COMMISSION STAFF WORKING DOCUMENT Accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the Interim Evaluation of the Customs Control Equipment Instrument 2021-2027
Date: 2025-12-01
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU financial instrument, customs inspection, customs union, modernisation aid, project funding

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.12.2025  SWD(2025) 385 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the Interim Evaluation of the Customs Control Equipment Instrument 2021-2027 {COM(2025) 733 final}  
 
 
Table of contents 

1. 

INTRODUCTION ....................................................................................................... 1 

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

2.1 Description of the intervention and its objectives .................................................... 2 

2.2 Point(s) of comparison .............................................................................................. 9 

3.  HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 

PERIOD? ................................................................................................................... 12 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ............................................. 18 

4.1 To what extent was the intervention successful and why? ..................................... 18 

4.2 How did the EU intervention make a difference and to whom? ............................. 34 

4.3 Is the intervention still relevant? ............................................................................. 40 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ....................... 47 

5.1 Conclusions – main achievements .......................................................................... 47 

5.2 Lessons learned – areas for improvement............................................................... 49 

ANNEX I:   PROCEDURAL INFORMATION ............................................................... 52 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ....................... 53 

ANNEX 

III.  EVALUATION  MATRIX  AND  ANSWERS  TO  THE 
EVALUATION QUESTIONS .................................................................................. 61 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS .............................................. 124 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............... 126 

 
 
 
 
 
APR 

BCP  

BRG 

Glossary 

Annual Progress Report  

Border Crossing Point 

Better Regulation Guidelines  

CELBET  

Customs Eastern and South-Eastern Land Border Expert Team 

CCE 

CCEI  

CLEN 

CUP 

Custom Control Equipment  

Customs Control Equipment Instrument  

Customs Laboratories European Network 

Customs Union Performance  

DG BUDG 

Directorate-General for Budget 

DG HOME 

Directorate-General for Migration and Home Affairs  

DG TAXUD 

Directorate General for Taxation and Customs Union 

EC 

EQ 

EQM 

EU 

II 

JRC 

European Commission 

Evaluation Question  

Evaluation Question Matrix  

European Union 

Impact Indicator(s) 

Joint Research Centre  

MAWP 

Multi-annual work programme  

MEF 

MFF 

MS 

OLAF 

OP 

RI 

TOR 

Monitoring and Evaluation Framework 

Multiannual Financial Framework 

Member State(s) 

European Anti-Fraud Office  

Output Indicator(s) 

Results Indicator(s)  

Terms of Reference 

 
 
 
1. 

INTRODUCTION 

The  Customs  Control  Equipment  Instrument  (CCEI,  also  referred  to  as  ‘the  Instrument’), 
established by Regulation (EU) 2021/10771, is part of the Integrated Border Management Fund 
along  with  the  Border  Management  and  Visa  Instrument2.  The  CCEI  is  a  new  EU  funding 
programme  that  provides  grants  to  customs  authorities  in  EU  Member  States  for  the  purchase, 
maintenance and upgrading  of customs control equipment.  Customs  authorities face increasing 
challenges  in  performing  checks  on  goods  entering  and  exiting  the  EU  to  ensure  safety  and 
security while facilitating legitimate trade. Customs officers and customs laboratories have to be 
equipped with modern and reliable control equipment to do their tasks efficiently and effectively. 
The  CCEI  addresses  Member  States’  need  for  financial  support  for  the  purchase  of  such 
equipment. The Instrument has a budget of EUR 1 006 million for the period 2021-2027.  

The  CCEI’s  objective  is  to  help  ensure  that  customs  controls  across  the  EU  are  adequate  and 
equivalent.  The  long-term  aim  is  to  harmonise  the  way  national  customs  authorities  carry  out 
controls. The CCEI supports customs authorities to act as one and to achieve their mission to: 

-  protect the financial and economic interests of the EU and its Member States; 

-  ensure security and safety within the EU; and 

-  protect the EU from illegal trad while facilitating legitimate business activity. 

In  accordance  with  Article  13  of  the  CCEI  Regulation,  the  Instrument  is  subject  to  an  interim 
evaluation.  The  overall  goal  of  this  evaluation  is  to  assess  the  performance  of  the  Instrument, 
including  aspects  such  as  its  effectiveness,  efficiency,  relevance,  coherence  and  Union  added 
value,  in  line  with  the  Better  Regulation  guidelines,  and  to  draw  lessons  for  possible  future 
improvements. 

To  support  the  interim  evaluation  exercise,  an  external  contractor  was  engaged  to  carry  out  a 
study. This study was delivered by Ipsos and Syntesia from September 2024 to April 2025. The 
evaluation  covers  the  activities  from  the  Instrument’s  launch  in  2021  until  the  end  of  2024. 
Projects financed under the first call launched in 2022 and the second call launched in 2023, are 
implemented in all 27 Member States. This interim evaluation has been undertaken at  an early 
stage of the programme’s implementation as only a few projects have been completed from the 
first call while the grants under the second call have just started.  

This staff working document (SWD) presents the main findings and conclusions of the interim 
evaluation and provides evidence and data which could serve as a basis for further improving the 
functioning of the CCEI in the remaining programme period.  

1 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 

2 Regulation (EU) 2021/1148 of the European Parliament and of the Council of 7 July 2021 establishing, as part of 
the Integrated Border Management Fund, the Instrument for financial support for border management and visa 
policy. The fund is included in Heading IV ‘Migration and border management’.  

1 

 
 
 
 
 
 
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1 Description of the intervention and its objectives 

This  chapter  provides  an  overview  of  the  CCEI  as  it  was  designed  and  intended  to  function. 
First,  a  general  description  of  the  Instrument  is  provided  outlining  its  key  characteristics. 
Subsequently,  a  brief  overview  of  the  Intervention  Logic  (which  was  developed  as  part  of  the 
Monitoring  and  Evaluation  Framework)  is  provided,  outlining  the  key  expected  results  at 
different  levels,  and  the  causal  chains  between  them,  including  the  assumptions  and  external 
factors that had been identified at the time the Intervention Logic was developed.  

Overview of the CCEI 

The  CCEI  is  a  funding  programme  designed  to  support  the  purchase,  maintenance,  and 
upgrading  of  customs  control  equipment  (CCE)3  in  the  European  Union  (EU).  Part  of  the 
Integrated  Border  Management  Fund  (IBMF),  the  CCEI  aims  to  contribute  to  improving  and 
harmonising customs controls across EU Member States. It had an original budget of just above 
EUR  1  billion  for  the  2021-2027  period  and  its  legal  basis  is  defined  in  the  CCEI  Regulation 
with an additional Delegated Regulation for monitoring and evaluation.4 

The CCEI’s general aim is to support the Customs Union and customs authorities in protecting 
financial interests, ensuring security, and facilitating legitimate trade. More specifically, it aims 
to  contribute  to  adequate  and  equivalent  customs  controls  through  transparent  equipment 
purchases, maintenance, and upgrades. Under the CCEI, Member States receive up to 80% in EU 
co-financing  for  CCE.  Eligible  equipment  includes  equipment  for  non-intrusive  inspection, 
hidden  object  detection,  radiation  detection,  laboratory  analysis,  and  various  other  customs 
control  purposes.  The  CCEI  supports  both  Border  Crossing  Points  (BCPs)  and  customs 
Laboratories (thereafter Labs). 

In terms of the implementation of the Instrument, CCEI grants are awarded to national customs 
authorities based on calls for proposals. Since the CCEI has been launched in 2021, 42 projects 
have been supported under the first CCEI call, providing over EUR 273 million of co-funding. 
By  the  end  of  2024,  grant  agreements  under  the  second  call  had  been  signed  or  were  in  the 
process of being signed. A third CCEI call is expected to be launched in 2026.  

The table below provides a high-level overview and summary of the CCEI’s key characteristics.  

3 Customs Control Equipment (CCE) is used interchangeably with ‘equipment’ throughout this report. Both terms 

can be assumed to be synonymous.  

4 Commission Delegated Regulation (EU) 2022/1528 of 4 July 2022 supplementing Regulation (EU) 2021/1077 of 
the  European  Parliament  and  of  the  Council  with  provisions  on  the  establishment  of  a  monitoring  and 
evaluation framework. 

2 

 
 
 
 
 
 
 
 
Table 1: Key features of the CCEI 

Aspect 

Overview 

Budget  and  legal 
base 

Aims 
objectives 

and 

The  source  of  funding  for  the  CCEI  is  the  Integrated  Border  Management  Fund 
(IBMF),  a  programme  that  makes  available  EUR  6.24  billion  for  the  2021-2027 
Multi-annual  Financial  Framework  (MFF)  for  the  purpose  of  improving  European 
integrated  border  management.  It  comprises  two  strands,  the  Border  Management 
and  Visa  Instrument  (BMVI)  focusing  on  the  control  of  persons  crossing  the  EU 
external  borders,  and  the  CCEI  focusing  on  the  customs  controls  on  cross-border 
movement of goods.  
The  legal  base  for  CCEI  is  the  CCEI  Regulation,  and  it  has  a  budget  of  just  over 
EUR  1  billion  (EUR 1,006,407,000,  to  be  precise)  for  the  current  MFF  (in  2021 
prices).  In  addition,  a  Delegated  Regulation  codifies  the  indicators  defined  in  the 
CCEI’s monitoring and evaluation framework (discussed below).  

The CCEI provides financial support for the purchase, maintenance and upgrading of 
customs  control  equipment,  with  a  view  to  the  IBMF  and  long-term  aim  of  the 
harmonised  application  of  customs  controls  by  the  Member  States.  A  fundamental 
principle  is  that  the  Customs  Union  is  only  as  strong  as  its  weakest  link  –
equivalent customs control equipment is therefore needed to prevent the diversion of 
(illicit) trade towards entry points with less robust controls.  
Its  general  objective  is  to  support  the  Customs  Union  and  customs  authorities  in 
their  mission,  which  is  to  (i)  protect  the  financial  and  economic  interests  of  the 
European  Union  and  its  Member  States,  (ii)  ensure  security  and  safety  within  the 
Union  and  (iii)  to  protect  the  Union  from  illegal  trade  while  facilitating  legitimate 
business activity.  
Progress towards the general objective should come about through the achievement 
of a specific objective, which is to “contribute to adequate and equivalent results of 
customs  controls  through  the  transparent  purchase,  maintenance  and  upgrading  of 
relevant  and  reliable  state-of-the-art  customs  control equipment that  is  secure,  safe 
and  environmental-friendly,  thereby  helping  the  customs  authorities  act  as  one  to 
protect the interests of the Union”.  

3 

 
 
 
 
 
Aspect 

Overview 

Eligible purchases 

The vast majority of the CCEI budget is devoted to the purchase, maintenance and 
upgrade of customs control equipment itself. The support is provided with up to 80% 
co-financing for equipment that meets the criteria laid out in the CCEI Regulation; 
funding  in  excess  of  the  80%  ceiling  can  only  be  granted  “in  duly  justified 
exceptional circumstances” (Article 8). Article 6(1)(b) specifies that the equipment 
must  address  at  least  one  of  several  purposes,  namely  (i)  non-intrusive  inspection, 
(ii)  indication  of  hidden  objects  on  humans;  (iii)  radiation  detection  and  nuclide 
identification;  (iv)  analysis  of  samples  in  laboratories;  (v)  sampling  and  field 
analysis  of  samples;  (vi) handheld  search.  Annex  I  of  the  Regulation  defines  an 
indicative  list  of  the  types  of  equipment  that  can  be  eligible,  with  an  emphasis  on 
limiting  the  support  to  equipment  for  customs  controls  rather  than  more  general 
equipment  needs  of  customs  authorities.  The  CCEI  supports  equipment  for  both 
BCPs and customs laboratories.  
More  specific  priorities  and  requirements  concerning  the  equipment  are  set  out  in 
Multiannual  Work  Programmes  (MAWPs)  and  associated  calls  for  proposals,  of 
which there have been two so far, for 2021-2022 and 2023-2024.  
Aside  from  the  funding  for  customs  control  equipment,  a  small  proportion  of  the 
CCEI budget is also allocated to flanking activities related to monitoring, evaluation 
and control/audit; studies, events and communication. 

