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  COM(2022) 635 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the final evaluation of the Customs 2020 programme {SWD(2022) 363 final}  
 
 
1. 

BACKGROUND 

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 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,  the 
multiannual action programme for customs in the EU, which was established by Regulation (EU) 
No  1294/2013,  is  indispensable  in  supporting  its  implementation.  It  provides  the  necessary 
resources to the functioning of the existing European Information Systems (EIS) for customs (and 
to the development of new ones required for the implementation of the UCC) and to facilitate and 
strengthen cooperation between national customs administrations 

In accordance with Article 18(1) and (3) of Regulation (EU) No 1294/2013, which requires the 
Commission  to  submit  to  the  European  Parliament  and  to  the  Council  a  mid–term  and  a  final 
evaluation report of the Customs programme and states that those evaluations shall be carried out 
by an independent external evaluator, an external study was commissioned to support the  final 
evaluation of the programme. Its results are presented in the attached staff working document and 
constitute the basis for this report.  

This  final  evaluation  builds  on the mid-term  evaluation of the Customs programme which was 
published  in  2019.  Its  purpose  is  to  assess  the  Customs  2020  programme  since  its  launch  on 
1 January  2014  up  to  its  end  on  31  December  2020.  The  evaluation  takes  into  account  the 
programme’s full range of funded activities and stakeholders. 

In line with Article 18(1) of Regulation (EU) No 1294/2013, the current report presents the results 
of the final evaluation on: (i) the progress made in the achievement of the programme’s objectives; 
(ii) the cost-efficiency of the different activities funded; (iii) the coherence of the programme and 
its  contribution  to  the  EU’s  broader  policies  and  priorities;  (iv)  the  continued  relevance  of  the 
programme; and (v) the added value of acting at EU level. Long-term impacts and the sustainability 
of the effects of the Programme have been considered throughout the analysis.  

2. 

EFFECTIVENESS 

The general objective of the programme is to support the functioning and modernisation of the 
Customs Union by means of cooperation between participating countries, their customs authorities 
and their officials.  

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); 

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The evaluation confirmed that the Customs 2020 Programme was a key instrument to support the 
implementation and consistent application  of the new customs legislative framework (UCC). It 
has been especially important in the progressive development and functioning of the European 
information  systems  (EIS)  for  customs,  creating  a  collaborative  IT  environment,  where 
customs authorities work together and share supply chain data and risk-relevant information.   

The customs EIS funded by the programme have provided the means for an automated, solid and 
reliable exchange of data between national customs administrations and with economic operators 
and  other  governmental  authorities.  The  number  of  messages  exchanged  between  the  customs 
administrations through the secure platform supported by the programme increased continuously 
since  2014,  reaching  around  8.4  billion  only  in  2020.  Certain  information  exchanges  with 
economic operators have improved significantly through the implementation of the EU Customs 
Trader Portal and specific trader portals of certain systems2. These portals have centralised access 
to several customs EIS and thus allowed data exchange between customs authorities and economic 
operators in a uniform way. They provided services for economic operators to submit applications 
and additional information and to receive notifications from the customs authorities. Information 
exchange  with  other  governmental  authorities  was  promoted  through  the  EU  Customs  Single 
Window Certificates Exchange (EU CSW-CERTEX) system, which connected national customs 
systems  of  participating  countries  to  EU  databases3  managing  supporting  documents  related  to 
non-customs requirements, such as Common Health Entry Documents, FLEGT licences for the 
import of timber and timber products and certificate of inspection for organic products.  

The Customs 2020 programme joint actions were an instrument for exchanging knowledge and 
good practices between customs authorities and with other governmental authorities within the 
participating countries. Through all types of joint actions, including expert teams (a new tool that 
supports enhanced operational cooperation on a regional or thematic basis), the programme has 
helped to develop guidelines and to identify, disseminate and take up  best practices, leading to 
improved working methods and a more consistent and harmonised application of Union law on 
customs and related matters. Joint actions have also helped in the preparation of new legislative 
initiatives, such as the proposal for a Regulation on the EU Single Environment for Customs4, 
thus contributing to the modernisation of the Customs Union and a better functioning of the Single 
Market.  

