REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods (28 June 2023 - 29 June 2024)
Date: 2024-10-16
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: art trade, cultural object, exchange of information, heritage protection, illicit trade, import (EU), import licence, information system, surveillance concerning imports, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.10.2024  COM(2024) 458 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods (28 June 2023 - 29 June 2024)          
 
 
Table of Contents 

1. 

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

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

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

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

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

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

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

Project development ........................................................................................................................... 6 

Methodology: approach used for the implementation of the ICG System ......................................... 7 

High-level planning .............................................................................................................................. 7 

Request for Changes (RfCs) ................................................................................................................. 8 

External synergies................................................................................................................................ 8 

Internal Cooperation ........................................................................................................................... 8 

Work with the Project Group on ‘Digitalisation of Cultural Goods’ .................................................... 8 

5.  RISKS FOR DELAYS ........................................................................................................................... 9 

Risk 1 – Staff allocation ....................................................................................................................... 9 

Mitigation actions .............................................................................................................................. 10 

6.  CONCLUSIONS ............................................................................................................................... 10 

ANNEX I: MULTIANNUAL STRATEGIC PLANNING............................................................... 12 

ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE ............ 14 

1 

 
 
 
Business Case 

Vision Document 

Project Charter  

ICG system 

TRACES 

GLOSSARY 

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

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

owner/system 

supplier 

The Project Charter replaces the Vision Document as per 
the  Commission  PM2/Agile 
the  alignment  with 
the  system  owner/system 
methodology.  It  records 
supplier partnership and  understanding  of the system at 
the time of writing. 

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

Trade  Control  and  Expert  System  -  the  European 
Commission's  multilingual  online  platform  for  sanitary 
and phytosanitary certification. It will also host the ICG 
system. 

EU CSW - CERTEX 

EU Customs Single Window - Certificates Exchange. 

MFF 

BPM 

BAC document 

PQTM 

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

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

The Business Acceptance Criteria document 

Proximity Quoted Times and Means 

2 

 
 
 
 
 
 
 
1.  INTRODUCTION 

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

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

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

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

The  functioning  of  the  ICG  system  depends  on  the  EU  Single  Window  Environment  for 
Customs  established  by  Regulation  (EU)  2022/23992,  which  provides  a  legal  basis  for  the 
functioning of the EU CSW-CERTEX.  

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

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

The first Commission annual progress report3 outlined the action taken by its services during 
the  first  year  after  the  Regulation  entered  into  force,  namely:  (a)  the  preparatory  work  for 
adopting the necessary implementing provisions, and (b) the consultations with the Member 
States via the Expert Group for customs issues related to cultural goods and the Project Group 
for the import of cultural goods.  

The  second  Commission  annual  progress  report4  presented  the  progress  achieved  with  the 
adoption of the Commission Implementing Regulation (EU) 2021/10795, as well as the roll-

1 OJ L 151, 7.6.2019, p. 1–14 
2 Regulation (EU)  2022/2399 of the European Parliament and of the Council of 23 November 2022 establishing 
the European Union Single Window Environment for Customs and amending Regulation (EU) No 952/2013  OJ 
L 317, 9.12.2022, p. 1–23   
3 COM(2020) 342 final 
4 COM (2021) 358 final 

3 

 
 
 
 
out of Phase 1 – ‘Conceptualisation’ of the ICG project, the work carried out by the Project 
Group  created  for  this  purpose  and  the  advancement  of  the  Business  Case  and  the  Vision 
Document for the ICG project. 

The third Commission annual progress report6 covered the finalisation of the first version of 
the package of Business Process Models for the ICG system; the finalisation of the Business 
Acceptance  Criteria  (BAC)  document;  and  the  creation  of  user  stories  and  their  alignment 
with the BAC, verifying the information needed for the developers to estimate and implement 
the functionalities necessary to meet the requirements.  

The fourth Commission annual progress report7 covered  

(a)  the  start  of  developing  the  ICG  system,  i.e.  the  first  internal  releases,  encompassing  the 
general functional infrastructure, as well as the core workflows. 

(b) the extention of the core functionalities to the complete management capabilities and the 
definition  of  new  functional  concepts  such  as  the  simplified  procedure  to  obtain  an  import 
licence  for  subsequent  imports;  applying  for  an  import  licence  that  covers  multiple  objects, 
splitting  a  licence  application;  or  the  ICG  third  countries  law  compendium  feature  (the 
Library). 