4 

 
 
 
 
 
Aspect 

Overview 

Implementation 
modalities  

The  CCEI  uses  the  modality  of  direct  management  by  the  Commission  services. 
The  vast  majority  of  the  funding  is  implemented  via  grant  agreements  with  the 
Member  States,  which  then  purchase  designated  customs  control  equipment  or 
related services (maintenance / upgrade) according to the relevant EU and  national 
procurement legislation, rules and procedures. The grants are awarded on the basis 
of  applications  in  response  to  calls  for  proposals.  In  terms  of  payment  modalities, 
after  the  signature  of  the  grant  50%  of  the  grant  amount  is  paid  as  pre-financing 
while the remaining  50% is paid at the end of the project after the approval of the 
final report.  
To  assist  in  the  CCEI’s  implementation,  DG  TAXUD  has  established  a  dedicated 
expert  group  –  the  CCEI  Coordination  Group  –  made  up  of  representatives  of 
national  customs  administrations  from  all  27  Member  States.  Its  objectives  are  to 
discuss and  adopt  policy  guidelines,  provide updates on  implementation status  and 
related activities, and, as necessary, consult with and notify the Member States. To 
encourage  cooperation  and  progress,  17  concrete  ‘deliverables’  providing  topical 
guidance  (e.g.,  on  the  procurement  of  customs  control  equipment;  safety,  security, 
environmental and interoperability of the equipment; co-sharing of equipment) were 
defined  at  the  outset,  for  which  individual  Member  States  take  responsibility  and 
gather input from others as needed5.  
In  line  with  Article  12(2)  of  the  CCEI  Regulation,  implementation  is  further 
supported  by  a  comprehensive  monitoring  and  evaluation  framework,  whose 
modalities  are  further  defined  in  the  Delegated  Regulation  ((EU)2022/1528)  and 
Staff Working Document (SWD(2022)314). This describes the CCEI’s intervention 
logic,  defines  indicators  and  sub-indicators  at  output,  results  and  impact  levels. 
Crucially, the Regulation requires recipients of funding to provide the data to inform 
the  indicators.  A  CCEI  Data  Model  has  been  developed  as  part  of  an  integrated 
approach  to  data  collection,  processing  and  reporting  throughout  the  programming 
cycle.  Inter  alia,  the  results  of  ongoing  monitoring  are  published  in  the  form  of 
Annual Progress Reports, so far for 2021, 2022 and 2023.  

Intervention logic of the CCEI 

An  intervention  logic  was  developed  ex-ante  as  part  of  the  Monitoring  and  Evaluation 
Framework  (MEF) for the CCEI, as  reproduced  in  the figure below.  It provides a step-by-step 
overview of the programme’s causal chains and overall path to achieving its intended objectives.  

5 Minutes of the kick-off meeting of the CCEI Coordination Group, 12-13 July 2021. 

5 

 
 
 
 
 
 
 
Figure 1: The CCEI’s Intervention Logic  

Source: CCEI Monitoring and Evaluation Framework, SWD(2022) 314 final. 

6 

 
 
 
 
 
 
The  following  bullet  points  concisely  set  out  the  different  stages  of  the  intervention  logic, 
considering the intermediate steps expected to be important for the intervention to be realised as 
envisaged: 

•  Inputs: The CCEI was designed to rely on three major inputs, namely financial resources 
(the EUR 1 billion budget for grants, complemented by Member States spending), human 
resources  (from  both  the  European  Commission  and  national  authorities),  and  data 
(complete  and  accurate  information  about  gaps  and  needs  surrounding  customs 
equipment). 

•  Activities:  The  CCEI’s  primary  activity  was  intended  to  be  the  provision  of  financial 
support  to  Member  States  via  grants  for  the  purchase,  maintenance,  and  upgrade  of 
customs  control  equipment.  Success  at  this  level  was  expected  to  depend  on  the 
Commission’s ability to organise calls for proposals and the capacity of Member States to 
apply for and handle the grants.  

•  Outputs:  The  main  intended  output  was  that  Member  States  customs  offices  would  be 
equipped  with  adequate  customs  control  equipment.  The  progression  from  activities  to 
outputs  was  expected  to  be  subject  to  several  factors,  including  Member  States’ 
administrative capacity,  equipment  availability, differences in  resources across Member 
States, and potential geopolitical influences on needs and priorities. 

•  Results:  The  equipment  purchased  was  intended  to  contribute  to  two  main  results, 
namely  adequate  customs  controls  leadings  to  equivalent  results  at  the  EU’s  external 
borders and better implementation of the Customs Risk Management Framework, leading 
to harmonised application of customs controls. The administrative capacity and resources 
of national authorities were recognised as crucial factors for these results to materialise.  

•  Impacts: The CCEI was designed to contribute to three long-term impacts aligned with 
the Customs Union’s mission, namely protection of the financial and economic interests 
of  the  EU  and  its  Member  States,  ensuring  the  safety  and  security  of  the  EU  and  its 
residents, and facilitation of legitimate business activities while preventing illegal trade. 

Several  key  assumptions  underpinning  the  causal  chain  of  the  abovementioned  Intervention 
Logic were identified, namely: 

•  Budget  adequacy:  The  allocated  CCEI  budget  of  circa  EUR  1  billion  is  sufficient  to 
address performance gaps by purchasing, maintaining, and upgrading necessary CCE in 
the seven-year period. 

•  Human resources: Both the European Commission and Member States commit adequate 

and competent human resources to manage and implement the CCEI effectively. 

•  National capacity: Member States have the necessary resources, expertise, and capacity 

to co-finance and actively participate in the implementation of the CCEI. 

•  Alignment with long-term vision:  Resources are used in  a manner  consistent  with  the 
long-term  goal  of  achieving  equivalent  results  in  customs  controls  across  the  EU’s 
external borders. 

7 

 
 
•  Support  from  the  Customs  Programme:  The Customs Programme  provides  adequate 
support  for  activities  such  as  needs  assessments,  training,  and  expert  pools,  which  are 
essential for the CCEI’s success. 

•  Needs assessment methodology: The needs assessment process linked to the data model 
is  continuously  improved,  based  on  expert  input,  and  ensures  the  collection  of 
comparable and relevant data. 

•  Transparent  fund  allocation:  Funds  are  allocated  transparently  based  on  logical  and 
coherent  award  criteria,  focusing  on  identified  priorities  and  ensuring  relevance  and 
added value. 

•  Equipment use and reporting: Purchased equipment is primarily used for its intended 
purpose,  and  Member  States  commit  to  achieving  pre-defined  results,  reporting  on 
equipment use and outcomes as required. 

In addition to the causal chain and its associated assumptions, a number of external factors that 
may have an impact on the implementation and results of the CCEI are also considered. These 
were  also  defined  as  part  of  the  Intervention  Logic  in  the  MEF,  and  can  be  summarised  as 
follows: 

•  Customs  Risk  Management  Framework:  The  effectiveness  of  the  CCEI  depends  on 
the  continued  functionality  of  the  Customs  Risk  Management  Framework,  which 
underpins risk-based customs controls. 

•  Complementary with  relevant EU policies and programmes:  The CCEI’s success  is 
linked to the effective coordination and synergy with other EU programmes, such as the 
Border  Management  and  Visa  Instrument  (BMVI),  the  Union  Anti-Fraud  Programme, 
Horizon  Europe,  and  the  Recovery  and  Resilience  Facility  (RRF).  These  programmes 
must complement the CCEI to avoid duplication and enhance overall and effective border 
management. 

•  National-level  challenges:  Delays  in  public  procurement  processes,  administrative 
burdens,  and  capacity  constraints  at  the  national  level  may  impact  the  timely 
implementation of CCEI projects. 

•  Evolving risks and threats: The dynamic nature of risks and threats at border crossing 
points (e.g., emerging security threats, changes in trade patterns) may require adjustments 
to equipment needs and priorities. 

•  Technological  advancements:  The  availability  of  state-of-the-art,  reliable,  and 
environmentally  friendly  equipment  that  meets  identified  needs  is  critical.  Rapid 
technological  changes  may  influence  the  suitability  and  effectiveness  of  purchased 
equipment. 

•  Inter-agency cooperation: The CCEI’s effectiveness may be influenced by the level of 
cooperation  between  customs  authorities  and  other  border  management  agencies, 
particularly in the shared use of equipment and interoperability of systems. 

8 

 
 
•  Global  trade  and  supply  chain  trends:  Factors  such  as  the  rise  of  e-commerce, 
digitalisation,  and  resilience  to  cyber-attacks  may  impact  the  demands  on  customs 
controls and the relevance of the equipment funded by the CCEI. 

This intervention logic and its constituent parts serve as a framework for understanding how the 
CCEI  was  intended  to  function,  providing  a  reference  point  for  the  evaluation  to  assess  the 
programme’s  design  and  implementation  against  its  original  objectives  and  intended  causal 
chain. As such, it is used as analytical tool underpinning parts of the narrative presenting the key 
evaluation  findings  and  in  the  detailed  responses  to  the  evaluation  questions  (Annex  3, 
particularly the analysis of effectiveness).  

2.2 Point(s) of comparison  

This chapter considers potential points of comparison against which the CCEI can be assessed. 
Indeed,  to  compare  actual  performance  a  baseline  is  generally  needed  to  provide  a  benchmark 
against which progress can be robustly measured for EU interventions. In the case of the CCEI, 
the  obvious  point  of  comparison  is  the  situation  before  its  creation  in  2021,  i.e.  when  no 
dedicated EU instrument for financial support for customs control equipment existed.  

In principle, there are two main sources for constructing the baseline / point of comparison. The 
first  is  the Commission’s ex-ante  Impact  Assessment, which was  written in  2018 and analyses 
the  problems  the  CCEI  is  intended  to  address.  The  second  is  the  MEF  data,  as  DG  TAXUD 
intended to  use the data provided by Member States in  early 2022 as part  of their applications 
under  the  first  call  to  provide  a  baseline  against  which  progress  throughout  the  CCEI’s 
implementation could be measured. However, as described further below in this document, both 
sources are subject to issues and limitations. Nevertheless, by considering elements of both, this 
chapter aims to provide points which can be used to frame and interpret the evaluation findings. 

The CCEI’s impact assessment 

European Commission’s ex-ante Impact Assessments are often a useful source of information on 
the situation before an EU intervention was launched (i.e. the baseline scenario). However, in the 
case  of  the  CCEI,  the  Impact  Assessment6  was  carried  out  jointly  for  four  instruments  and 
contains little information (and no quantitative data at all) specifically on the situation as regards 
customs equipment. With respect to the CCEI specifically, it asserts that, without a suitable EU 
intervention, “imbalances that exist between Member States, due to differences in the capacities 
and  resources  available”,  and  the  fact  that  “several  EU  Member  States  suffer  from  the  severe 
shortage of customs control equipment”, could not be effectively addressed.7 Such disparities in 

6 European Commission (2018): Impact Assessment accompanying the document Proposal for a Regulation of the 
European  Parliament  and  of  the  Council  establishing  the  Asylum  and  Migration  Fund;  Proposal  for  a 
Regulation of the European Parliament and of the Council establishing the Internal Security Fund; Proposal for 
a  Regulation  of  the  European  Parliament  and  of  the  Council  establishing,  as  part  of  the  Integrated  Border 
Management  Fund,  the  instrument  for  financial  support  for  border  management  and  visa;  Proposal  for  a 
Regulation  of  the  European  Parliament  and  of  the  Council  establishing,  as  part  of  the  Integrated  Border 
Management Fund, the instrument for financial support for customs control equipment. SWD(2018) 347 final 

7  The  Impact  Assessment  illustrates  this  point  by  using  the  example  of  customs  services  of  the  EU  Eastern  and 
South-Eastern  Land  Borders,  where  a  2017  Customs  2020  Programme  activity  found  that  53%  of  the  EU 
Customs BCPs lacked automated number plate/container number recognition systems (ANPRS) that would be 

9 

 
 
 
 
available  control  equipment  allows  customs  "shopping",  which  only  a  “high  degree  of 
cooperation and coordination […], ideally at Union level”, could effectively address.  

In view of this, the Impact Assessment provides relatively general information on the needs the 
CCEI is meant to address, but few specifics as to the extent of those needs. Data on this is being 
collected  via  the  CCEI  data  model  itself,  as  Member  States  are  to  submit  data  on  the  actual 
equipment that is available at BCPs and Labs as part of their funding applications. This data is 
reviewed and discussed in this next sub-section.  

Inventory data 

A  useful  point  of  comparison  against  which  to  assess  the  CCEI’s  progress  is  the  pre-CCEI 
‘inventory data’. This refers to the  existing  customs control equipment,  i.e. the  equipment  that 
Member States already disposed of, and which they were required to report as part of their CCEI 
applications  (Sheet  3  in  Part  B).  This  data  was  to  be  provided  by  customs  administrations 
showing  the  number  and  type  of  equipment  available  and/or  in  use  at  each  BCP  and  customs 
laboratory. Due to the sensitive nature of this data the present analysis considers the aggregated 
data.  

With respect to BCPs, as shown in table below, the total number of equipment available in the 
five  main  categories  that  are  eligible  for  CCEI  co-financing  across  the  EU-27  was  6,480. 
Radiation  and  nuclear  type  equipment  accounted  for  the  highest  number,  with  2,900  pieces  of 
equipment representing around 45% of the total equipment. They were followed by non-intrusive 
inspection  equipment  with  1,437  pieces  (just  over  22%).  Trace  detection  and  handheld  search 
amounted to 980 (15%) and 962 (15%), respectively, of the available equipment. Field analysis 
and  spectroscopy  equipment  represented  the  lowest  number  of  equipment  in  absolute  and 
relative terms, with 201 pieces of equipment representing a total of just over 3% of the total CCE 
inventory across the EU-27.  