The Customs 2020  training activities have played  an important  role  in supporting  a more 
coherent  application  of  the  new  customs  legislative  framework  (UCC),  which  entered  into 

2   Authorised Economic Operator system, European Binding Tariff Information-3 system and Information Sheets 

for Special Procedures 

3  

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

4   COM (2020) 673 final 

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application during the funding period. This has facilitated its understanding among both customs 
authorities  and  economic  operators,  contributing  to  a  smoother  implementation.  Together  with 
several joint actions, training activities have also provided guidance in the preparation of the UK’s 
withdrawal from the European Union.  

The Customs 2020 programme has built trust between customs administrations and their officials 
and  has  promoted  working  relationships  and  exchanges  that  continued  beyond  the  specific 
programme  activities.  However,  these  networking  opportunities,  which  have  always  been 
considered  a  key  element  of  the  programme,  have  somewhat  decreased  with  the  COVID-19 
pandemic, raising the need to reassess how to optimise the use of face-to-face and online meetings, 
as well as to explore more appropriate platforms and/or channels that can ensure that networking 
continues  through  virtual  means,  to  replace  or  complement  what  were  common  ways  of 
networking.  

Based  on  the  above,  the  evaluation  showed  that  the  Customs  2020  programme  had  a  positive 
impact on the functioning and modernisation of the Customs Union and the internal market, 
in  turn  supporting  legitimate  trade  and  preventing  illegal  activities.  The  programme  has 
supported legitimate economic activities in various ways. First, the digitalisation of customs 
procedures funded by the programme has simplified and harmonised some of them (and is 
expected to continue to do so as more systems become operational) thereby reducing compliance 
costs and increasing legal  certainty  for traders,  ultimately strengthening  the competitiveness  of 
European  businesses.  Second,  training  materials  available  to  both  customs  authorities  and 
economic  operators  have  also  supported  that  objective.  In  addition,  the  best  practices  resulting 
from joint actions have contributed to improving the conditions and procedures for undertaking 
trade.  

However, as already mentioned, digitalisation is still an ongoing process and some of the IT 
systems  envisaged  in  the  UCC  have  not  yet  been  developed  or  updated5,  delaying  the 
materialisation  of  expected  benefits.  Consulted  economic  operators  see  scope  for  more  trade 
facilitation  in  general  and  have  voiced  the  challenges  related  to  the  complexity  of  the  IT 
environment,  the  staggered  development  of  national  components  by  Member  States  and  the 
insufficient  communication  thereof.  Although  these  issues  are  primarily  policy  related  and  lay 
mainly under the responsibility of the EU Member States, they point at the opportunity for seeking 
a better engagement with economic operators under the next iteration of the programme.  

According  to  the  evaluation,  the  programme  has  supported  customs  authorities  in  the 
prevention of illegal activities, and therefore the protection of the financial and economic interest 

5   The UCC was amended in 2019 to postpone the deadline for the deployment of three national systems to 2022 
and of six trans-European systems to 2025. These include 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. 

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of the Union and of the Member States. The digitalisation process, which the Customs 2020 has 
supported,  provides  the  means  for  conducting  automated  checks,  cross-verification  and  data 
validations, potentially contributing to reduce fraud and error. In addition, the IT capacity-building 
activities and joint actions (in particular the new expert teams) allowed for increasing coordination 
between customs authorities and the Commission in relation to the prevention of fraud. Human 
competency-building  activities  have  strengthened  customs  officials’  competency  in  relation  to 
controls in the customs territory of the Union.  

Despite  these  positive  findings,  there  is  evidence  of  inconsistent  application  of  customs 
controls6, which shows the need to adjust the risk management framework that the Commission 
has put in place with the support of the programme to prevent illegal activities. In addition, several 
stakeholders consulted referred to e-commerce fraud as an outstanding issue.    