(c)  the  launch  of  business  activities  for  the  EU  CSW-CERTEX  integration,  so  that  import 
licences or importer statements are accessible to customs via the EU CSW-CERTEX. 

The present fifth annual progress report covers the period from July 2023 to June 2024. This 
will be the last report before the ICG system becomes operational in the 2nd quarter of 
2025. For the sake of completeness, the objectives to be met, the project architecture and the 
planning approach, which are detailed in previous progress reports, are also briefly mentioned 
here.  The  overall  assessment  of  the  progress  made  and  the  identified  risks  for  delay  are 
summarised in the conclusions section of this report. 

2.  OBJECTIVES TO BE MET 

The ICG system is to become operational by 28 June 2025 at the latest, as on that date, it will 
become mandatory for all operators to obtain import licences or submit importer statements to 
customs through that electronic system, in order for them to be able to import8 legally specific 
categories of cultural goods into the Union.  

The project is currently at its third phase, as most of the development has been completed and 
the  interconnection  of  the  ICG  system  to  the  EU-CSW  CERTEX  is  well  underway.  In 
parallel, training sessions are organised to familiarise Member States administrations with the 
ICG system’s operational functionalities.  

5  Commission  Implementing  Regulation  (EU)  2021/1079  of  24  June  2021  laying  down  detailed  rules  for 
implementing certain provisions of Regulation (EU) 2019/880 of the European Parliament and of the Council on 
the introduction and the import of cultural goods; OJEU L 234 of 2.7.2021, p. 67. 
6 COM(2022) 580 final 
7 COM(2023) 758 final 
8 The Regulation defines as ‘import’ the placement of goods under the following customs procedures: release for 
free  circulation;  storage  in  customs  warehouses  or  free  zones;  temporary  admission;  and  end-use,  including 
inward processing. 

4 

 
 
 
The project on the import of cultural goods is also planned in detail through the Multi-Annual 
Strategic Plan for electronic Customs revision 20239 (MASP-C Rev. 2023 v1.0). An excerpt 
of  the  planning  of  the  project  on  the  import  of  cultural  goods  from  MASP-C  rev.  2023  is 
provided  in  Annex  I  to  this  report  (table  1  –  Consolidated  fiche  1.18  ‘Digitalisation  of 
Cultural Goods’), as well as an excerpt of the planning of EU CSW-CERTEX rev. 2023 from 
MASP-C Consolidated Fiche 1.13 (table 2). 

3.  PROJECT ARCHITECTURE AND PLANNING APPROACH 

As explained analytically in the first annual progress report, the Project Architecture is based 
on  the  methodology  provided  for  in  MASP-C  rev.  2023  and  its  Annexes,  including  the 
Governance Scheme, the EU Customs Business Process Modelling Policy and the IT strategy. 
A comprehensive roadmap, with the main project phases and the critical milestones is detailed 
in Annex II. 

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

Phase  1  –  Conceptualisation  Initially,  a  Business  Case  is  prepared,  providing  the  project 
justification  and  defining  budgetary  requirements.  Further,  the  Level  3  (user  requirements 
BPMs)  and  Level  4  (functional  requirements  BPMs)  are  produced,  followed  by  a  Vision 
Document,  which  provides  more  detailed  information  on  the  project  definition  in  terms  of 
architecture, cost, time, and risk, as well as information such as milestones, deliverables and 
project organisation.  

Phase  2  –  System  development  Based  on  the  provisions  of  the  implementing  act,  the  user 
requirements and the functional specifications for the system, technical specifications on how 
the system will be constructed are developed.  

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

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

As the ICG system will be interconnected with Member States’ customs systems via the EU 
CSW-CERTEX,  this  activity  will  require  Conformance  Testing.  While  the  date  of 
interconnection was  originally  foreseen for 3 March 2025, the Commission has prepared an 

9 https://taxation-customs.ec.europa.eu/customs-4/electronic-customs_en and MASP-C Annex 2 

5 

 
 
 
amendment to the EU SWE-C Regulation in order to align the applicability date with that of 
Regulation (EU) 2019/880, i.e. by 28 June 2025 at the latest. 

