group project.  

9.4  Improve  the  reporting  functionality  of 
ART,  by  including  the  Expert  Teams 
reporting.  

9.5   Launch  an  external  study  in  order  to 
identify available tools in the market that 
could  cover  the  functionalities  of  ART 
and  PICS  and  possibly  replace  them  in 
the next future.  

Implemented 

Implemented 

Implemented 

Implemented 

Improve  reporting  and 
information-sharing 
tools,  so  that  these  can  be  made  more  user-
friendly  while  still  meeting  demands  for 
security and functionality. 

Detail: 

We  recommend  that  DG  TAXUD  conduct  an 
(internal  or  external)  audit  of  these  tools  and 
their  use  and,  based  on  the  results,  decide  on 
next  steps.  Given  shifting  security  and  file-
sharing  needs,  PICS  in  particular  could  be 
either revamped or replaced, while ART could 
be refined so that its formidable functionalities 
are made more user-friendly.   

Any  changes  should  then  be  communicated  in 
an  accessible  way  to  stakeholders  in  the 
Commission  and  administrations,  particularly 
the  national  coordinators  who  are  responsible 
for  sharing  information  about  the  programme 
among  potential  joint  action  and  training 
participants.  Such 
could 
include  online 
tutorials  as  well  physical 
training sessions as appropriate. 

communication 

COMMUNICATION 

11 

12 

Summary:  
Increase senior level buy-in and political will 
among national administrations to boost 
participation and engagement. 

Detail:  
We recommend that the senior leadership of 
national administrations engage more actively 
with the programme, with a view to expressing 
any concerns or needs that are not being met 
and helping DG TAXUD to address them. 
National coordinators, as the ‘ambassadors’ of 
the programme in their respective countries, 
have a particular role to play in communicating 
about the programme throughout their 
administrative hierarchies. This is especially 
true in candidate countries, some of which 
participate relatively little in the programme. 

11.1 Review the programmes communication 
strategy and include a specific section (series 
of actions) targeting the senior management of 
the national administration.  
In support of the actions develop a consistent 
message (stressing the importance of 
participation and engagement) and ensure that 
it is properly communicated – e.g. by 
including it systematically in briefings. 

11.2 As part of the communication strategy 
and in order to develop the targeted 
communication actions, identify all events and 
fora (visits, forums, conferences, meetings etc. 
such as Customs Policy Group, TADEUS, 
ECNTC etc.) where TAXUD senior 
management meet/interact with their peers 
from national administrations. Use the 
briefings supporting the meetings in order to 
pass on messages relating to the programmes.  

Partially implemented 

Implemented 

12.1 Create policy-based and content-oriented 
(e.g. 
newsletters  on  evolutions/highlights 
quarterly,  or  biannually)  within  TAXUD  and 
to MS/PCs  

Postponed 

Summary:  
Communicate more actively about the 
possibilities of the programme, with national 
coordinators and other officials taking a more 
active role in finding out about and spreading 
awareness of the programme. 

Detail:  
We  recommend  that  national  coordinators  and 
other  officials  take  a  more  active  role  in 

103 

 
 
 
 
 
 
 
Postponed 

Implemented 

Postponed 

finding  out  about  and  spreading  awareness  of 
the possibilities of the programme within their 
administrations.  Relevant  action  could  range 
from  sharing  materials  produced  by  DG 
TAXUD on local intranets and translating such 
materials  to  organising  information  sessions 
and  asking  other  administrations  for  success 
stories and other forms of assistance.  

Summary:  
Review strategy for dealing with economic 
operators and citizens, with a view to arriving 
at a common understanding of whether and to 
what extent actors beyond administrations 
should be targeted. 

Detail:  
We recommend that DG TAXUD review the 
communication strategy for the programme, 
with a view to arriving at a common 
understanding of whether and to what extent 
actors beyond administrations should be 
targeted. This could include some intermediate 
action, such as surveying certain subsets of 
economic operators to gauge needs and 
interest. Later on, DG TAXUD could decide 
whether any Customs / Fiscalis branding 
would be appropriate, and design activities for 
reaching given types of stakeholders. 