Table 2: BCP baseline inventory data (2022)  

Equipment category  

Field analysis and spectroscopy 

Handheld Search 

Non-intrusive Inspection 

Radiation and Nuclear 

Trace Detection 

Total 

Number of 
equipment 

% of total 

201 

962 

1,437 

2,900 

980 

6,480 

3.1% 

14.9% 

22.2% 

44.8% 

15.1% 

100% 

needed  for  risk  management;  46%  of  them  lacked  scanners  for  cargo  and  vehicle  inspection  of  trucks  and 
wagons; and 51% lacked personal hand control equipment. 

10 

 
 
 
The inventory data for equipment of customs laboratories is shown below. As can be seen, out of 
the  total  of  5,436  pieces  of  equipment,  the  largest  proportion  was  “general”  laboratory 
equipment, followed by analytical instruments and analysers, and chromatography equipment.  

Table 3: Lab baseline inventory data (2022) 

Equipment category  

Analytical Instruments and Analysers 

Chromatography 

General Laboratory Equipment 

Microscopy and macroscopy 

Spectrometry 

Total 

Number of 
equipment 

% of total 

1,340 

1,046 

2,239 

178 

633 

5,436 

24.7% 

19.2% 

41.2% 

3.3% 

11.6% 

100% 

As  regards  relevant  points  of  comparison,  for  several  of  the  indicators  that  are  included  in  the 
MEF,  mid-term  and  long-term  targets  were  defined  (for  2024  and  2027,  respectively).  Where 
possible  and  relevant,  these  targets  are  considered  as  part  of  the  analysis  of  progress  in  the 
ensuing chapters. 

11 

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

This chapter examines the implementation of the CCEI to date focusing on the two Multiannual 
Work  Programmes  (MAWPs)  2021-2022  and  2023-2024.  It  covers  the  objectives,  priorities, 
funding,  and  outcomes  of  the  first  two  calls  launched  in  October  2021  and  December  2023, 
respectively,  alongside  a  preview  of  the  anticipated  third  call  in  2025.  The  first  call  addressed 
urgent  equipment  needs  with  a  short-term  focus,  while  the  second  aimed  for  long-term 
harmonisation of customs controls. The chapter details project progress, equipment acquisitions, 
funding distribution across Member States, and key developments, supported by figures and data 
on co-financing and (effective) implementation timelines. 

General overview 

The  CCEI  has  developed  two  MAWPs  to  date,  namely  the  2021-2022  MAWP  and  the  2023-
2024  MAWP,  each  with  its  own  objectives,  policy  priorities,  budget,  and  expected  outcomes. 
The  CCEI's  implementation  has  been  structured  in  two  stages,  with  each  stage  supported  by  a 
separate funding call aligned with the respective MAWP.  

The  first  call,  launched  in  October  2021,  adopted  a  short-term  approach,  focusing  on  the 
adequacy  of  equipment  to  address  the  most  urgent  needs  and  enhance  the  performance  of 
customs  controls.  In  contrast,  the  second  call,  launched  in  December  2023,  took  a  long-term 
perspective, aiming to achieve the specific objective of ensuring adequate and equivalent levels 
of  customs  control  results.  The  figure  below  puts  the  timing  of  the  first  two  calls  and  their 
implementation in the context of the programming period.   

Figure 2: CCEI Implementation to date  

As  of  mid-2025,  projects  under  the  first  call  were  being  implemented,  with  some  already 
completed. Meanwhile, most grant agreements for the second call were signed in late 2024. The 
time to grant deadline was 30 November 2024 and 42 out of 46 grant agreements were signed on 
time, with the majority of projects scheduled to commence in 20258, one project finalised after 

8 As of mid-2025, only one grant agreement remained to be signed. 

12 

 
 
 
 
the  time-to-grant  deadline  and  three  projects  not  signed  before  the  end  of  2024  due  to  the 
countries’  further  internal  considerations.  All  27  Member  States  have  been  allocated  CCEI 
funding  through  one  or  both  calls,  with  most  benefiting  from  financing  in  both  instances.  The 
following  sections  provides  an  overview  of  each  call,  highlighting  the  main  priorities,  key 
figures, and developments.  

First CCEI call 

The  first  call,  introduced  in  October  2021  as  part  of  the  2021-2022  Multiannual  Work 
Programme  (MAWP),  had  a  short-term  focus  aimed  at  addressing  the  most  urgent  customs 
equipment  needs  of  the  Member  States.  In  particular,  it  sought  to  fill  gaps  in  equipment 
availability or meet clearly identified, unmet needs. This call prioritised three key policy areas: 
(i)  strengthening  and  better  equipping  the  Customs  Union,  (ii)  enhancing  Union  added  value 
through five strategic building blocks, and (iii) promoting innovation and sustainability. The call 
was set to finance the acquisition of equipment for Border Crossing Points (BCPs) and Customs 
Laboratories (Labs). Funding was limited to one project application per Member State, covering 
up  to  20  work  packages  (one  per  BCP),  and  one  project  application  covering  up  to  five  work 
packages  (one  per  Lab).  Moreover,  the  Call  included  a  retroactivity  clause  allowing  Member 
States to apply for co-financing of actions initiated since 1 January 2021.  

Over  the  course  of  the  first  call,  a  total  of  42  projects  were  selected  for  funding  (from  43 
applications).  Grants  were  awarded  to  facilitate  the  procurement,  maintenance,  or  upgrade  of 
over 1,300 pieces of equipment for more than 210 BCPs and over 500 pieces of equipment for 
more than 30 Labs. Of the projects, 20 made use of the retroactivity clause. Regarding the type 
of equipment requested by Member States, the most requested items were radiation and nuclear 
detection devices,  which are considered essential to ensure compliance of the customs controls 
with  safety  requirements  as  well  as  corresponding  to  emerging  new  threats  and  priorities. 
Additionally,  a  significant  number  of  requests  were  made  for  Non-Intrusive  Inspection  (NII) 
Equipment  and X-ray Scanners.  To a lesser  extent,  requests  were  also  made  for  field  analysis, 
spectroscopy,  and  trace  detection  equipment.  For  Labs,  the  requests  were  less  varied,  with 
chromatography equipment being the most frequently requested, followed by general laboratory 
equipment and spectroscopy.  

The total funding allocated to projects was EUR 273.5 million, just under the maximum Union 
contribution of EUR 273.7 million available. This funding was divided into EUR 247.2 million 
for BCP projects, with an average grant size of EUR 10.6 million, while Labs received EUR 26.2 
million in total funding, with an average grant size of EUR 1.5 million. The sizes of individual 
grants  varied  widely,  with  maximum  and  minimum  sizes  for  BCPs  of  EUR  32.2  million  and 
EUR 37,900, respectively, whereas for Labs, they were EUR 4.9 million and EUR 79,200. 

13 

 
 
Figure 3: Overview of CCEI funding awarded per Member State after the first call 

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30.000.000

25.000.000

20.000.000

15.000.000

10.000.000

5.000.000

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BG IT PL NL BE LT FR FI HU PT RO LV SK ES SE HR EE CY IE CZ DE SI AT LU

BCPs

Labs

Regarding  the  distribution  of  grants,  five  countries  –  Bulgaria,  Italy,  Poland,  the  Netherlands, 
and  Belgium  –  ranked  among  the  top  five  in  funding,  being  granted  50%  of  the  total  EU 
contribution  supporting  both  BCPs  and  Labs.  In  contrast,  Austria,  Slovenia,  Luxembourg, 
Germany,  and  Czechia  were  allocated  the  least  funding.  Additionally,  three  countries  – 
Denmark, Greece, and Malta – did not apply for funding in the first call.  

Implementation  of  proposal  evaluation  and  grants  preparation  proceeded  on  schedule.  The 
average "time to inform" (TTI) – the time taken to notify beneficiaries about the outcome of their 
proposal  –  was  125  days  after  the  closing  date  for  the  call,  which  is  58  days  ahead  of  DG 
TAXUD’s  target.  Furthermore,  the  average  “time  to  sign”  was  124  days,  without  a  specific 
target, while the average "time to grant" (TTG) was 251 days from the call closing, which is 24 
days before the target. 

The grants approved in the first call had durations initially set at ranging from 12 to 36 months, 
with an average of 31 months. Over half of the projects – 29 in total (69%) – had durations of 36 
months, while 13 (31%) had a shorter duration, with six (46%) of them lasting 24 months. From 
the  42  first  call  projects  as  of  May  2025,  twenty  (47.6%)  had  an  amendment  extending  the 
duration of the grant  agreement. The extensions  range from  a period of three to  thirty months, 
making  some  project  last  five  years  and  one  even  five  and  a  half  years.  Additionally,  some 
amendments  focused  solely  on  changes  to  the  type  of  equipment  to  be  purchased  or  the 
designated  BCP  for  deployment.  As  of  August  2025,  12  projects  have  been  completed  (29%) 
with  an  approved  final  project  implementation  report.  Most  of  the  remaining  projects  (13)  are 
now expected to finish in 2025, while 12 are projected to conclude in 2026 and four in 2027.  

Regarding  the  equipment  itself,  based  on  data  submitted  by  the  Member  States,  by  the  end  of 
2024, a total of 907 pieces of equipment had been purchased, maintained, or upgraded through 
CCEI funds. Regarding BCPs, 573 pieces of equipment have been co-funded, the majority being 
new  purchases  (546  purchased,  20  maintained,  and  7  upgraded),  representing  41%  of  the  total 

14 

 
 
 
 
 
 
target  under  the  first  call.  For  Labs,  even  greater  progress  has  been  made,  with  334  pieces  of 
equipment  supported  (299  purchased  and  35  maintained),  reaching  64%  of  the  target.  The 
highest  numbers to  date correspond to  radiation detection and nuclide identification equipment 
(227  units  purchased,  maintained,  or  upgraded)  and  non-intrusive  inspection  equipment  (175 
units) for BCPs, as well as analytical instruments and analysers (110 units) for Labs. 

Second CCEI call 

The second call, launched under the 2023-2024 MAWP and closed in February 2024, focused on 
the long-term harmonisation of customs controls. It was designed to encourage the multi-purpose 
use  of  funded  equipment  to  achieve  five  priorities:  (i)  ensuring  safety  and  security,  (ii) 
strengthening  customs  authorities’  ability  to  manage  and  adapt  to  international  crises,  (iii) 
addressing the challenges posed by the exponential growth of e-commerce, (iv) contributing to 
the  European  Green  Deal,  and  (v)  advancing  innovation  in  customs  control  equipment, 
particularly regarding interoperability. 

This  call  was  informed  by  the  data  collected  in  the  first  call,  which  aimed  to  map 
comprehensively  the  entire  Customs  Union.  Building  on  this  data  and  the  five  identified 
priorities,  DG  TAXUD  provided  tailored  guidance  on  equipment  for  BCPs  and  Labs  for  each 
Member State. As a result, the second call was designed to be implemented in a more targeted 
manner.  

Security,  including  cybersecurity,  of  the  equipment  funded  by  the  Instrument—identified  as  a 
key  concern  from  the  programme’s  outset—took  on  greater  importance  for  this  call.  Security 
requirements  for  the  equipment  were  further  strengthened  in  this  regard,  with  each  BCP  work 
package required to demonstrate how it addresses this aspect.  

As  in  the  previous  call,  in  the  second  call  Member  States  were  asked  to  submit  separate 
applications for BCPs (with up to 20 work packages) and Labs (with up to five work packages). 
After  the  evaluation  of  the  submitted  proposals  47  projects  (from  47  applications)  from  the 
second call had been selected for funding, 25 of which were for BCPs and 22 for Labs.  

In total, Member States requested over EUR 303 million in grants, 86% of which was for BCPs. 
In  the  case  of  Labs,  funding  requests  saw  an  increase  of  over  50%.  Given  that  the  financial 
envelope  for  grants  was  around  EUR  284  million,  the  call  was  oversubscribed  in  terms  of  the 
level  of  funding.  While  all  applications  were  accepted,  23  of  them  had  their  budgets  reduced. 
The average grant size awarded by the EC was approximately EUR 6.2 million (EUR 9.9 million 
for BCPs and  EUR  1.7  million  for Labs). As  with  the first  call, grant  sizes were very diverse, 
ranging from EUR 285,360 to EUR 25.5 million for BCPs, and EUR 64,000 to EUR 5.7 million 
for Labs. 

15 

 
 
Figure 4: Overview of CCEI funding recommended per Member State after the 2nd Call  

30.000.000

25.000.000

20.000.000

15.000.000

10.000.000

5.000.000

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Labs

The  second  call,  similarly  to  the  first  one,  proceeded  mostly  on  schedule,  albeit  with  some 
delays.  More  specifically,  the  average  "time  to  inform"  was  124  days  after  the  second  call’s 
closing date, 59 days ahead of the DG TAXUD target. The average "time to sign" was 133 days, 
not taking into account four grants that experienced additional delays for various reasons outside 
the control of DG TAXUD9. The average "time to grant" was 257 days from the call closing, 18 
days ahead of the target – also without the above mentioned four grants. 