4.  PROGRESS OVERVIEW  

Project development  

During the reporting period there has been substantial progress in the development of the ICG 
system, as well as with regard to its integration with the EU CSW-CERTEX. Throughout the 
reporting  period,  collaboration  with  Member  States  has  been  a  top  priority.  To  ensure  that 
their  input  and  feedback  would  contribute  to  the  system's  continuous  improvement  and 
successful  implementation,  several  work  meetings  were  organised.  Those  have  taken  place 
both on a bilateral basis and within the Project Group on the Digitalisation of Cultural Goods.  

Early feedback from Member States has been invaluable in refining the system, allowing the 
Commission  to  address  concerns  and  incorporate  suggestions  effectively.  Four  live 
demonstrations of the ICG system have taken place throughout this reporting period, during 
which  Member  States  played  a  pivotal  role  in  providing  feedback  and  insights.  Early 
engagement  with  them  facilitated  the  gathering  of  valuable  feedback  on  prototypes  and 
functionalities, allowing for iterative improvements based on real-world usage scenarios. This 
collaborative  approach  not  only  enhanced  the  usability  of  the  system  but  also  fostered 
ownership. 

Progress  continued  on  both  business  and  technical  fronts  for  the  ICG  system  and 
specifications were adapted to meet the evolving needs. By keeping these specifications up-
to-date,  the  project  ensured  that  it  remained  agile  and  responsive  to  changing  requirements. 
Strong focus was placed on testing the system in view of identifying and anticipating potential 
problems while enhancing the user experience and reducing the chances of critical issues that 
may  occur  post-deployment.  Integration  efforts  with  the  EU  CSW-CERTEX  system 
continued to be a priority to ensure that the customs control objective would be operational as 
per the legal deadline of 28 June 2025.  

During the reporting period the Commission has also been developing training modules on the 
new  import  rules  and  the  ICG  system,  as  well  as  a  user  manual  for  the  ICG  system.  The 
design  of  the  training  materials  and  the  development  of  the  user  manual  underscore  the 
project's  commitment  to  ensuring  that  end-users  are  equipped  with  the  knowledge  and 
resources  needed  to  leverage  the  system  effectively.  With  regard  to  training  materials,  two 
modules are being developed: one for competent authorities and importers and the second for 
customs.  

Notable  progress  was  also  made  in  the  development  of  the  ICG  compendium  comprising 
succinct profiles of third countries’ legislation on export requirements. The so-called Library 
feature  of  the  ICG  system  aims  to  assist  competent  authorities,  importers  and  customs  in 
informing  themselves  on  the  exact  requirements  for  exporting  cultural  goods  legally  out  of 
third countries.  To this end,  extensive efforts were dedicated to  refining  and fine-tuning the 
template  to  ensure  that  it  accurately  captures  the  relevant  legal  provisions  and  other  key 
details of the third countries  in  question and the first  12 profiles were drafted. The exercise 
continues  with  the  preparation  of  more  country  profiles,  in  close  cooperation  with  the 

6 

 
 
 
 
 
 
 
International Council of Museums (ICOM), in particular regarding countries for which a Red 
List has been issued by that organisation. 

In parallel, by embracing emerging technologies, the project aims to remain at the forefront of 
innovation  by  exploring  the  potential  integration  of  AI-driven  functionalities  for  the 
identification of cultural objects. 

Methodology: approach used for the implementation of the ICG System 
The  methodological  approach  used  for  the  implementation  of  the  ICG  represents  a  mix 
between  different  Commission  services’  methodologies  and  practices  for  conceptualisation, 
quality assurance, development and deployment. In this context, the regular internal meetings 
and  demonstration  sessions  allow  for  discussing  and  implementing  real  functionalities, 
avoiding too elaborate mock-up screens. The adaptive planning allows for responding faster 
to expectations and changes in a flexible way.  

To  ensure  effective  feedback  from  future  users  and  the  successful  implementation  of  the 
system,  Member  States  will  be  invited  to  participate  on  a  voluntary  basis  as  soon  as  a  test 
version is available. This collaborative approach aims to: 

Engage stakeholders early: gathering diverse perspectives and insights that will be valuable 
for refining the system. At the same time, an extensive demo was organised for the art market, 
specifically  tailored  for  them,  highlighting  the  main  workflows,  while  gathering  relevant 
feedback.  