13 

targeting 

(series  of  actions) 

12.2  Review  the  programmes  communication 
strategy  and  tools  and  include  a  specific 
the 
section 
national  coordinators.  Ensure  synergies  and 
efficiencies  with  the  TAXUD  communication 
strategy. As part of the plan: 
-  clarify  the  purpose  and  the  role  of  the 
national  coordinators  in  raising  awareness  on 
the programme activities; 
-  provide  the  national  coordinators  with  a 
communication  toolbox  (set  of  tools  provided 
at  their  disposal  in  order  to  achieve  the 
objective of the recommendation) 
- 
evidence/contributions 
coordinator. Use it to raise awareness.  
-  investigate  the  need  to  set  coordinators 
network  at  national  level  (similarly  to  the 
current  coordinators  network  at  EU  level)  to 
raise awareness and encourage participation 
- consider the possibility to create programme 
easily 
identity 
communication 
recognisable  (branding,  marketing  tools)  and 
provide it to national coordinators, in line with 
Art.20.2  of 
future  Grant  Agrements  on 
“Visibility of funding”. 

with 
from  each  national 

compile 

success 

stories 

that 

is 

the 

awareness 

specifically 

12.3  Extend  the  next  Programmes’  Poll  to 
check 
and 
satisfaction among tax/customs officials – this 
will  not  only  test  the  knowledge  of  the 
programmes,  but  it  will  also  further  raise 
awareness and help prepare a plan to fill in the 
knowledge gaps accordingly. 

targeting 

(series  of  actions) 

13.1  Review  the  programmes  communication 
strategy  and  tools  and  include  a  specific 
section 
the 
economic  operators  and  citizens.  Ensure 
synergies  and  efficiencies  with  the  TAXUD 
communication strategy. As part of the plan: 
-  make  use  of  social  media  in  order  to  reach 
economic  operators  and  citizens  as  the  most 
efficient way   
- identify and make use of the existing 
TAXUD forums where economic operators 
and citizens are represented. E.g. Platform for 
Tax Good Governance. Compile a list of such 
events (establish an annual events calendar for 
TAXUD) and ensure a consistent 
communication message that should be 
systematically conveyed. Linked to action 11.2 
- consider the use of surveys as both 
communication and needs identification tool 
- consider the possibility to create programme 
communication identity which is easily 
recognisable (branding, marketing tools)  

Postponed 

13.2 Meet with trade and civil society 
associations in the various fora where they may 
have an interest in the programmes’ activities 
(such as the Trade Contact group, the Platform 
for Tax Good Governance, amongst others) in 
order to identify communication opportunities 
and to establish an effective communication 

104 

 
 
 
 
 
 
channel with economic operators and citizens.  

Source: DG TAXUD 

105 

 
 
 
ANNEX VII.  KEY FEATURES OF CUSTOMS EIS AND JOINT ACTIONS 

Table 13 Description of EIS for customs 

EIS for customs 

Description of the system 

TARIC 

QUOTA 2 

EBTI3 

EU CSW-CERTEX  

Multilingual  database  in  which  all  measures  relating  to  EU 
customs  tariff,  commercial  and  agricultural  legislation  are 
integrated.  The  tariff  system  is  a  reference  data  system  for 
other EIS.  

The electronic system for quota management/allocation tracks 
the overall EU usage of "First come first served" import quotas 
in  force  granted  to  products  originating  from  certain  third 
countries.  

A Binding Tariff Information (BTI) is a decision issued by the 
customs  authorities  that  is  binding  on  all  Member  States' 
customs  authorities  and  on  the  holder  of  the  decision.  The 
European Binding Tariff Information-3 system (EBTI-3) is the 
IT  system  by  which  applications  are  submitted  and  BTI 
decisions 
issued  and  managed  (i.e.  revoked).  All  BTI 
applications  and  BTI  decisions  are  stored  in  this  database 
(hereinafter the "EBTI-3 database") managed by the European 
Commission.  

participating 

customs 
connects 
EU  CSW-CERTEX 
authorities’  national  systems  to  EU  databases  managing 
supporting  documents  related  to  non-customs  requirements, 
such  as TRACES  .  EU  CSW-CERTEX  enables  customs 
authorities to  automatically verify the respective  non-customs 
formalities.  This  means  that  when  an  economic  operator 
submits  a  customs  declaration  requiring  the  compliance  with 
Union  non-customs  law,  customs  and  partner  competent 
authorities  can  automatically  and  effectively  exchange  and 
verify  the  required  information  for  the  customs  clearance 
process.  