Project  length  is  more  standardised  compared  to  the  first  call.  87%  of  the  projects  have  a  set 
duration  of  36  months  (projected  to  end  in  the  period  2027-2028)  –  the  longest  timeframe  – 
leading to a slight increase in the average duration (33,6 months) than in the first call.  

Considering  participation  across  the  two  calls,  three  countries  –  Bulgaria,  Poland,  and  the 
Netherlands – have been the top recipients, ranked among the top five in terms of grant funding 
on both occasions. Additionally, Denmark, Greece, and Malta, which did  not participate in the 
first call, took part in the second. In contrast, Estonia and Portugal participated in the first call 
but not in the second. 

Third CCEI call 

Looking ahead, the third CCEI call is planned to be launched in 2026, following the adoption of 
the  next  CCEI  Work  Programme.  The  European  Commission  Communication  "A 
comprehensive EU toolbox for safe and sustainable e-commerce" provides some insights into the 

9 The four grants are as follows: two to Belgium (one for BCPs and one for laboratories), one BCP grant to Bulgaria, 
and one BCP grant to Luxembourg. The signature of the two Belgian grants were delayed after a request from 
the applicant Member State. The signature of the Luxembourgish grant was delayed as the Member State was 
invited for grant preparation starting in December 2024. 

16 

 
 
 
 
 
 
 
possible  third  call.10  The  Communication  outlines  the  European  Commission's  strategy  and 
proposed  measures  to  address  the  challenges  posed  by  the  rapid  growth  of  e-commerce, 
particularly the import of low-value goods directly shipped to consumers in the EU. According 
to the Communication, the CCEI Work Programme 2025 is likely to include “a dedicated call on 
e-commerce with a budget of EUR 100 million”. The purpose of this call would be to support the 
enforcement  of  customs  controls  and  the  detection  of  non-compliant  and  dangerous  products 
imported through e-commerce. 

10 European Commission. (2025). A comprehensive EU toolbox for safe and sustainable e-commerce (COM(2025) 

37 final).  

17 

 
 
 
 
 
4.  EVALUATION FINDINGS (ANALYTICAL PART) 

This chapter presents the main findings of the interim evaluation that assessed the performance 
of  the  CCEI  against  the  five  evaluation  criteria:  effectiveness,  efficiency,  relevance,  coherence 
and EU added value. The overall analysis is based on evidence from both the  supporting study 
and the Commission’s own sources. The responses to the individual evaluation questions can be 
found in Annex 3).  

4.1 To what extent was the intervention successful and why?  

The  answer  to  this  question  is  based  primarily  on  the  assessment  of  the  effectiveness  of  the 
CCEI,  i.e.  how  successful  it  has  been  in  achieving  or  progressing  towards  its  objectives,  and 
why. To assess this, the evaluation explored the implementation and use of the CCEI to date; the 
design of the instrument; the pace of progress made by CCEI-supported projects and the reasons 
for delays; the early outputs and emerging results; and the extent to which the available funding 
has been allocated in a way that targets key needs and risks. In addition, the response considers 
the CCEI’s efficiency, in particular whether the timeframes, costs and burdens are minimised to 
the greatest extent possible without hampering the instrument’s ability to achieve its objectives; 
and  its  coherence,  both  internally  and  with  regard  to  its  alignment  with  other  relevant  EU 
policies and programmes. 

Two waves of projects to date have seen the CCEI used by all Member States 

The activities foreseen under the CCEI have been rolled out broadly as anticipated. To date, two 
Multi-Annual  Work  Programmes  (MAWPs)  and  corresponding  calls  for  proposal  have  been 
issued under the CCEI. All 27 Member States have now received CCEI funding (22 under both 
calls, two only under the first and three only under the second call). The Member States that did 
not participate in the first call (Denmark, Greece and Malta) provided broadly similar reasons for 
this  –  namely,  a  lack  of  preparedness  within  the  customs  administration  to  deal  with  the 
requirements  of  preparing  and  submitting  a  proposal  within  the  time  available,  and/or  the 
absence of a  comprehensive needs assessment that  could  be used to  determine what  additional 
equipment  should  be  procured.  In  one  case,  there  was  reportedly  also  a  sense  within  the 
administration  that  the  country  did  not  really  need  additional  resources  for  customs  control 
equipment.  All  three Member States did  take part in  the second call, based on a more detailed 
understanding  of  their  needs  and  gaps  that  they  had  developed  in  the  meantime,  and/or  a  re-
assessment  of  their  priorities.  The  Member  States  that  did  not  participate  in  the  second  call 
(Estonia  and  Portugal)  did  so  because  of  delays  in  finalising  their  projects  under  the  first  call, 
which led them to decide they lacked the internal resources to embark on additional projects for 
the time being. 

Under each call, the majority of Member States applied for funding for equipment for both BCPs 
and laboratories, but a few went for only BCPs. Overall, the majority of Member States applied 
for significantly less funding than the maximum of 15% of the total budget available. Under the 
first call, on average the participating Member States applied for around EUR 11.4 million of co-
financing  (compared  to  the  maximum  of  EUR  40.7  million).  The  amounts  applied  for  were  a 
little but not significantly higher under the second call. As a result, as shown in the table below, 
under both calls the demand for funding was only slightly greater than the supply: the first call 
was oversubscribed by less than 1%, and the second by 8%. Demand for support for BCPs was a 
little higher than the 80% of the total call budgets that had been earmarked for this, and demand 

18 

 
 
for laboratories was lower than the 20% that were set aside. Funds were flexibly re-allocated in 
line with demand to ensure optimal budget utilisation.  

Table 4: Aggregated demand for CCEI co-financing per call 

Amounts available and applied for (in EUR ) 

First call (2021-2022) 

Second call (2023-2024) 

Available budget for BCPs 

Applied for BCPs by MS 

Available budget for laboratories 

Applied for laboratories by MS 

Available budget – Total  

Applied for by MS – Total  

217,211,200 

247,193,266 

54,302,800 

26,282,097 

271,514,000 

273,475,363 

227,170,400 

266,382,600 

56,792,600 

40,726,128 

283,963,000 

307,108,728 

The information gleaned from questionnaire responses, interviews and case studies confirms that 
Member States took different approaches to their applications, and this is reflected in the amount 
of  co-financing  they  requested.  In  response  to  the  first  call,  some  submitted  highly  ambitious 
projects that clearly went above and beyond what they would have been able to procure without 
CCEI  support.  Other  Member  States  opted  for  a  more  cautious  approach,  for  various  reasons, 
including a lack of familiarity with the Instrument, and uncertainty about their ability to secure 
national  funds beyond what  had  already been  approved for  existing  plans to  purchase  customs 
control equipment. They chose to only apply for relatively modest amounts of EU co-financing. 
However, in several cases, Member States became more proactive and ambitious in the second 
call,  applying  for  higher  amounts  for  more  expensive  equipment  that  would  have  been 
challenging  to  finance  solely  through  national  budgets.  On  the  other  hand,  difficulties  and/or 
delays  encountered  in  projects  under  the  first  call  appear  to  have  led  a  few  Member  States  to 
scale back their ambitions under the second call, or even not participate at all. 

The fact that the CCEI has now been / is being used by all 27 Member States confirms it is seen 
as  a  valuable  and  relevant  instrument  by  customs  administrations  across  the  EU.  On  the  other 
hand,  the  fact  that  the  level  of  demand  under  both  calls  to  date  has  been  relatively  low  (only 
marginally  higher  than  the  available  budget)  shows  that  the  absorption  capacity  of  Member 
States is not unlimited. 

Overall design of the instrument appropriate and effective 

By and large, the design of the CCEI has proven to be appropriate and fit for purpose. There is 
no evidence to suggest that any of the main design elements – including the available budget, co-
financing  rate,  eligibility  criteria  and  priorities,  and  the  management  and  implementation 
framework  –  have  acted  as  a  significant  constraint  to  the  implementation  of  the  CCEI,  with 
beneficiaries (namely the national customs administrations of the EU Member States) providing 
almost entirely positive feedback on all of them. 

The CCEI budget has been considered adequate. Over 90% of respondents to the questionnaire 
for  national  customs  administrations  agreed  (almost  half  of  them  “strongly”)  that  the  CCEI 
budget is sufficient to fill performance gaps and make a difference to customs controls in their 

19 

 
 
 
Member State.  The  fact  that  the demand for co-financing  has  been so closely  aligned with  the 
supply provides further  evidence that the  amount  of funding available is sufficient  to  meet  the 
Member States’ main needs. 

As for the co-financing rate (up to 80% of the total eligible costs of an action), several national 
customs administrations reported that obtaining the remaining 20% from national budgets can be 
challenging, which has  constrained the scope and level of ambition of some projects under the 
first and second calls. Only 55% of questionnaire respondents agreed – and 19% disagreed – that 
it is straightforward to obtain approval for the co-funding needed at national level to take part in 
the  CCEI.  A  few  noted  that  a  higher  co-financing  rate  (potentially  even  100%)  would  help  to 
encourage Member States to procure more highly innovative, cutting-edge (and thus expensive) 
equipment.  On  the  other  hand,  most  acknowledged  that  the  co-financing  rate  is  already  quite 
generous, and that it would be unrealistic to expect the EU to purchase equipment for BCPs and 
laboratories  without  any  national  contribution  (since  EU  programmes  typically  require  co-
funding as a way of incentivising engagement and buy-in). 

National customs authorities had a mostly positive view on how the eligibility criteria align with 
their  equipment  needs  and  priorities.  Based  on  their  questionnaire  responses,  the  level  of 
alignment is especially high for laboratory equipment, but only 30% found the criteria for BCP 
equipment to be “fully” aligned with their needs.  

Figure 5: To what extent do the eligibility criteria align with the equipment needs and priorities 
of your administration? 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Eligibility criteria for BCPs

30%

53%

10%

7%

Eligibility criteria for customs laboratories

52%

22%

4%

22%

Fully aligned

Mostly aligned

Partly aligned

Not aligned at all

Don’t know

Source: Questionnaire responses from national customs administrations 

Member States identified additional needs that are not or only partly eligible under the current 
criteria. The main gaps are listed below. 

Several  Member  States  saw  the  ineligibility  of  costs  associated  with  infrastructure  and/or 
training  as  a  constraint,  since  some  equipment  can  only  be  used  (effectively)  if  the  relevant 
infrastructure  (e.g.  new  lanes  for  lorries)  and/or  suitably  qualified  staff  is  available.  A  few 
interviewees believed that this might lead some administrations to prioritise relatively easy to use 
and install (in particular mobile or handheld) equipment when applying for CCEI funding, even 
if more advanced equipment would align more closely with needs, other things being equal.  

•  Several  Member  States  applied  (or  would  have  liked  to  apply)  for  co-financing  for  IT 
equipment  (including  both  hardware  and  software)  that  can  facilitate  the  effective 
functioning  of  BCP  equipment,  in  particular  by  enabling  the  connection  between, 

20 

 
 
 
integration, centralised control and/or analysis of equipment at, and data / images from, 
different BCPs. However, such equipment is not eligible, and the associated costs were 
therefore excluded from CCEI grants.  

•  A few Member States expressed disappointment that the inclusion of maintenance costs 
for  existing  equipment  were  not  allowed  under  the  second  CCEI  call  that  limited  this 
possibility for new equipment and equipment purchased under the first call.11 

•  More  generally,  a  few  administrations  argued  that  the  eligibility  criteria  should  be 
defined more flexibly and dynamically, to better allow for the inclusion of cutting-edge, 
innovative,  potentially  “game  changing”  technologies  such  as  AI-powered  systems  or 
drones. 

It  should  be  noted  that  some  of  these  apparent  “gaps”  in  terms  of  what  is  eligible  for  CCEI 
funding  can  potentially  be  addressed  via  other  EU  programmes  and  funds,  including  the  EU 
Anti-Fraud Programme (which a few Member States reported having used to co-finance e.g. IT 
equipment)  and  the  Recovery  and  Resilience  Facility  (which  at  least  one  Member  State  was 
considering  using  to  help  fund  infrastructure  necessary  to  install  and  operate  equipment 
purchased through the CCEI).  

The framework for implementing the CCEI (including the process for defining the priorities, the 
work of the CCEI Coordination Group, and in particular the guidance provided by DG TAXUD) 
were viewed favourably  by beneficiaries, and there are no indications that  this has in  any way 
hindered progress. In interviews, almost all national customs authorities were complimentary of 
the  way  the  Commission  manages  the  instrument,  and  especially  of  the  hands-on  support 
provided, and of the flexibility and pragmatism shown, by DG TAXUD project officers.  