Foster collaboration: contributing to a more robust and user-friendly system. 

Early familiarisation: Member States will have the opportunity to become familiar with the 
system  early  in  the  development  process,  helping  them  understand  its  functionalities  and 
benefits before the date of the full deployment. 

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

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

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

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

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

(e) “Out of scope”: features not for the first ICG system version (e.g. Artificial Intelligence); 

7 

 
 
 
 
 
Table 1: High-level overview of availability targets 

Request for Changes (RfCs) 
As per the Change Management Process, whenever a change is identified, this is registered in 
a Request for Change (RfC) list. While the development activities are progressing and internal 
discussions  are  ongoing,  several  changes  are  identified  to  be  implemented  at  the  Level  2-
Level 4 ICG BPMs. Therefore, the BPMs and BAC document are updated to reflect the latest 
status  considering  the  amendments.  The  Member  States  are  informed  about  the  changes, 
however  so  far  the  modifications  do  not  have  any  impact  on  them.  As  part  of  the  external 
review process,  during the second quarter of 2024, Member States were asked to  conduct  a 
formal review of all changes implemented up to that point and provide feedback or comments 
as necessary.  Member States approved the changes, having been informed in a timely manner 
about the modifications, thanks to the close cooperation established through various forums.  

External synergies 
During  the  reporting  period,  the  Commission  has  been  liaising  closely  with  international 
organisations, such as UNESCO and ICOM in the context of populating the ICG Library with 
quality third country law profiles, in particular for Red List countries10).  

Internal Cooperation 
An extensive cooperation exists between the Commission’s services responsible for customs 
and for health, who are responsible for a number of policies that are deeply intertwined. The 
operational framework of cooperation has been agreed between services and has been further 
enhanced during the reporting period through continuous monitoring.  

Work with the Project Group on ‘Digitalisation of Cultural Goods’ 
The  Commission  has  created  a  Customs  Project  Group  on  the  Digitalisation  of  Cultural 
Goods11 which serves as a discussion forum for experts from Member States national customs 
administrations and competent (cultural) authorities with experience in carrying out licencing 
formalities  in  heritage  matters,  in  particular  digitally.  The  Group  provided  support  in  the 
preparation of the implementing act, and is assisting the Commission services with defining 
the parameters and elaborating the criteria for the functional specifications of the ICG system. 

The  Project  Group12  currently  consists  of  delegates  from  15  Member  States  (AT,  BE,  BG, 
DK,  DE,  EE,  EL,  ES,  FR,  HU,  IT,  LV,  NL,  PT  and  RO)  and  to-date  it  has  met  four  times 
(during the reporting period 29 June 2023 – 28 June 2024). 

During this reporting period, the Project Group mainly examined and provided their expertise 
and insight on the following subjects: 

•  Four demonstrations of the ICG system were conducted; during the last one (June 2024) 
Member States had the opportunity to test the ICG system in a training environment, and 
they were also informed about the pre-registration of operators (in order to avoid a large 
influx of registration requests just before the date when the system is expected to go live). 

10 https://icom.museum/en/resources/red-lists/  
11  The  Project  Group  on  Digitalisation  of  Cultural  Goods  serves  as  a  discussion  platform, where  experts  from 
national customs administrations and competent (cultural) authorities with experience in carrying out licencing 
formalities in heritage matters, in particular digitally, come together to provide support with the activities related 
to the development of the ICG System.  
12 For more details on the Project Group’s mandate and work, please see the Commission’s first Progress Report 
COM(2020) 342 final. 

8 

 
 
 
 
•  Establish the functionality of the ICG system supporting the temporary import of cultural 
goods  in  exemption  from  licencing  requirements  in  the context of commercial art fairs, 
including a mechanism for follow up controls of the exempted imports by the competent 
authorities and an alert mechanism in case the terms of the exemption were infringed. 
•  Define  the  template  for  the  third  countries  law  compendium,  to  help  the  ICG  users 

identify the export laws in third countries.  

•  Finalise  the  Administrative  Cooperation  module,  allowing  Member  States  competent 

authorities to exchange information on documents managed in the ICG.  

•  Cooperation  with  the  Member  States  regarding  the  services  or  departments  they  have 

designated as competent authorities in their territory (for inclusion in the ICG).  