Direct  trader  access 
EIS 
the 
to 

Ensures  the  uniform  authentication  and  authorisation  of 
economic  operators,  enabling  their  direct  unified  access  to  a 

106 

 
 
(UUM&DS):   

Customs Decision 
System (CDS):  

Customs Risk 
Management System 
(CRMS) 

SURV3  

Import Control 
System 2 (ICS2) 

number of central Customs EIS, by federating MS Identity and 
Access Management systems.   
The  UUM&DS  links  to  central  systems,  such  as  the  CDS, 
EORI or AEO systems, which are operated at the EU level.  

It is a system for all new applications for customs decisions or 
authorisations  in  an  electronic  way.  It  allows  economic 
operators  to  apply  for  and  manage  their  customs  decisions 
through  a  single  EU  interface  and  enables  national  customs 
authorities 
the  granting  and 
management of authorisations that are valid in more than one 
Member  States.  It  provides  system-to-system  access  for 
import,  export  and  transit  systems  to  authorisation  data, 
allowing to automatically check their existence and validity.  

to  consult  each  other  on 

The CRMS  facilitates the exchange of information for risk 
management purposes.  

It  centralises  in  one  place  the  relevant  information  related  to 
imports and exports in the EU. SURV3 provides an upgrade of 
the Surveillance 2+ system to ensure its alignment to the UCC 
requirements such as the standard exchange of information by 
electronic data-processing techniques and the establishment of 
adequate  functionalities  needed  for  processing  and  analysing 
the  full  surveillance  dataset  obtained  from  Member  States. 
While  deployed  in  2018,  it  will  not  be  fully  used  until 
December 2022 when all  Member States have upgraded their 
national  import  systems  (gradual  implementation  linked  to 
input from the upgraded national import systems).  

This system aims to strengthen pre-arrival safety and security 
of  goods  entering  the  Union  by  implementing  the  new  UCC 
requirements  regarding  the  lodging  and  treatment  of  entry 
summary  declarations  (ENS),  namely  the  provision  of  ENS 
data in more than one submission and/or by different persons 
and  the  exchange  of  that  data  and  the  risk  analysis  results 
among  the  customs  authorities.  ICS2  is  implemented  in  three 
releases, the first in 2021, second in 2023, and third in 2024. 

AEO system 

The  upgrade  of  the  AEO  system  aimed  to  improve  the 

107 

 
 
related 

business  processes 
to  AEO  applications  and 
authorisations  considering the changes of the legal  provisions 
of the UCC. The first phase aimed at implementing the major 
enhancements to the AEO system in view of the harmonisation 
to  the  customs  decision  taking  procedure.  The  second  phase 
implemented  in  2019  the  electronic  form  of  the  AEO 
application  and  decision  and  provided  for  the  economic 
operators  an  EU  harmonised  interface  to  submit  the  AEO 
application and receive the decision electronically (eAEO).  

INF SP  has 

This  system  ensures  the  administrative  and  standardised 
exchange  of  information  between  economic  operators  and 
customs  authorities,  and  between  customs  authorities 
themselves involved during the customs procedures of inward 
and  outward  processing.  The 
two  main 
components, which are the INF Specific Trader Portal (STP) – 
accessible through the EU Customs Trader Portal (EUCTP)  – 
and  the  INF  central  system.  It  replaced  the  transitional 
arrangements  for  the  INF  Special  Procedures  in  2020  as 
defined in the UCC Work Programme. The centralised INF SP 
system  is  operational  to  all  Members  States  and  economic 
operators. The main objective of the INF SP System is to make 
all  INF  data available and to  streamline the processes of  INF 
data management. 

Information Sheets 
(INF) for Special 
Procedures (SP) 

Source: DG TAXUD 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
Table 14. Key features of the Customs 2020 joint actions 

109 

 
 