There  are  no  concerns  about  the  internal  coherence  of  the  CCEI,  i.e.  the  extent  to  which  its 
various elements are coherent with one another. The CCEI is designed as a relatively “simple” 
instrument,  which  provides  financial  support  for  a  single  core  type  of  activity  (namely,  the 
purchase,  maintenance  and  upgrade  of  customs  control  equipment  by  the  national  customs 
administrations of the 27 EU Member States) according to a clear and sound intervention logic. 
The  supporting  activities  (including  the  meetings  and  deliverables  of  the  CCEI  Coordination 
Group,  and  the  guidance  and  technical  and  administrative  support  provided  to  applicants  and 
grantees by DG TAXUD) are consistent with the instrument’s logic and objectives.  

Significant delays caused primarily by problems with national procurement 

Many  of  the  projects  that  were  supported  by  CCEI  grants  under  the  first  call  are  subject  to 
delays. In May 2025 twenty of the 42 projects (47.6%) under the first call experienced a duration 
extension. Over half (53%) of the projects have been progressing slower than expected according 
to the responses by national customs administrations to the questionnaire.  

The main reasons for these delays were external, i.e. not related to the design or management of 
the CCEI as such. By far the most significant external factor that has hindered the progress made 

11 In the first CCEI call maintenance costs were eligible for existing equipment (up to 20% of the total eligible cost). 
In  the  second  CCEI  call,  for  BCPs  maintenance  cost  eligibility  is  limited  to  equipment  purchased  under  the 
CCEI. For Labs, maintenance costs are eligible for all existing equipment, just like in the first call.  

21 

 
 
 
by  CCEI  projects  to  date  are  difficulties  experienced  with  completing  the  procurement 
procedures  at  national  level.  Only  52%  of  national  customs  authorities  who  responded  to  the 
questionnaire  agreed  that  procurement  processes  at  national  level  function  sufficiently  well  to 
allow  the  effective  purchase  of  the  equipment  in  question.  Member  States  reported  problems 
with  cumbersome  procedures  involving  multiple  permits  and  approvals,  a  lack  of  experts  and 
human  resources  in  the  national  procurement  units,  uncertainty  about  if  and  how  to  exclude 
certain  suppliers  due  to  cybersecurity  concerns,  a  lack  of  bidders,  appeals  or  complaints  from 
unsuccessful  tenderers,  and  budget  freezes  as  factors  that  slowed  down  the  procurement  of 
equipment. Moreover, the case studies showed that these problems were especially prevalent in 
larger projects  that sought  to  procure high  volumes of equipment,  and in projects  that targeted 
equipment that was new and/or innovative for the customs administrations in question, and with 
which they therefore had no or only limited procurement experience. 

A  few  Member  States  also  mentioned  having  encountered  supply  issues,  including  extended 
delivery timelines for equipment at a particular point in time, and rising prices for certain types 
of  equipment.  In  the  relatively  few  cases  where  there  seem  to  have  been  supply  problems, 
bottlenecks may have been partly caused – according to some interviewees – by a simultaneous 
surge in  demand for certain  types of equipment  from several  Member States due to  the CCEI. 
However, this does not appear to have been a very widespread or significant constraint for most 
projects,  and  84%  of  respondents  to  the  questionnaire  for  national  customs  authorities  agreed 
that the required equipment is available on the market. 

Geopolitical challenges and cybersecurity concerns have affected the CCEI 

In three of the ten case studies, as well as in several other projects, cybersecurity concerns were 
reported  to  play  a  significant  role.  Specifically,  there  have  been  and  continue  to  be  significant 
concerns (linked primarily  to  a specific supplier from  China) that sensitive data from  scanning 
equipment and services could be leaked to unauthorised users. In recent years, as concerns have 
emerged and intensified, attempts have increasingly been made to assess the risk profiles of the 
manufacturers and restrict them, if deemed necessary, from procurement procedures for sensitive 
equipment, and especially to ensure that only secure solutions benefit from EU (including CCEI) 
funding.  However,  several  Member  States  have  reported  difficulties  with  achieving  this  in 
practice,  with  national  legislation  reportedly  offering  different,  more  or  less  effective,  ways  of 
addressing  the  concerns.  At  EU  level,  security  and  cybersecurity  protection  of  the  equipment 
funded  was  reaffirmed  in  2023  through  the  work  carried  out  under  the  CCEI  Coordination 
Group, and further clarified in the 2023-2024 CCEI MAWP and in the second call for proposals, 
which provided additional requirements and guidance to increase the stringency of security and 
cybersecurity  requirements,  and  required  the  granting  authority  to  involve  national  security 
services  and  to  request  substantiating  documentation  of  compliance  with  reference  to  key 
security  requirements  (including  the  NIS2  Directive12  and  security  guidance  issued  by  the 
Commission). Nonetheless, some national customs administrations reported a continued lack of 
legal certainty in this area. In certain countries, procurement processes had to be cancelled, re-
launched  and/or  specifically  re-designed  to  avoid  results  deemed  incompatible  with  national 
security priorities. 

12 Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the Union. 

22 

 
 
 
During  interviews,  manufacturers  of  customs  control  equipment  also  noted  difficulties 
navigating  different  rules  and  procedures  across  EU  Member  States,  particularly  for  more 
sensitive  technologies,  and  expressed  a  desire  for  clearer  guidance  on  topics  like  licensing 
requirements,  cybersecurity  standards,  and  how  to  get  new  technologies  approved  for  CCEI 
funding. Several manufacturers expressed concern about competition from non-EU (particularly 
the  above-mentioned  Chinese)  suppliers  based  primarily  on  price,  and  expressed  a  desire  for 
procurement criteria to give more weight to factors like security, quality, and European content, 
rather  than  focusing  primarily  on  price  (which  is  also  in  line  with  the  Commission  guidance 
provided to the Member States). Some also suggested incentives or preferences for Europe-based 
manufacturers to support EU strategic autonomy in this sector. 

Another geopolitical factor that has affected the implementation of the CCEI is the Russian full-
scale  invasion  of  Ukraine,  which  has  significantly  influenced  the  customs  control  equipment 
procurement  strategies  and  priorities  of  certain  Member  States,  especially  those  that  share  a 
border with Ukraine, Belarus or Russia. In response, the MAWP 2023-2024 included the priority 
“Mitigating  international  conflicts  and  crises”,  with  a  specific  emphasis  on  equipping  BCPs  to 
correctly implement the sanctions imposed against Russia under elevated customs security risks 
(in  other  words,  shifting  focus  from  controlling  imports  to  controlling  exports),  as  well  as 
performing the necessary controls to enable the flow of trade through the EU-Ukraine Solidarity 
Lanes. But some projects under the first MAWP and call were also affected by these factors; for 
example,  the  closure  of  Finland’s  Eastern  border  necessitated  substantial  changes  to  its  BCP 
project, and led the Finnish customs authority to re-focus the equipment away from land BCPs 
bordering  Russia  and  Norway,  and  towards  ports  in  Western  Finland;  these  changes  were  the 
main  reason  for  the  delayed  implementation  of  the  project.  Similarly,  Poland  reported  that  the 
purchase  of  equipment  for  a  specific  BCP  was  abandoned  due  to  the  combined  effects  of  the 
COVID-19 pandemic and the Russian  invasion of Ukraine. On the other  hand, some  countries 
including  Bulgaria  and  Slovakia  reported  that  the  CCEI  had  already  helped  them  address 
challenges resulting from the war. 

The combination of these external factors (problems with national procurement, the geopolitical 
challenges and cybersecurity concerns) made it necessary to amend a significant number of grant 
agreements. The majority of these imply an extension of the project duration, some also involve 
changes  to  the  equipment  to  be  procured,  some  (but  not  all)  of  which  have  decreased  the 
maximum grant value. During interviews, national customs authorities provided mostly positive 
feedback  on  how  DG  TAXUD  has  handled  amendments,  variably  describing  its  approach  as 
flexible, pragmatic and proactive. 

Early outputs and emerging results, but difficulty of measurement 

Despite the delays and implementation hurdles described above, the CCEI has begun to deliver 
tangible  outputs.  Based  on  the  data  submitted  by  the  Member  States,  by  the  end  of  2024,  907 
pieces of equipment had been purchased, maintained or upgraded through CCEI funds (indicator 
OP 1.1). Once all projects under the first call are completed, these numbers are expected to more 
than  double.  The  highest  numbers  to  date  correspond  to  ‘Radiation  detection  and  nuclide 
identification’  (227  units  purchased,  maintained  or  upgraded)  and  ‘Non-intrusive  inspection’ 
(175  units)  equipment  for  BCPs,  and  ‘Analytical  Instruments  and  Analysers’  (110  units)  for 
laboratories.  

23 

 
 
Table 5: Pieces of equipment purchased, maintained or upgraded through CCEI funds 

Equipment supported by the CCEI (as of end 
2024) 

Purchased  Maintained  Upgraded 

Total 

Target 
under call 
1 

% of 
target 
achieved 

BCPs 

Laboratories 

Total 

546 

299 

845 

20 

35 

55 

7 

0 

7 

573 

334 

907 

1,398 

524 

1,922 

41% 

64% 

47% 

DG TAXUD also collects data from Member States on the ‘occupancy rate’ of the CCEI-funded 
equipment (indicator OP 1.2), indicating the frequency of its use (a 100% occupancy rate means 
“daily use”). Analysis of the 2024 data reveals that the actual usage is closely aligned with the 
targets for all equipment types. Equipment at BCPs is used very frequently, with occupancy rates 
above  90%  for  most  categories  of  BCP  equipment.  Occupancy  rates  of  laboratory  equipment 
tend to be a little lower (between 50 and 70%), but also in line with targets. This suggests that, 
overall, the equipment is used extensively and in line with expectations. 

However, judging – let alone measuring quantitatively – the results and impacts of the CCEI is 
difficult given the early stage of implementation. The experience gathered to date shows that all 
of the results indicators defined in the MEF are subject to significant challenges and limitations 
as regards the completeness, quality and/or comparability of the underlying data.13  

Indicator RES 1.1 is intended to measure the specific results achieved by Member States through 
use  of  CCEI  funded  equipment,  by  comparing  actual  results  with  MS’  commitments  (with 
reference  to  baselines  or  targets,  e.g.  in  terms  of  the  number  or  value  of  seizures  of  different 
types  of  goods  or  substances,  the  number  of  controls  conducted  or  the  hit  rate).  The  available 
data shows limited progress, with only between 10% and 21% (depending on the objective) of 
commitments achieved as of 2024. However, it needs to be re-emphasised that the quantity and 
quality  of  the  data  is  poor  due  to  significant  reporting  issues  and  inconsistencies,  meaning  the 
results should not be taken at face value. 

Indicator  RES 1.3  attempts  to  measure  the  degree  of  adherence  of  BCPs’  equipment  to  the 
common  list  of  equipment  that  should  be  available  per  type  of  BCP.  It  is  calculated  by 
comparing the data provided by the MS regarding the equipment that is available and the main 
risks encountered, with targets for recommended equipment levels per BCP. The available data 
shows  a  small  increase  in  the  adherence  rates  (i.e.  the  proportion  of  BCPs  that  have  the 
recommended equipment) for all types of BCPs from the baseline (2022) to 2024, but the rates 
remain low. Between 9% and 17% for air, land, postal, rail and sea BCPs have the recommended 
equipment  levels  that  is  far  below  the  60%  target  set  for  2024.  These  consistently  low  rates 
indicate  that  the  targets  as  defined  are  likely  to  be  unrealistic,  i.e.  overly  ambitious,  and  not 
sufficiently taking into account specificities of individual BCPs and the prevalent risks. 

13 It should be noted that impact indicators have also been defined. However, changes in these indicators  will take 
even longer to emerge, and are even more difficult to attribute to the CCEI; they are therefore not included in 
the Annual CCEI Reports published to date, or considered for the sake of this interim evaluation. 

24 

 
 
 
 
 
Indicator RES 1.4 is about the coverage of risks and threats, and more specifically, the extent to 
which  BCPs  have  the  necessary  equipment  available  to  mitigate  identified  financial  and  non-
financial  risks.  Based  on  the  available  data  for  2024,  the  coverage  rates  vary  significantly 
between  types  of  BCPs  and  risks.  Overall,  mobile  BCPs  generally  demonstrate  the  highest 
coverage across the spectrum of risks and threats considered, suggesting greater effectiveness in 
risk mitigation compared to other types of BCP. However, the data limitations mean care needs 
to be taken when interpreting these results.  