3. 

EFFICIENCY 

The Customs 2020 programme committed a 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), mostly due to the increased focus on the development of the 
EIS in the context of the UCC implementation. 87% of the budget has been spent on developing, 
maintaining and operating the EIS for customs. These common IT systems are clearly resource-
intensive. However, they are indispensable for the day-to-day work of customs administrations 
and  bring  a  range  of  benefits  in  all  areas  of  customs  activities.  Though  it  was  not  possible  to 
quantify  these  benefits,  they  mostly  relate  to  the  simplification  and  standardisation  of  customs 
procedures  through  automation,  a  more  effective  implementation  and  consistent  application  of 
customs  law  and  the  increased  interoperability  and  information  sharing  between  customs 
authorities. By developing and operating the common components for the EIS, the programme has 
led  to  important  economies  of  scale,  avoiding  duplication  of  efforts  for  Member  State,  while 
reducing compliance costs and administrative burdens for economic operators. Despite the fact 
that the evaluation could not confirm the cost-effectiveness of the IT capacity building activities 
(due mostly to the difficulties to quantify their benefits) it provided an overall positive picture of 
their efficiency.  

Joint actions represented 11% of the committed budget and made up a high contribution to 
the programme’s objectives.  The  average  cost  per participant per action for all types of joint 
actions (except expert teams) was around EUR 742. Project groups accounted for almost half of 
the expenditure on joint actions but are probably the most cost-effective type due to their reach 
(over  33  000  participants)  and  relatively  low  cost  (average  participant  cost  of  EUR 676) 
participation. They have enhanced cooperation and working relationships among participants and 

6   European Court of Auditors, Special report – Customs controls: insufficient harmonisation hampers EU financial 

interests (04, 2021). 

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supported the preparation of new customs law and the effective implementation of the legislation 
in force, through the identification of best working practices for administrative procedures.  The 
evaluation signalled the need to improve the timeliness of invitations to the meetings to ensure the 
participation of the best possible experts at the lowest possible cost. Due to the different nature of 
the newly implemented expert teams  (and therefore different  monitoring  data), it is difficult  to 
compare the cost-effectiveness  of the expert teams  with the other joint  actions.  However, their 
potential to reduce costs was highlighted during the evaluation, as they provide the opportunity 
for Member States to pool resources and expertise rather than acting separately. 

Although  human  competency  building  activities  have  consumed  only  2%  of  the  programme 
budget, they are considered to generate a high value for money, especially the eLearning trainings 
that can be used repeatedly without incurring in additional costs (apart from making the necessary 
updates). As evidenced in the evaluation, 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. 
This  was  particularly  important  during  this  iteration  of  the  Programme  where  a  new  customs 
legislative  framework  became  applicable.  In  this  regard,  the  UCC  EU  eLearning  programme, 
consisting of 15 modules to support the implementation of the UCC, was released in 2016. The 
subsequent  years  mostly  focused  on  updating  and  developing  translations  of  existing  modules 
(with  two  to  three  new  modules  in  English  a  year).  In  line  with  their  release,  the  number  of 
eLearning modules used by participating countries has also increased throughout the life of the 
programme. The number of downloads of publicly  available eLearning modules (namely those 
available to economic operators) raised from 3 219 in 2014 to 30 408 in 2020 and the number of 
national customs officials trained by  EU common training material increased by tenfold during 
this programming period (from just over 4 000 in 2014 to 40 000 in 2019). These trainings were 
overall perceived to be of good quality. 

4. 