Type of joint 
action 
seminars and 
workshops 

project groups 

working visits 

expert teams 

monitoring 
actions 

Key features 

create unique opportunities for exchange in a group setting and 
compare strategies and methodologies between countries 
provide space for networking, building contacts and reinforcing 
relationships with other national administrations 
gather more expertise (including from external stakeholders such as the 
World Customs Organisation) than would be possible in a national 
setting 
ensure common understanding and interpretation of EU legislation 
improve relevance and focus among participants that share both 
historical and geographical links, and face similar challenges 
allow for in-depth and recurrent group work on specific issues and 
policy areas 
develop concrete solutions to common problems across range of 
policies and practical areas 
strengthen networks and working relationships through continuous 
communication 
pool knowledge and experience between and within participating 
countries as well as with the Commission 
act as catalysts, creating the conditions for the generation of more 
concrete outputs in other fora (such as dedicated project groups) 
many of them are quasi-permanent and serve as standing platforms for 
coordination at various levels 
provide opportunity for focused in-depth exploration of (often defined 
at operational level) topics of mutual interest, often on a bilateral basis 
as this is the only type of action focused mainly on individual 
exchanges 
lead to exchange of information and experience by engaging in real 
working, business-level situations, allowing participating countries to 
reassess their own performance while considering practices of their 
counterparts 
gain inspiration on good administrative and organisational practices or 
approaches from host country to be adopted to national circumstances  
useful for candidate and potential candidate countries to learn about 
EU legislation, national implementation and Member States working 
practices, praised for the direct operational exchanges  
structured form of operational collaboration on topics of mutual 
interest driven by participating countries and enhancing close 
collaboration 
provide a strong mandate and financing to tackle a specific challenge  
identify gaps and lead to recommendations/solutions for improvement 
provide possibility for exchange of experiences and working methods 

110 

 
 
between and within participating countries as well as with the 
Commission 
provide opportunities for joint monitoring visits, including with the 
Commission  
provide technical assistance which targets specific capacity needs  
exploit synergies with the Structural Reform Support Service, which 
provides technical support to administrations 
raise awareness about specific topics among customs administrations 
within and outside the customs union 
supports the development of a communication policy towards national 
stakeholders  
help with coordinating communication and serve as structured thinking 
around future communication needs 
useful to examine specific issues in depth (used for evaluations, impact 
assessments, economic analysis, etc.) 

capacity building 
and supporting 
actions 
joint 
communication 
actions 

studies 

Source: Mid-term evaluation of the Customs 2020 programme  

111 

 
 
 
 
ANNEX VIII.  MEMBER STATES INVESTMENTS IN EIS FOR CUSTOMS  

The  e-Customs  annual  progress  reports  present  Member  States’  expenditure  on  each 
project of the MASP-C129, as reported in their national annual reports to the Commission.  

The figure shows that the total investment fluctuates between EUR 85 million in 2014 to 
almost EUR 180 million in 2020. However, as mentioned in the report, the cited figures 
are not  directly comparable due to  the inconsistent  number of Member States reporting 
over the years, which is respectively presented at the bottom of each bar for all years, in 
which data was collected. 

Figure 10: Member States’ costs related to IT capacity building (2014-2020)130 

€

n
o

i
l
l
i

M

180

160

140

120

100

80

60

40

20

0

2014
(22
MS)

2015
(24
MS)

2016
(25
MS)

2017
(25
MS)

2018
(28
MS)

2019
(26
MS)

2020
(26
MS)

Source: European Commission, 2020 e-Customs annual progress report 

Figure 11 sets out the average cost per Member State for the years 2014-2020. The total 
sum  allocated  by  Member  States  for  each  year  is  divided  by  the  number  of  Member 
States that reported during this timeframe131. As can be seen, the average dispensed cost 
per Member State has only increased since the Customs 2020 programme started in 2014. 

129   This covers customs IT systems and corresponding budgetary resources;  coordination of the systems 
with  other  e-Government  systems;  promotion  and  implementation  of  e-Customs  services  and  Single 
Window; trainings in respect of e-customs systems; consultation with economic operators on various 
aspects of the e-Customs systems and services. 

130   2014: 1 from 22 MS costs  were not reported; 2015: 1 from 24 MS costs  were not reported; 2016: 1 

from 25 MS costs were not reported; 2020: 2 from 26 MS costs were not reported. 

131   The number of Member States that contributed budgetary information is not the same throughout the 
years. Since 2008, between 22 and 28 Member States have reported on their budget allocation, except 
for 2011, when only 12 reports were received. 