The evaluation attempted to shed further light on the results achieved to date, and on whether the 
CCEI is on track to generating additional results in line with expectations over the remainder of 
the programming period, via the questionnaire, interviews and case studies. In the questionnaire, 
Member States were asked to rate, based on their experience of the CCEI so far and expectations 
for the rest  of the programming  period to  2027, its  likely  contribution to its specific objective, 
which  is  to  “contribute  to  adequate  and  equivalent  results  of  customs  controls  through  the 
transparent  purchase,  maintenance  and  upgrading  of  relevant  and  reliable  state-of-the-art 
customs control  equipment  that is  secure, safe and environmental-friendly, thereby helping the 
customs authorities act as one to protect the interests of the Union”. Nearly three quarters (74%) 
of  respondents  believed  that  the  CCEI  would  make  a  “significant”  contribution  toward  this 
objective; the remainder expected “some” contribution (16%) or responded “don’t know” (10%). 
Not a single respondent believed the CCEI would make only a “small” or no contribution at all. 

National customs administrations were also asked a series of questions about the results achieved 
so far. The responses (see figure below) suggest that the equipment that has been purchased and 
deployed to date is being used effectively and as intended. The majority of respondents reported 
that the equipment has already noticeably improved the performance of both BCPs (especially by 
improving  detection  accuracy,  but  also  by  increasing  the  speed  of,  capacity  for  and  possible 
number  of  controls)  and  customs  laboratories,  although  it  is  worth  noting  that  there  were  a 
relatively high number of neutral or “don’t know” responses to these questions.  

The data on relevant performance metrics that is available for the (few) projects that have been 
finalised  shows 
the  difficulties  of  quantitatively  measuring  and  substantiating  such 
improvements.  For  example,  in  the  case  of  the  Spanish  BCP  project,  which  was  finalised  in 
September 2024, the final report includes data on the number of controls, average process time, 
and % hit rate at the 16 BCPs that received the equipment. This shows that all of these metrics 
increased at most but not all BCPs. According to Spanish customs, the reasons for the variations 
can be manifold, and include changes in traffic volumes (e.g. significant increases in traffic can 
lead  to  longer  average  processing  times).  But  it  is  also  clear  that  some  metrics  are  open  to 
interpretation,  in  particular  the  hit  rate,  which  can  be  influenced  by  many  factors  (including 
possible  deviations  of  illicit  traffic  flows  to  other  BCPs).  It  was  also  noted  that,  when  an  old 
scanner is replaced with a newer one, one would not necessarily expect to see a change in (all of) 
the  metrics.  Overall,  in  the  Spanish  case,  interviewees  felt  that  the  lack  of  progress  on  certain 
indicators  does  not  necessarily  mean  the  equipment  in  question  is  not  used  effectively.  Other 
national customs administrations responded along similar lines. Some also provided examples of 
how the CCEI had facilitated more effective and efficient controls that may not be picked up by 
relatively  crude  standardised  metrics.  For  example,  CCEI  support  enabled  Sweden  to  acquire 
large, fixed scanners for certain key BCPs, and allowed it to redeploy existing mobile scanners to 
other  BCPs,  reportedly  resulting  in  a  more  efficient  overall  distribution  of  resources;  while 
Germany's  acquisition  of  new  substance  detectors  expedited  control  procedures  at  BCPs  by 
reducing reliance on laboratory analyses. 

25 

 
 
On  the  other  hand,  there  were  lower  levels  of  agreement  that  the  CCEI  has  led  to  increased 
standardisation  of  equipment,  more  practical  cooperation  and/or  data  sharing  between  EU 
customs  authorities.  These  are  not  explicit  objectives  of  the  CCEI,  but  are  nonetheless  areas 
where the Instrument was thought to have the potential to make a contribution. However, they 
are not aspects that have been the focus of projects and grants under the first call. On the issue of 
the  lack  of  standardisation,  several  manufacturers  of  customs  control  equipment  who  were 
interviewed  noted  that  different  countries  have  varying  specifications  for  similar  equipment, 
which can lead to inefficiencies and increased costs. On the other hand, a few representatives of 
Member State customs administrations warned that, while a certain level of standardisation may 
be desirable for certain types of equipment, full-scale standardisation of, for example, scanning 
equipment across the EU would fail to take into account the sometimes varying national needs, 
and could  imply  security risks, as criminals  could  also  adapt  to  and learn to  take advantage of 
such common standards.  

Figure 6: If your customs administration has already purchased and deployed customs control 
equipment using one or more CCEI grants, please provide your insight on the results achieved 
so far? 

Source: Questionnaire responses from national customs administrations 

26 

 
 
 
Finally, it is worth considering the extent to which the CCEI has contributed to the procurement 
of  modern  /  innovative  equipment,  and  ensured  the  equipment  is  secure  and  safe  (in  terms  of 
protection  of  data,  cyber-resilience)  and  environmentally-friendly  (including  as  regards  the 
disposal of the replaced equipment). Taking these elements in turn, the questionnaire responses 
from national customs authorities suggest the situation varies somewhat: 

•  91% agreed (incl. 52% “strongly”) that the CCEI encourages and facilitates the purchase 

of innovative, cutting-edge equipment. 

•  87% agreed (incl. 58% “strongly”) that implementation of the CCEI takes due account of 

safety and environmental considerations. 

•  77% agreed (incl. 42% “strongly”) that implementation of the CCEI takes due account of 

data protection, cyber-resilience and the security of the equipment purchased. 

•  However,  only  67%  agreed  (incl.  35%  “strongly”)  that  all  aspects  related  to  the 
equipment, including its security, could be covered by the current procurement rules. 

This  suggests  that,  while  beneficiaries  (i.e.  national  customs)  agree  with  the  importance  of  all 
these  aspects  in  principle,  in  practice  they  do  not  always  play  an  (equally)  important  role  in 
projects and procurements. The case studies and interviews show clearly that some but not all of 
the equipment procured is innovative or cutting-edge; environmental considerations are usually 
considered  but  rarely  as  a  decisive  factor;  and  while  cybersecurity  is  generally  taken  very 
seriously,  many  customs  authorities  felt  ill-equipped  to  effectively  address  concerns  in  this 
respect.  

Targeting funds at key needs and risks: a work in progress 

An  important  element  that  needs  to  be  taken  into  account  to  evaluate  the  effectiveness  of  the 
CCEI is the way needs are assessed and used to determine the allocation of funding. As per the 
CCEI  Regulation  (recital  24),  “implementation  should  be  supported  by  assessments  of  needs” 
with  the  involvement  of  national  customs  authorities  and  based  on  a  clear  methodology;  the 
Commission  should  use  this  information  to  determine  the  allocation  of  the  funds  to  Member 
States,  taking  into  consideration  factors  including  volumes  of  trade,  relevant  risks,  and  the 
administrative  capacity  of  the  customs  authorities.  To  contribute  to  budgetary  discipline,  “the 
conditions  for  the  prioritisation  of  grants  should  be  clearly  defined  and  based  on  such  an 
assessment of needs”, driven by data on the available customs control equipment at each BCP, 
compared with a common list of equipment that should be available (Article 11(4)). 

Priorities  are  defined  in  each  MAWP  to  address  specific  needs.  The  first  (2021-2022)  MAWP 
and  call  corresponded  to  a  short-term  approach  dedicated  to  addressing  the  most  urgent  needs 
and raising customs control performance. To facilitate this, the priorities were kept very general 
and  flexible,  and  Member  States  were  allowed  to  apply  for  funding  retroactively  (i.e.  include 
costs  that  had  already  been  incurred)  to  compensate  for  the  late  adoption  of  the  MFF  and, 
consequently,  the  CCEI  Regulation.  The  second  (2023-2024)  MAWP  and  corresponding  call 
were based on a “comprehensive mapping of the entire Customs Union to determine areas that 
need particular attention”, based on the data collected from Member States in the first call. This 
showed that there were still  urgent  needs (in terms  of missing and inadequate equipment), and 
meant it was “essential to identify concrete policy priorities to ensure targeted and efficient use 
of the available funds.” The priorities of the second call were narrowed to focus on more specific 

27 

 
 
policy areas, namely (1) Safety and Security; (2) Mitigating international conflicts and crises; (3) 
e-Commerce;  (4)  Building  Green  Capabilities;  and  (5) Interoperability  &  Innovation.  For  the 
Safety and Security priority, the call explicitly required “mandatory coverage of at least one of 
the relevant risks/threats.” Thus, while the second call aimed to introduce an increased focus on 
specific  priorities  informed  by  actual  needs,  it  should  be  noted  that  most  (if  not  all)  types  of 
eligible equipment could still be reasonably justified as addressing at least one, and potentially 
several  of  the  five  priorities.  As  such,  these  priorities  did  not  significantly  limit  the  types  of 
equipment which Member States could focus on in their applications for co-financing. 

Focusing the available funding at the  most significant needs is meant to  happen at the level of 
individual proposals and projects, by ensuring the evaluation of applications duly considers the 
extent to which the equipment Member States apply for responds to the main risks and needs. In 
theory,  this  is  achieved  via  the  award  criteria,  in  particular  “Relevance”  and  “Added  value”, 
which  should  ensure  that  the  projects  that  are  most  closely  aligned  with  the  identified  needs 
achieve higher scores, and are thus prioritised for funding.  

However, in the first call, in practice this prioritisation only happened to a very limited extent, 
for the following main reasons: 

•  Very broad priorities: As noted above, the first call was designed to help Member States 
address  their most urgent  equipment  needs and raising performance overall. Therefore, 
national  customs  authorities  were  free  to  apply  for  any  eligible  equipment.  The  case 
studies show that different Member States took different approaches, with some but not 
all of them focusing on the highest risks. Many projects included equipment that had to 
be  replaced  or  added  for  different  reasons  (in  several  cases  taking  advantage  of  the 
retroactivity clause), but not necessarily for especially high-risk BCPs. 

•  No competition: The requested funding for the first call almost exactly matched the total 
budget  available, meaning there was essentially  no competition  for funding, and hence 
no  need  for  the  Commission  to  prioritise  proposals  or  work  packages  that  were  more 
aligned with key needs or risks over others that were less aligned. In essence, Member 
States received co-financing for whatever equipment they chose to apply for, as long as 
it  was  eligible  under  the  CCEI  criteria  and  the  applications  met  minimum  quality 
thresholds. 

• 

Issues with the data: The data on which needs assessments are to be based  – including 
what equipment is currently available at each BCP, compared with what should ideally 
be  available  in  view  of  traffic  volumes  and  risk  profiles  –  is  to  some  extent  fraught. 
Member  States  frequently  struggled  to  interpret  and  provide  all  of  the  data  that  was 
requested, 
reliability  and 
comparability.  In  addition,  the  “ideal”  list  of  equipment  per  BCP  as  defined  (which 
forms  the  basis  for  the  “adherence”  indicator  RES 1.3)  appears  overly  ambitious,  and 
unlikely  to  provide  a  clear  steer  as  to  which  equipment  is  most  needed  to  address  key 
risks and gaps. 

its  comprehensiveness, 

to  concerns  about 

leading 

All  in  all,  therefore,  the  envisaged  data-driven  approach  to  identifying  needs  and  allocating 
funding could only be applied to a very limited extent under the first call. As a result, it is clear 
that, by and large, the first wave of projects responded primarily to national needs and priorities 
as  identified  by  applicants  (i.e.  Member  States)  themselves,  with  very  little  steer  or  corrective 

28 

 
 
action at EU level to ensure they addressed the most pressing needs of the Customs Union as a 
whole. 

In  the  second  call,  the  situation  changed  somewhat.  Based  on  the  data  provided  by  Member 
States  as part of their applications for and reporting on projects  under the first  call  (as well as 
data  from  selected  other  sources),  DG  TAXUD  provided  country-specific  recommendations  to 
each national customs administration regarding which types of equipment and risks they should 
prioritise under the second call. Draft recommendations were first sent in November 2023, and 
subsequently discussed in bilateral meetings, before a final version was sent to Member States as 
a  complement  to  the  call  documentation  in  December  2023.  Under  this  call,  the  Relevance 
criterion made explicit reference to the individual recommendations, and applicants were asked 
to justify the needs based on these. In addition, the minimum passing score for Relevance was 
increased  by  one  point  (from  5  to  6  out  of  10)  to  try  to  emphasise  the  importance  of  this 
criterion.  All  applicants  addressed  the  individual  recommendations,  some  in  a  major,  others  in 
more  minor  ways.  During  interviews,  several  national  customs  administrations  referred  to  and 
welcomed the recommendations, describing them as helpful and relevant. 

As  such,  the  recommendations  provided  an  important  use  case  for  the  data  collected  from 
Member  States,  and,  along  with  the  more  specific  priorities,  are  likely  to  have  had  at  least  a 
modest  effect  in  terms  of  making  applications  under  the  second  call  more  responsive  to  key 
needs at the level of the Customs Union as a whole. Nonetheless, competition for funding was 
again limited, meaning the lion’s share of applications could be funded, and only a limited level 
of  selection  and  prioritisation  was  needed.  As  noted  previously,  no  applications  were  rejected 
entirely, although some had their scope reduced with the exclusion of certain work packages. 