COHERENCE 

The final evaluation focused on the programme’s external coherence with EU’s broader policies 
and  priorities.  The  findings  of  the  mid-term  evaluation  which  focused  on  internal  coherence 
between  the  different  features,  components  and  design  of  the  programme  remain  valid.  The 
evaluation found that the Customs 2020 programme has both supported other EU initiatives 
and  programmes  and  benefited  from  them.  As  detailed  in  the  staff  working  document 
accompanying  this  report,  an  example  of  such  interlinkages  is  the  case  of  “prohibitions  and 
restrictions”,  which  refer  to  non-customs  regulatory  formalities  (sanitary,  phytosanitary, 
environmental,  agricultural,  etc.)  required  for  the  import  and  export  of  goods  that  customs 
authorities are entrusted to enforce at the EU borders. Coherence with other spending programmes, 
such  as  Fiscalis  2020,  the  Structural  Reform  Support  Programme  or  Hercule  III,  and  their 
respective policy areas was also achieved to a reasonable extent, avoiding overlaps and reaching 
complementarities.   

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Several mechanisms were used to ensure this coherence, such as inter-services meetings and inter-
service consultations among different Commission’s services, mixed project and expert groups, 
participation  of  observers  from  various  Commission  services  in  project  group  meetings  or 
activities, or the assessment of project proposals by officials from different Commission services. 
Despite the observed positive results, the evaluation, as well as the impact assessment conducted 
for the next funding programme, found room for further complementarities and synergies in certain 
areas. For instance, additional synergies could be explored with the successor of the 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, by seeking a more joined-up and 
cross-sectoral approach at operational level. Cooperation with third countries on the fulfilment of 
EU and international environmental goals was also highlighted as potential area where coherence 
could be enhanced.  

Finally, the evaluation suggested additional ways to improve coherence, such as further structuring 
or formalising cooperation between involved Commission services, following the principles and 
recommendations  of  the  European  Interoperability  Framework7,  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 successor initiative could benefit from the upcoming proposal for a Regulation on a high level 
of public sector interoperability across the Union8 to further ensure cross-domain and cross-border 
seamless  interactions.  This  would  also  help  to  identify  successful  solutions  and  practical 
experience that could benefit others. 

5. 

RELEVANCE 

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, 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 also be considered are 
economic operators. 

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 
the concerned stakeholders 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 

7   See The European Interoperability Framework in detail | Joinup (europa.eu) 

8  

Included in the Commission’s work programme 2022, pp 7 (resource.html (europa.eu)) 

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pandemic.  Moreover,  the  evaluation  examined  whether  the  programme  is  aligned  to 
problems and actions identified in the 2020 Customs Action Plan “Taking the Customs Union 
to the next level”9 which proposes a revised Customs Union strategy.  

The final evaluation showed that the programme continues to be both relevant and necessary 
and that stakeholders’ needs have remained largely unchanged since the mid-term evaluation. This 
is  also  in  line  with  the  Impact  Assessment  for  the  post-2020  customs  programme,  which 
confirmed these needs. In addition, 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  with  the  objectives  of  the 
programme,  were  in  the  areas  of  risk  management,  management  of  e-commerce,  promotion  of 
compliance, and operational cooperation between customs authorities10. 

The  programme  was  found  to  continue  to  be  particularly  relevant  in  relation  to  the  need  to 
harmonise the application and effective implementation of the Customs Union rules. Customs 
authorities,  but  also  economic  operators,  indicated  under  the  evaluation  that  the  programme’s 
activities had helped Member States come together and therefore come closer to a more common 
understanding of those rules. Networking, exchange of ideas and practices as well as formulation 
of common guidance and standards were seen as important aspects of these activities. Customs 
authorities also confirmed the continued need for the programme to support Member States 
in the digitalisation and modernisation of customs procedures, which is still ongoing.  

Interviewed  economic  operators  in  general  demanded  even  further  simplification  and 
harmonisation of customs legislation and processes, confirming that this is a continued need. 
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 businesses. This had already been recommended by the mid-term evaluation of 
the programme and will be addressed during the next funding period.    

Overall,  the  programme  adapted  well  to  unforeseen  events,  such  as  COVID-19  and  the  UK’s 
withdrawal from the European Union. The programme’s activities contributed to preparing the 
ground for  the  UK’s  withdrawal  from  the  EU,  showing  its  flexibility  to  address  unforeseen 
developments. Customs authorities were regularly updated about the progress in this respect and 
participated in various meetings and seminars11 on the matter. There were specific joint actions in 
this key area under the objective of supporting the preparation, application and implementation of 

9   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. 