•  Progress on the training materials for the ICG system, including the ICG user manual, to 
ensure users will be fully equipped with the necessary knowledge and skills to efficiently 
operate the system. 
Incorporation  of  the  feedback  from  Member  States  with  regards  to  concrete  workflows 
such  as :  Split  workflow,  Partial  rejection  workflow,  e-Seal,  issuance  of  an  importer 
statement for the purpose of a commercial art fair and the related period of time for the 
temporary admission, etc. 

• 

•  Cooperation on the future translation activities for the ICG system, making it available in 

all EU languages, ensureing inclusivity and accessibility for all users. 

•  Member States were consulted regarding the  future  extension of the ICG to include the 
export domain13, ensuring an equal protection for European as well as for world cultural 
heritage.  Some  examples  of  consultation  with  the  Member  States  on  the  export  topic 
include :  practice  to  issue  open  licences,  the  existence  of  digital  solution  to  handle  the 
export certificates in the area of cultural goods, workflows at national level, etc. 

Additionally, during the reporting period and as new functionalities were created and added to 
the system, the ICG developers team made a demonstration to the Expert Group on customs 
issues related to cultural goods14 and to the Expert Group ‘Dialogue with the Art Market’15 to 
get  feedback  on  the  implementation  of  the  new  features.  Three  demonstrations  were 
performed in the context of the Project Group of Digitlisation of Cultural Goods, and a fourth 
with the Customs Business Group (CBG), given the importance to familiarise all the Member 
States with the ICG testing environment and not only the Project Group members.  

5.  RISKS FOR DELAYS 

Risk 1 – Staff allocation 

The initial  proposal  from  the Commission  did not  provide for the creation  of an  IT system. 
Thus,  resources  were  not  allocated  accordingly.  However,  in  the  course  of  the  negotiations 
and  at  the  request  of  the  co-legislators,  the  creation  of  the  ICG  system  was  included  in  the 
Regulation, which called for additional resources, unforeseen at that point. The needs for this 
six-year project in terms of IT development personnel were estimated, at the time of the final 
political  trilogues  in  December  2018,  to  be  two  full  time  Administrator  posts.  To  partly 
mitigate  this  risk,  an  internal  PQTM  consultant  was  assigned  from  Q4  2023  to  support  the 

13 Council Regulation (EC) 116/2009 on the export of cultural goods. 
14 A Commission group composed by representatives of Member States customs and cultural authorities. 
15A  Commission  group  composed  by  representatives  of  art  market  associations,  academia,  international 
organisations and other stakeholders. 

9 

 
 
 
 
Administrator  in  charge.  This  is  intended  to  provide  additional  support,  given  that  both  the 
AD and the PQTM consultant work only partially on the ICG project. 

Despite  the  constraints,  the  Commission  is  committed  to  delivering  the  project  within  the 
stipulated  timeframe,  ensuring  compliance  with  the  regulatory  requirements.  The  legal 
framework  mandates  that  the  system  must  be  continuously  maintained  and  operated  once 
established.  Therefore,  ongoing  resource  allocation  is  essential  for  proper  aftercare. 
Discontinuing support would negatively affect compliance with the legal requirements.  

Sustaining  a  dedicated  team  will  provide  essential  continuity,  leveraging  expertise  for  both 
immediate  support  and  future  enhancements,  thereby  ensuring  long-term  reliability  and 
adaptability for the overall cultural goods domain, including import and, in the future, export. 

Mitigation actions 
The risk has been reported internally.  

6.  CONCLUSIONS 

This  progress  report  is  the  last  one  of  the  series  as  the  ICG  system  will  become 
operational and Regulation (EU) 2019/880 fully applicable on 28 June 2025. 

The main actions to develop the ICG system that were undertaken during the period covered 
by the present 5th progress report can be summarised as follows: 

•  The reporting period saw significant advancements in the development of the ICG system 
and  its  integration  with  the  EU  CSW-CERTEX.  Collaboration  with  Member  States 
remained a priority, involving early participation for familiarisation with the ICG system 
and  feedback,  which  played  a  crucial  role  in  refining  its  functionalities.  Four  live 
demonstrations  were  conducted,  allowing  Member  States  to  be  actively  involved  in  the 
process and provide valuable insights and feedback, which led to iterative improvements 
and enhanced usability.  