Overall, this has meant that the extent to which the allocation of the funds has been effectively 
informed  by  a  rigorous  assessment  of  needs  has  been  limited  under  the  first  and,  to  a  slightly 
lesser degree, second call. There is no doubt that the equipment that has been supported by the 
CCEI to date is both eligible for co-financing under the applicable rules, and relevant to address 
the  overarching  objectives.  However,  it  responds  more  to  needs  as  identified  by  individual 
Member  States.  Therefore,  the  CCEI  as  implemented  to  date  may  not  always  ensure  that  the 
most  significant  gaps  and  needs  at  EU  level  are  addressed  as  effectively  and  efficiently  as 
possible. 

Implementation mostly efficient, but issues with the data model 

Overall,  feedback  from  the  national  customs  administrations  (i.e.  CCEI  beneficiaries)  suggests 
that  the  support  provided  by  the  Commission  to  Member  States  in  the  implementation  of  the 
CCEI  has  been  highly  appreciated.  Their  satisfaction  with  the  guidance,  programme 
management, and timeliness  of support provided by the CCEI is  gauged  annually via a survey 
launched by DG TAXUD in the context of the MEF, which shows that satisfaction levels have 
been consistently high – with nearly 100% of respondents either satisfied or fully satisfied with 
all  aspects  (namely,  the  quality  of  (1)  the  guidance  provided  at  the  application  stage,  (2)  the 
information contained in the call documentation, and (3) the ongoing guidance provided during 
implementation). 

In a similar vein, over 90% of respondents to the questionnaire agreed (many of them “strongly”) 
that  the  guidance  provided  by  DG  TAXUD  to  participate  in  the  CCEI  was  sufficiently  clear. 
Feedback  gathered  during  interviews  confirms  that  the  guidance,  communication  and  ad-hoc 

29 

 
 
support  provided  by  the  Commission  were  particularly  well  appreciated.  Moreover,  several 
interviewed customs authorities stated that plenty of notice was given to customs authorities to 
ensure they were ready to respond to  CCEI calls in  time. A clear majority of respondents  also 
found the CCEI Coordination Group to be an effective forum for collaboration, and believed the 
process for defining priorities for the MAWPs took into account their needs. On the other hand, 
there were only tepid levels of appreciation for the Annual Progress Reports and the indicators 
defined in the MEF. 

Figure  7:  Please  consider  your  level  of  agreement  with  the  following  statements  of  the 
management structure and processes of the CCEI  

Source: Questionnaire responses from national customs administrations 

Feedback was also generally positive on the grant application and award processes. Applicants 
and  beneficiaries  had  no  significant  complaints  about  these  procedures,  except  as  regards  the 
burden  linked  to  the  preparation  of  CCEI  applications,  which  was  perceived  as  very  heavy  by 
several interviewees. 

This criticism was linked primarily to the data model, and more specifically, to the quantitative 
data applicants had to provide (via the “detailed budget sheets” that accompany the application 
form).  This  data  includes  a  comprehensive  inventory  of  the  Member  State’s  customs  control 
equipment (broken down by BCPs and Labs), as well as traffic statistics per BCP and Labs, and 
a series of performance indicators meant to help identify and rank risks. In accordance with the 
data-driven  approach  enshrined  in  the  CCEI  Regulation,  the  purpose  of  this  data  is  to  identify 
gaps and needs, so that CCEI funding can be targeted at these, as well as facilitate monitoring 
and  evaluation  of  the  Instrument  (via  the  MEF  indicators).  To  enable  this,  national  customs 
administrations are expected to submit data at the grant application stage, as well as, in updated 
form, via their annual progress and final reports on each grant. 

30 

 
 
 
However,  the  questionnaire  responses,  interviews  and  case  studies  showed  that  most  national 
customs administrations found it difficult and burdensome to provide this data with the requested 
levels  of  detail  and  granularity.  Interview  feedback  suggests  that  the  data  collection  and 
reporting  process  often  required  significant  manual  effort,  as  the  data  typically  had  to  be 
compiled  from  various  sources,  and  the  categories  were  not  always  aligned  with  national 
procedures and frameworks, and in some cases, not available at all. Certain metrics (in particular 
those  related  to  the  identification  and  ranking  of  risks)  were  also  deemed  to  be  insufficiently 
clearly defined and thus open to interpretation. 

Moreover, several Member States expressed doubts about the actual relevance and usefulness of 
the data. While they typically understood the need for CCEI support to be informed and driven 
by a good understanding of the actual needs  and risks, and were supportive  in  principle of the 
Commission’s  endeavour  to  collect  data  to  facilitate  this,  many  expressed  doubts  about  the 
extent  to  which  the  data  sheets  in  their  current  form  were  conducive  to  achieving  this.  The 
majority (52%) of questionnaire respondents  tended to agree that the information DG TAXUD 
collects as part of the CCEI grant application process (via the various detailed budget sheets) was 
relevant  for  identifying  the  needs  of  their  customs  administration,  but  only  a  small  proportion 
(19%) agreed strongly, while a similar proportion disagreed (19%) or responded neutrally (10%).  

As a result of the above-mentioned issues, the data collected by DG TAXUD was not complete, 
and  there  were  issues  with  its  quality,  reliability  and  comparability  across  Member  States  and 
categories. This was the fundamental hurdle by far to successfully implementing and leveraging 
the data model as envisaged. The fact that the data on which needs assessments are to be based is 
to some extent fraught is one of the main reasons why it is difficult to ascertain to what extent 
CCEI funding to date has been effectively and efficiently focused on the most significant needs 
and risks. 

To assess the costs of the CCEI, the evaluation sought to explore not only the direct costs for the 
EU  budget  –  approx.  EUR 550  million  in  grant  funding  approved  to  date  –  but  also  the 
administrative  burden  incurred  by  the  Member  States.  To  estimate  this,  as  part  of  the 
questionnaire,  national  customs  administrations  were  asked  to  provide  information  about  the 
amount of staff time they dedicated to participation in the CCEI. Although not all Member States 
were  able  to  provide  such  data,  and  the  responses  of  those  that  did  varied  significantly,  they 
nonetheless allow for at least an indicative estimation of the burden the various procedures and 
tasks impose on participating entities. National customs administrations reported they expended 
slightly  less  than  120  days  of  their  staff’s  time  to  take  part  in  the  CCEI  and  manage  their 
country’s projects (per year so far on average). By applying a set of assumptions in accordance 
with the EU’s Standard Cost Model, this can be translated into an annual administrative burden 
of  approximately  EUR  22,500  per  Member  State  (including  overheads),  or  a  little  over  EUR 
600,000 for  all national  customs administrations taken together. This  is  equivalent  to  less than 
0.5% of the annual CCEI budget. 

Among the different CCEI-related tasks that national customs administrations have to carry out, 
the  one  they  indicated  as  using  up  the  most  resources  was  managing  an  active  CCEI  grant, 
followed, in second place, by compiling a CCEI grant application (incl. the data required for the 
data model). As part of the questionnaire, respondents were also asked to indicate whether or not 
they considered the total CCEI-related workload, and that stemming from each of the tasks, to be 
acceptable. The majority responded that this was the case for nearly all tasks, with only a small 
minority  (10%)  describing  the  amount  of  time  needed  as  not  acceptable.  However,  23%  of 

31 

 
 
respondents reported not finding the amount of time at application stage to be acceptable. This 
further  confirms  the  feedback  from  customs  administrations  that  the  data  requirements  were 
excessive and burdensome.  

In view of this – i.e. it is difficult and burdensome for Member States to provide the data, and 
even so, what they are able to provide is not sufficiently reliable, consistent and comprehensive 
for  DG  TAXUD  to  use  as  intended  –  there  is  likely  to  be  significant  simplification  potential 
regarding the data model.  This  is  not to  say that data should no longer be collected. However, 
there may well be potential to streamline the framework and focus it on the elements for which, 
with a little extra effort, reliable and comparable data can be collected, and subsequently used to 
identify real needs and monitor progress. As part of this, it should be considered whether some 
indicators that are currently collected via the data sheets 4 and 5 could be removed or reduced in 
terms of their scope or granularity. For the indicators that remain, it should be revisited whether 
they  are  defined  in  a  clear  and  unambiguous  way,  and  where  needed,  additional  clarifications, 
simplification and guidance provided to ensure their consistent interpretation and application. 

Coherence high, both internally and externally, but potential for synergies not fully exploited 

The CCEI’s design is internally coherent, in the sense that its various elements (of which there 
are  few  –  essentially,  a  single  kind  of  main  activity,  namely  the  provision  of  support  for  the 
purchase,  maintenance  and  upgrade  of  customs  control  equipment  via  grants  to  projects 
implemented  by  the  national  customs  administrations  of  EU  Member  States,  and  a  series  of 
supporting  activities  implemented  by  DG  TAXUD  to  steer,  coordinate  and  manage  the 
instrument,  and 
to  applicants  and 
beneficiaries)  all  operate  well  together  to  achieve  its  objectives.  Where  aspects  of  the  CCEI’s 
design (e.g. the shares of the call budgets earmarked for BCPs and Labs, respectively) turned out 
to  be  not  fully  aligned  with  actual  needs,  the  CCEI  Regulation  provided  sufficient  room  for 
manoeuvre for the Commission to respond flexibly. 

technical  and  administrative  assistance 

to  provide 

Nonetheless, to date CCEI-supported national projects have operated almost entirely in isolation 
from each other, and there may be scope to try to foster synergies between them, by exploring 
ways  in  which  aspects  like  standardisation,  data  sharing,  or  learning  from  each  other’s 
experiences  could  be  built  into  projects  and/or  addressed  via  supporting  activities.  During 
interviews,  several  representatives  of  national  customs  administrations  expressed  a  desire  for 
more  informal  knowledge-sharing  platforms,  such  as  workshops  and  peer-to-peer  sessions,  to 
facilitate best practice exchanges and enhance collaboration among Member States, with a view 
to improving customs practices and fostering innovation. Some also lamented that, to date, the 
CCEI has not made any attempts to facilitate joint procurement, noting that this holds significant 
potential  to  generate  economic  benefits,  although  key  barriers  (in  particular  differing  national 
legislation) are likely to continue to be difficult to overcome. 

Externally,  the  CCEI  is  designed  in  a  way  that  seeks  to  maximise  its  coherence  with  other 
relevant  EU  programmes  and  funds.  In  this  context,  collaboration  with  the  Customs 
programme14, the Border Management and Visa Instrument15 and close links, including through a 

14 The  Customs Programme supports actions (among others) that can complement the CCEI, such as exchange  of 

good practices, lessons learnt or training relating to the equipment concerned. 

32 

 
 
 
structured coordination mechanism, with the Union Anti-Fraud Programme, the Horizon Europe 
Programme, and the Technical Support Instrument (TSI) can be mentioned. The MAWP 2023-
2024 states specifically that the CCEI seeks to create synergies with all of these, as well as with 
the  Internal  Security  Fund  (ISF)  and  the  Recovery  and  Resilience  Facility  (RRF),  and  that 
complementarities with these programmes are encouraged.  

Specifically, the CCEI and the EU Anti-Fraud Programme overseen by OLAF demonstrate clear 
complementarity,  effectively  addressing  distinct  yet  interconnected  objectives.  Before  the 
establishment  of  the  CCEI  as  a  standalone  instrument,  OLAF's  programme  (Hercule)  was 
instrumental in supporting beneficiaries seeking funding for border equipment. Since the CCEI’s 
inception, the Anti-Fraud programme has reallocated its resources to support other beneficiaries 
(e.g. other law enforcement agencies) and different types of tools and technologies.   

Overall, while the CCEI’s external coherence with other relevant sources of EU funding is high 
in  theory,  the  extent  to  which  this  has  led  to  actual  synergies  and  complementarities  varies 
somewhat.  This  is  partly  due  to  the  different  levels  of  awareness.  Based  on  the  questionnaire 
responses  (see  below  figure),  almost  all  of  the  officials  dealing  with  the  CCEI  in  national 
customs  administrations  are  familiar  with  the  Customs  programme,  but  awareness  levels  are 
much lower for some of the other initiatives. Consistently with this, most examples of synergies 
highlighted  by  questionnaire  respondents  and  interviewees  related  to  aspects  of  the  Customs 
programme, such as trainings, meetings, and expertise sharing actions and fora like the Customs 
Laboratories Expert Team  (CLET), the Customs  Laboratories  European  Network (CLEN), and 
the  Customs  Eastern  and  South-Eastern  Land  Border  Expert  Team  (CELBET).  But  there  is 
limited evidence of meaningful synergies or concrete complementarities with the other initiatives 
listed,  which  may  be  partly  due  to  the  fact  that  a  number  of  respondents  pointed  out  that  they 
would not be aware of synergies or overlaps because these initiatives are generally handled by 
other officials within their national authorities.  