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

11   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). 

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Union law, and specific training support was also provided in 2019 on preparation for the UK’s 
withdrawal from the European Union12. In addition, 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. Despite this positive 
assessment, consulted customs authorities consider that further programme support in this area 
is still needed.   

The  programme  also  adapted  well  to  COVID-19  pandemic  and  the  new  reality.  Both  customs 
authorities and economic operators consulted agreed that the Commission’s services in charge of 
customs had 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. In terms of the programme activities, after some initial interruptions and 
delays in joint actions and the testing of new IT systems, the programme adapted well to the 
situation.  However,  the  more  virtual  environment  appears  to  have  affected  networking 
opportunities and some customs authorities consider the programme’s management systems 
outdated  and  not  adapted  to  the  new  reality  of  increased  virtual  ways  of  working  and 
networking.   

On  their  side,  economic  operators  pointed  at  the  management  of  e-commerce  and  the 
technological  innovation  for  customs  processes  as  two  evolving  needs  that  have  not  been 
sufficiently  addressed  by  the  Commission  and  the  Member  States  via  the  programme,  thus 
confirming its continued relevance.   

6. 

EU ADDED VALUE 

Customs  policy  is  an  exclusive  competence  of  the  EU.  However,  the  implementation  of  EU 
customs  legislation  lays  on  the  Member  States.  The  EU’s  legal  framework  in  itself  does  not 
sufficiently ensure the proper functioning of the Customs Union. It should be complemented by 
supporting  measures  as  provided  by  the  Customs  2020  programme  to  ensure  that  EU  customs 
legislation is applied in a convergent and consistent way at national level. 

As stated above, the Customs 2020 programme has been instrumental in supporting all aspects of 
UCC  implementation.  The  UCC  would  have  been  implemented  on  its  own,  but  without  the 
programme’s support, most likely with greater difficulties and lesser harmonisation. The Customs 
2020 programme has provided for financial sustainability of the EIS, which are crucial in ensuring 
the availability and sharing of supply chain data and risk-relevant information. In doing so, the 
Customs 2020 programme has brought about  economies of scale and efficiency gains, helping 
national administrations — as well as economic operators in many instances — to save time and 
resources, in particular for participating countries with smaller customs administrations and fewer 
resources.  Everything  that  is  related  to  the  interoperability  and  interconnectivity  of  central  IT 

12   Through the development of fast-track upskilling and on-boarding customs training programmes for direct use by 

national authorities. 

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systems is EU added value. The symbiotic features of the central EIS architecture are unmatched 
and cannot be reproduced at national level. 

The joint actions have pooled the expertise and knowledge of participating countries, giving the 
administrations unequalled opportunities for cooperation, communication and networking; they 
ultimately build trust and lead to greater convergence of approaches and practices. The same goes 
for  training  activities,  which  have  not  only  helped  national  customs  administrations  to  better 
understand and implement EU customs legislation and its related procedures, but also, if not more 
importantly, in a more uniform manner. Efficiency gains have been the largest especially for those 
participating countries that either did not have expertise in a specific area or  did not have well 
developed national training programmes. Doing it on their own would have been difficult and more 
costly or could potentially not have happened at all. Ultimately, the Customs 2020 programme has 
contributed to the approximation of national approaches, establishing trust and creating a single 
narrative and a shared vision. 

If the programme did not exist, cooperation between participating countries would have been much 
more difficult, based on unstructured relations, formal time-consuming channels and reciprocity 
agreements (bilateral or multilateral agreements where provisions are applied reciprocally), which 
would be significantly more difficult and costly to implement in practice and maintain. Given the 
scale of the Customs 2020 operations in terms of the sheer number of joint actions, versatility of 
topics,  their  European  dimension  or  pan-European  participation  in  actions  and  training,  it  is 
difficult to imagine that similar activities would have been organised at any other level. As regards 
the  European  Information  Systems,  if  there  was  no  future  funding  for  their  continuous 
development and maintenance, it would be difficult to continue to use them beyond the medium 
term.  There  would  be  a  high  risk  of  them  becoming  obsolete,  and  the  economies  of  scale  and 
reductions in overall costs would be lost. 