112 

 
 
 
                                                           
 
Figure 11: Average Member States’ costs for MASP-C projects (2014-2020) 

€

n
o

i
l
l
i

M

7

6

5

4

3

2

1

0

2014

2015

2016

2017

2018

2019

2020

Source: European Commission, 2020 e-Customs annual progress report 

113 

 
 
 
 
 
ANNEX IX.  LIST OF ABBREVIATIONS 

AEO 

AFF 

ART 

ASEM 

AWP  

BTI 

CCC 

CCEI 

Authorised Economic Operators 

Action Follow-up Form 

Activity Reporting Tool 

Asia-Europe Meeting 

Annual Work Programme 

Binding Tariff Information 

Customs Code Committee 

Customs Control Equipment Instrument 

CCN/CSI 

Common Communication Network/Common Systems Interface 

CCWP 

Customs Cooperation Working Party 

CDS 

CEG 

Customs Decision System 

Customs Expert group 

CEG-DIH 

Customs Expert Group – Data Integration and Harmonisation section 

CELBET 

Customs Eastern and South-Eastern Land Border Expert Team 

CIRCABC 

Communication & Information Resource Centre for Administrations, Businesses & 
Citizens 

CLET 

CPG 

CRMF 

CRMS 

CSM 

CWV 

DG 

Customs Laboratories Expert Team 

Customs Project Group 

Customs Risk Management Framework 

Customs Risk Management System 

Customs Seminars 

Customs Working Visit 

Directorate General 

DG BUDG 

Directorate-General for Budget 

DG CLIMA 

Directorate-General for Climate Action 

114 

 
DG DIGIT 

Directorate General for Informatics 

DG ECFIN 

Directorate-General for Economic and Financial Affairs 

DG GROW 

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 

DG HOME 

Directorate General for Migration and Home Affairs 

DG JUST 

Directorate General for Justice and Consumers 

DG REFORM 

Directorate-General for Structural Reform Support 

DG SANTE 

Directorate-General for Health and Food Safety 

DG TAXUD 

Directorate General for Taxation and Customs Union 

DG TRADE 

Directorate-General for Trade 

EAF 

Event Assessment Forms 

EBTI-3 

The European Binding Tariff Information-3 system 

EC 

ECA 

ECCG 

ECRIS 

ECS 

EIS 

ENI 

EORI 

EOS 

European Commission 

European Court of Auditors 

Electronic Customs Coordination Group 

European Exchange of Criminal Records system 

Export Control System 

European Information Systems 

European Neighbourhood Instrument 

Economic Operator Registration and Identification 

Economic Operators’ System 

EU-LISA 

European Union Agency for the Operational Management of Large-Scale IT 
Systems in the Area of Freedom, Security and Justice 

ETCIT 

Expert team on new approaches to develop and operate Customs IT systems 

EU 

European Union 

EU CSW-
CERTEX 

EU Customs Single Window Certificates Exchange 

EU SWE-C 

EU Single Window Environment for Customs 

115 

 
 
EUCTP 

EU Customs Trader Portal 

FRC 

Financial Risk Criteria 

FRONTEX 

European Border and Coast Guard Agency 

F-gases 

Fluorinated gases 

HLPG 

HS/CN 

ICS2 

High-Level Project Group 

Harmonised System and Combined Nomenclature 

Import Control System 2 

INF SP 

Information Sheets for Special Procedures 

ISG 

IT 

LMS 

Inter-Service Steering Group 

Information Technology 

Learning Management System 

MASP-C 

Multi-Annual Strategic Plan for Customs 

MASP-T 

Multi-Annual Strategic Plan for Taxation 

MEF 

MRA 

NCTS 

OLAF 

ODS  

Monitoring and Evaluaton Framework 

Mutual Recognition Agreement 

New Computerised Transit System   

European Anti-Fraud Office 

Ozone Depleting Substances 

PARCS 

Prohibitions and Restrictions Customs Controls Strategy 

PICS 

PMF 

Programmes Information and Collaboration Space 

Performance Measurement Framework 

QUOTA 

The electronic system for quota management / allocation 

REX 

SIS 

Registered Exporter System 

Schengen Information System 

SPEED 

Single Portal for Entry or Exit of Data 

STI 

Shared Trader Interface 

116 

 
SURV 

SWD 

The surveillance management and monitoring system 

Staff Working Document 

TARIC 

The integrated Tariff of the European Union 

TCG 

Trade Contact Group 

TRACES 

Trade Control and Expert System 

TSG 

UCC 

Training Support Group 

Union Customs Code 

UCC DA 

UCC Delegated Act 

UCC IA 

UCC Implementing Act 

UK 

United Kingdom 

UUM&DS 

Uniform User Management and Digital Signatures 

VAT 

WCO 

Value-Added Tax 

World Customs Organisation 

117