•  Several  ICG  functional  concepts  were  agreed  and  completed,  in  close  cooperation  with 

the Member States, to ensure the readiness of the system within the legal deadline. 

•  A  strong  focus  was  placed  on  testing  to  identify  potential  issues  and  improve  the  user 

experience, reducing the likelihood of critical problems post-deployment. 

•  Additionally,  progress  was  made  on  developing  third  country  profiles  for  the  ICG  law 
compendium  (the  Library),  with  extensive  efforts  to  refine  the  template  to  accurately 
capture export legal provisions and other key details for the targeted countries. 

•  The  period  also  emphasised  the  development  of  comprehensive  training  materials, 
including  a  user  manual,  to  ensure  end-users  are  well-equipped.  Two  training  modules 
are planned: one for competent authorities and importers, and another for customs. 

• 

•  Planning  the  translations  for  the  ICG  system  in  close  cooperation  with  the  Member 
States,  to  ensure  the  relevant  linguistic  skills  and  cultural  knowledge  necessary  to 
accurately translate technical terms. 
Integration with the EU CSW-CERTEX system remained a key priority in order to ensure 
that customs will have all the necessary access to information for control purposes within 
the  legal  deadline.  Ongoing  efforts  are  made  to  enhance  system  reliability  and  user 
satisfaction  through  rigorous  testing,  focusing  on  identifying  and  addressing  potential 
issues pre-deployment. 

10 

 
 
 
 
 
•  Finalisation  of  the  mechanism  for  the  Administrative  Cooperation,  enabling  Member 
States’ competent authorities to exchange information on documents managed within the 
ICG system. 

11 

 
 
 
 
ANNEX I: MULTIANNUAL STRATEGIC PLANNING 

The  MASP-C  ensures  an  effective  and  coherent  management  of  IT  projects  by  setting  out  both  a 
strategic framework and milestones within the legal deadlines established in legislation. It is ultimately 
endorsed by the Member States in the Customs Policy Group (CPG) based on advice provided by the 
Electronic  Customs  Coordination  Group  (ECCG)  and  consultations  with  trade  at  the  Trade  Contact 
Group (TCG). 
The planning for the electronic system has been discussed and approved by the Member States and is 
described in detail in Fiche 1.18 of the MASP-C rev. 2023. 

Table 1 below provides an excerpt of the planning of the project on the import of cultural goods from 
MASP-C rev. 2023 Fiche 1.18. 

Table 1 - Excerpt of MASP-C rev. 2023 Fiche 1.18 

Milestones 

Estimated completion date 

1  Business Analysis and Business Modelling 

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

2  Legal Provisions 

3 

4 

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

5  Operation 

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

6 

Q4 2020 
Q3 2021 
Q3 2021 

Q2 2019 
Q2 2021 

Q2 2021 
Q2 2021 

Q2 2023 
Q2 2023 

Q3 2024 
N/A 
N/A 

Q4 2024 
Q2 2025 

Q2 2025 

N/A 

Q4 2024 
Q4 2024 

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

12 

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

Table 2 - Excerpt of MASP-C rev. 2023 Fiche 1.13 – Component 2 “EU CSW- CERTEX” 

Milestones 

Estimated completion date 

1  Business Analysis and Business Modelling 

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

2  Legal Provisions 

3 

4 

- Current provisions adopted* 
- Future provisions adopted** 
Project Initiation Phase 
- Vision Document 
- Project Charter 16 
- GO decision 
IT Project 
- Application & Service Specifications 
- Technical System Specifications 
Construction Phase 
- Central services implementation 
- Service integration in National Systems 
- National implementation 
Transition Phase 
- Deploy and rollout 
- Conformance tests 

Q1 2017 
Q4 2023 
Q1 2024 
Q1 2024 

In force 
2022 

Q3 2017 
Q4 2023 
Q4 2023 

Q2 2024 
Q2 2024 

Q3 2024 
From Q4 2024 onwards 
From Q4 2024 onwards 

Q4 2024 
From Q4 2024 onwards 

5  Operation 

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

6 

Q1 2025 

N/A 

N/A 
N/A 

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

16 To replace the Vision Document as per the alignment with the Commission PM2/Agile methodology. 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE 

14