Customs  2020  has  created  tangible  outputs  and  helped  customs  officials  acquire  skills  and 
exchange experiences. None of the programme’s outputs would likely continue beyond the short 
term if the programme were to be discontinued. Existing differences would persist, and networks 
built thanks to years of collaboration would fade. 

7. 

CONCLUSIONS AND LESSONS LEARNED 

The evaluation showed that the programme has been effective in achieving its objectives and has 
contributed  significantly  to  improve  the  functioning  of  the  Customs  Union  and  to  its 
modernisation.  It  has  fostered  cooperation  and  the  exchange  of  information,  ranging  from 
facilitating  convergence  at  the  strategic  level  to  approximating  approaches,  interpretation, 
administrative procedures, best practices and rules at the operational level.  The programme has 
been  especially  important  in  transitioning  to  a  customs  paperless  environment  supporting  the 
development and functioning of the customs EIS, providing for their financial sustainability and 
ensuring the availability and exchange of supply chain data and risk-relevant information.  

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From  an  efficiency  perspective,  the  difficulties  to  monetise  the  benefits  of  the  Customs  2020 
activities,  did  not  allow  the  evaluation  to  accurately  conclude  on  the  extent  to  which  the 
programme’s  resources  had  produced  the  best  possible  results  at  the  lowest  possible  costs. 
However, considering the findings on effectiveness alongside the cost figures showed that, overall, 
the  programme  had  provided  value  for  the  EU  and  national  customs  authorities  at  a 
reasonable cost.  

The evaluation concluded positively on the coherence of the Customs 2020 programme with 
broader EU policies, especially, but not only, regarding prohibitions and restrictions that customs 
authorities must enforce at the border. It also corroborated the added value of the programme, 
which  lies  in  supporting  all  aspects  of  UCC  implementation,  requiring  EU  solutions  for  EU 
problems and close cooperation of the Member States. The programme has provided for financial 
sustainability of the interoperable and interconnected European Information Systems, meeting the 
requirements of the UCC with greater economies of scale and efficiency. Finally, the evaluation 
revealed  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 the stakeholders’ needs, adapting well to unforeseen events 
(such as COVID-19 and the UK’s withdrawal from the European Union) and addressing problems 
and priorities identified in the impact assessment of the next customs programme and in the 2020 
Customs Action Plan.  

Despite the progress made, the analysis performed under the five evaluation criteria pointed to a 
number of challenges and lessons learnt. It pointed at the following areas where improvements are 
needed:  

  The evaluation provided evidence of differences in the application of customs controls, 
suggesting there was room to revise the risk management framework in place. In addition, 
several  stakeholders  referred  to  e-commerce  fraud  as  an  outstanding  issue  and  some 
custom authorities consider that further programme support on the consequences of the 
UK’s  withdrawal  from  the  European  Union  is  still  needed.  This  is  in  line  with  the 
assessment provided in the European Court of auditors, Special Report Customs controls13 
and the 2022 Report by the Wise Persons Group (WPG) on challenges facing the Customs 
Union14. In this context, future programmes’ actions could be designed to  help address 
such differences. 

  The evaluation showed that despite the significant progress made in in terms of developing 
IT structures and systems, some of the IT systems envisaged in the UCC have not yet been 

13   European Court of Auditors, Special report – Customs controls: insufficient harmonisation hampers EU financial 

interests (04, 2021). 

14   See TAX-20-002-Future customs-REPORT_BIS_v5 (WEB).pdf. The report states ’divergences remain between 
national Customs authorities in the application of rules and procedures and customs face growing difficulties to 
control borders’. 

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developed or updated, resulting in the economic operators not perceiving the benefits 
of the UCC and voicing concerns over the complexity of the  customs  IT environment. 
They  emphasised  the  need  to  further  simplify  and  harmonise  customs  legislation  and 
processes. This is in line with the results of the interim evaluation of the implementation 
of the UCC which found that ‘numerous rules are still not uniformly applied across the 
Member States. The full automation of the customs processes is still in the process of being 
achieved (…), even if significant milestones have already been accomplished’.15  

  The evaluation found that additional synergies could be explored with the successor of 
the Hercule  III programme, for  example on the  development  of data  repositories or on 
joint data analysis, or with other EU programmes that run significant electronic systems. 
The  evaluation  deemed  the  existing  coordination  within  the  Commission  good  but 
emphasised the need to continuously explore ways to better coordinate with other services 
in view of a fast-changing world. The evaluation also emphasised the need to raise the 
visibility of the programme. Also, the interim evaluation of the implementation of the UCC 
indicated that “the UCC implementation did not fully tap into the potential synergies with 
related policies and proper coordination between customs authorities and other relevant 
national administrations in charge of applying EU policies at the border is lacking.” 

  The evaluation process demonstrated that it could be worthwhile for the Commission and 
Member States to share more customs data. This would serve, among other, to better 
measure the costs and benefits of the investments made. The need for better customs data 
was  also  highlighted in  the 2022 Report by  WPG. Their detailed recommendation 2 to 
‘Introduce  a  new  approach  to  data,  focussed  on  obtaining  better  quality  data  (…)’ 
suggests that the Customs Programme should focus on that purpose: ‘The existing budget 
for 2021-2027 could be refocused for these goals.’ 16 

  The  evaluation  showed  that  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. This is in line with 
recommendation 9 of the 2022 Report by the WPG to ‘Properly resource, skill and equip 
Customs to ensure their capacity to fulfil their missions.’ 

15   See  COMMISSION  STAFF  WORKING  DOCUMENT  EXECUTIVE  SUMMARY  OF THE  EVALUATION 
INTERIM EVALUATION of the implementation of the Union Customs Code  - Publications Office of the EU 
(europa.eu) 

16   Recommendation 2 is as follows: ‘Introduce a new approach to data, focussed on obtaining better quality data 
based  on  commercial  sources,  ensuring  it  is  cross-validated  along  the  chain,  better  shared  among 
administrations, and better used for EU risk management. Clarify which private actors – including e-commerce 
platforms - must provide data, with costs for non-compliance. Provide businesses with a single data entry point 
for customs formalities and a single window/portal. Data to be stored and properly managed in a central data 
warehouse. The existing budget for 2021-2027 could be refocused for these goals.’ 

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  The evaluation confirmed that (i) joint actions provided the opportunity for Member States 
to  access  a  wider  pool  of  knowledge  and  experts  than  at  individual  level  and  create 
economies of scale; and that (ii) expert teams enhance operational cooperation and a more 
consistent  application  of  customs  legislation.  However,  it  also  showed  that  leading  the 
expert teams is burdensome and that no expert team gathers all the Member States; so, 
cooperation is necessarily limited. In this context, the Customs 2020 programme settings 
may not be sufficient to address all the current challenges facing the Customs Union and, 
as outlined in the 2022 Report by the WPG, there may be a need to set up a new operational 
actor  to  service  and  coordinate  the  efforts  of  the  Member  States,  providing  a  more 
integrated cooperation and thus ensuring that the Customs Union acts one.     

As a result of the mid-term evaluation of the programme, the Commission put forward an Action 
Plan on how to address the 13 recommendations made then. These regarded, “programming and 
design”,  “implementation”,  “monitoring  and  reporting”  and  “communication”.  Several  actions 
have  been  implemented  and  some  are  ongoing  under  the  new  programme.  Overall,  the 
Commission acknowledges and endeavours to address these challenges under the implementation 
of the Customs programme 2021-2027.  

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