Only  a  handful  of  examples  of  a  complementary  use  of  the  CCEI  and  other  EU  instruments 
could be identified. A few Member States indicated having used the Anti-Fraud Programme and 
receiving funding for elements that are not covered by the CCEI but complement the equipment 
procured under the CCEI (e.g. videorecorder, IT-equipment, or vehicles). One Member State was 
reportedly considering using the RFF to help fund infrastructure necessary to install and operate 
equipment purchased through the CCEI. The overall efficacy of synergies with the BMVI is still 
developing.  Regarding  the  extent  to  which  customs  control  equipment  is  shared  with  other 
border  authorities,  the  responses  highlight  that  many  Member  States  have  not  yet  shared 
equipment  financed  under  the  CCEI  with  other  border  authorities.  This  is  often  due  to  the 
specific nature of the equipment, which is tailored for customs use and requires trained personnel 
for operation.  

15  The  Border  Management  and  Visa  Instrument  (BMVI)  with  the  CCEI  forms  part  of  the  IBMF,  but  focuses 
primarily  on  control  of  persons  crossing  the  EU  external  borders,  thus  complementing  the  CCEI’s  focus  on 
goods. 

33 

 
 
 
Figure 8: The CCEI aims to  complement  a number of  other sources of  EU funding, several  of 
which are listed below. Can you indicate whether you / colleagues working with the CCEI are 
aware of these initiatives? 

Source: Questionnaire responses from national customs administrations. 

4.2 How did the EU intervention make a difference and to whom? 

While  still  ultimately  concerned  with  the  success  of  the  CCEI,  this  question  looks  at  success 
through  the  lens  of  EU  added  value.  More  specifically,  it  seeks  to  understand  whether  the 
instrument  made  a  difference  for  the  intended  target  audience  of  national  customs  authorities, 
above and beyond what could have been expected with national interventions and funding alone. 
This is in line with the principle of subsidiarity, which dictates that EU action should be limited 
to areas where it is truly needed. It also follows the logic of deploying finite EU resources in the 
most efficient manner, since, other things being equal, these should be devoted to interventions 
where  other  actors  are  either  unable  to  step  in,  or  where  EU  involvement  catalyses  positive 
impacts that could not have been achieved otherwise. 

The answer to this question is based on assessment of the CCEI from several angles. First and 
perhaps most important  is the assessment of ‘additionality’ of CCEI funding, which means the 
extent to which it led to purchases of customs control equipment that was not only needed, but 
would not have been possible through other means. It then considers whether and how the CCEI 
generated  cost  savings  and/or  economies  of  scale,  e.g.,  by  pooling  expertise  or  increasing 
standardisation  in  a  way  that  reduced  costs  charged  by  suppliers.  Another  angle  –  absolutely 
fundamental given the EU’s common external border and absence of internal borders – relates to 
the CCEI’s ability to contribute to the mission of EU customs to act as one. Further to this, it is 
also important to consider whether and how the CCEI has enabled the Member States to address 
mutual challenges. Finally, the assessment looks at how the CCEI could be further harnessed to 

34 

 
 
 
support  the  proposed  EU  Customs  Reform16,  which  foresees  a  step  change  in  terms  of 
harmonising, coordinating and – to a certain extent – centralising customs practices.  

CCEI funding mostly additional, but in some cases it merely replaced national funding 

For  the  over  EUR  550  million  of  CCEI  funding  used  and  committed  so  far  to  be  truly 
‘additional’, it needs to  be directed towards purchases that would not  have been possible  from 
national  budgets  or  other  sources.  In  the  first  instance,  a  key  underlying  condition  for 
additionality  seems  to  have  been  present.  Stakeholders  engaged  for  the  evaluation  frequently 
raised  the  issue  of  imbalances  between  Member  States  in  the  financial  resources  available  for 
customs  control  equipment.  For  example,  nearly  80%  of  customs  authorities  responding  to  the 
questionnaire cited this as a ‘very’ (48%) or ‘quite’ important issue. This concern was echoed in 
the  open  replies,  with  several  Member  States  identifying  financial  imbalances  as  a  critical 
problem,  since  ‘the  Customs  Union  is  only  as  strong  as  its  weakest  link’.  Many  interviewees 
from  customs  authorities,  European  institutions  and  international  organisations  expressed  a 
similar  view.  The  implication  is  that  many  customs  authorities  would  not  have  been  able  to 
mobilise the resources needed for adequate customs control equipment without outside funding.  

However, it does not follow automatically that only Member States in need of the funding would 
take part in the instrument. The levels of additionality would be expected to differ depending on 
the  circumstances  and  needs  of  individual  customs  authorities.  The  data  collected  in  this 
evaluation  indicates  that  the  Member  States  fall  broadly  into  two  groups.  The  first  group  is 
comprised  of  countries  for  which  CCEI  funding  clearly  enabled  purchases  of  customs  control 
equipment  that  would  not  have  been  possible  from  other  sources.  The  questionnaire  results 
suggest  that  most  Member  States  fit  this  description.  Almost  two  thirds  (61%)  of  respondents 
reported that, without the CCEI, their customs authorities would not have been able to purchase 
equipment requested in their grant applications. Only 9% were of the opposing view, while the 
remaining 30% were either neutral or didn’t respond.  

Of  the  in-depth  case  studies  conducted  on  ten  grants  for  the  first  CCEI  call,  levels  of 
additionality  were  found  to  be  high  for  six  of  these.  In  these  cases,  a  unifying  theme  was  of 
significant equipment needs combined with lacking resources at national level. All but one of the 
case study grants in this category possess important land borders with third countries, while the 
other is the site of one of the EU’s largest container ports. Four of the grants were also among 
the  largest  from  the  first  call  in  terms  of  monetary  value.  Customs  authorities  in  all  six  of  the 
countries  emphasised  urgent  needs,  e.g.,  due  to  continued  reliance  on  equipment  that  was 
obsolete and/or had exceeded its expected lifecycle. It is also telling that these six grants were all 
subject to delays. While negative from an implementation perspective, this seems correlated with 
high levels of additionality, because Member States that dared to go outside their comfort zones 
with ambitious funding requests frequently experienced difficulties to put these plans into action. 
Still,  despite  timescales  that  were  longer  than  expected,  the  case  studies  provide  compelling 
evidence that these grants will ultimately lead to the purchase and deployment of equipment that 
would not have materialised otherwise. 

16 Communication from the Commission to the European Parliament, the Council and the European Economic and 
Social  Committee,  Customs  reform:  Taking  the  Customs  Union  to  the  next  level,  COM(2023)  257  final, 
Brussels, 17.5.2023; see also the Commission’s dedicated website, which provides an overview of the planned 
reform as well as its impact assessment and other documentation.  

35 

 
 
 
In  contrast,  the  other  four  of  the  case  studies  covered  equipment  needs  that  national  officials 
admitted would have been met regardless of the CCEI. The specific circumstances differed to a 
degree;  for  example,  in  some  cases  the  CCEI  funding  was  simply  used  to  help  implement 
equipment modernisation plans that had already been approved and launched. In other cases, the 
availability  of  EU  funding  allowed  customs  authorities  to  speed  up  /  bring  forward  equipment 
purchases  that  might  have  been  spread  out  over  a  few  years.  Given  the  importance  of 
maintaining a high level of control at all times, the role of the CCEI in allowing these Member 
States to deploy needed equipment more quickly is also a form of additionality that should not be 
underestimated.  In this respect,  it is  worth  pointing out  that only  one of the four grants  in  this 
group was delayed.  

Of course, the picture is not fully black and white. For example, customs authorities from several 
Member  States  explained  that,  even  if  they  would  have  been  able  to  purchase  the  requested 
equipment without EU co-funding, the CCEI served to elevate customs control equipment on the 
political  agenda,  incentivising  customs  to  strive  for  more  ambition  and  ‘protecting’  against 
budget cuts. 

Some costs savings generated, but major economies of scale still largely unrealised  

In  principle,  the  CCEI  could  also  make  a  difference  by  saving  money  for  the  Member  States. 
Several  pathways  to  these  savings  could  be  foreseen.  At  a  basic  level,  the  CCEI  Coordination 
Group  aims  to  serve  as  a  forum  for  pooling  knowledge  on  customs  control  equipment  and  on 
procurement,  which  could  help  the  Member  States  to  develop  tender  specifications  and  run 
procurement processes more efficiently. Increased standardisation, if achieved, could also reduce 
the costs charged by suppliers, while joint procurement would aim, inter alia, to give purchasers 
more bargaining power and drive down costs.  

In practice, the first of these pathways seems to have materialised to some extent. Asked in the 
questionnaire  about  whether  the  CCEI  Coordination  Group  is  an  effective  forum  for 
collaboration, the vast majority either ‘strongly agreed’ (29%) or ‘tended to agree’ (55%). In the 
interviews, several customs authorities further explained that the expertise, advice and templates 
/ sample material shared in the Coordination Group served to reduce costs at national level for 
the  drafting  of  tender  specifications,  management  of  procurement  processes,  and  dealing  with 
suppliers.  This  was  especially  appreciated  by  smaller  Member  States,  which  lack  in-house 
capacity.  Aside  from  saving  staff  time,  this  also  reduced  the  chances  of  unsuccessful 
procurements  and  litigation.  In  addition,  the  more  targeted  approach  of  the  second  call  for 
proposals, which included specific recommendations to Member States and increased guidance 
in  areas  like  security  specifications,  was  seen  as  a  further  step  forward.  However,  customs 
authorities  would  have  hoped  for  even  more  opportunities  through  the  CCEI  for  informal 
exchange  and  knowledge-sharing,  which  they  did  not  feel  had  been  fully  exploited  to  date. 
Moreover, the scale of these types of savings has been limited because they have not affected in 
any  fundamental  ways  the  processes  for  procuring  and  deploying  customs  control  equipment, 
where most costs are incurred.  

Turning to the savings that could potentially result from either standardisation of equipment or 
joint  procurement,  these  remain  largely  unrealised.  Regarding  standardisation,  although  a 
majority of questionnaire respondents (55%) agree that this is occurring to some extent through 
the CCEI, this was not considered an area of major progress, and no interviewees felt that it was 
helping  to  obtain  lower  prices.  For  its  part,  joint  procurement  is  permitted  in  the  CCEI 

36 

 
 
Regulation  and  many  officials  responding  to  the  questionnaire  and  taking  part  in  interviews 
mooted its future promise, especially for less tailored types of equipment like handheld scanners. 
The potential benefits from central purchasing by the Commission, if facilitated by the proposed 
EU  Customs  Reform,  also  attract  considerable  enthusiasm.  However,  these  benefits  remain 
theoretical  in  the  absence  of  any  concrete  attempts  to  actively  promote  or  enable  joint 
procurement at this stage.  

Incremental steps achieved towards the EU Customs mission of acting as one 

In light of the EU’s common external border, a key part of the mission of EU customs is for the 
27  customs  authorities  to  increasingly  act  as  if  they  were  one.  The  CCEI  specific  objective 
envisages  progress  towards  this  mission  through  enabling  purchases  of  customs  control 
equipment,  which  in  turn  aim  to  reduce  disparities  between  Member  States  and  contribute  to 
achieving a uniform level of control.  

The CCEI has  been progressing towards its objectives  relatively  effectively,  albeit  slowly,  due 
mainly to problems and delays experienced with national procurement processes. Still, this was 
attributed  to  external  factors  rather  than  design  flaws  in  the  CCEI.  Encouraging  early  results 
were  noted,  alongside  beneficiaries’  confidence  that  the  CCEI  will  make  a  significant 
contribution  over time to  its  objective of achieving adequate  and equivalent  results of customs 
controls.  This  is  a  positive  finding,  though  most  practical,  operational  impacts  are  still  yet  to 
emerge.  

In theory, the CCEI  could  also  foster other opportunities for customs  authorities to  act  as one, 
such as through increasing cooperation between customs authorities, standardisation of customs 
control equipment, and sharing of data and actual equipment. Some effect can be observed on the 
first  of these. As mentioned above  the CCEI Coordination Group has become a key  forum  for 
exchange  on  matters  concerning  customs  control  equipment  (with  other  groupings  such  as 
CELBET17 and CLEN18 also playing important roles in this respect), even if some participants 
saw room to take further advantage of this (e.g., by organising more workshops and peer-to-peer 
sessions).  However,  when  it  comes  to  operational  collaboration  stemming  from  the  CCEI, 
examples of impact are extremely limited. Just 26% of questionnaire respondents agreed that the 
CCEI had led to  more data-sharing, of  which only  10% ‘strongly’. Despite the role of EU  co-
funding and a general enthusiasm to work more together, the bottom line is that decisions on the 
equipment  to  be purchased and its use are made  primarily within national  silos. This  is in  line 
with the implementation modality of the CCEI, which relies on the Member States to procure the 
equipment,  and  with  policy  on  customs  controls  more  broadly,  whereby  individual  customs 
authorities are in charge of risk analysis and controls.  

In  this  regard,  interviewed  officials  expressed  little  awareness  for  how  data  or  the  equipment 
itself (where physically feasible, such as for mobile equipment between neighbouring countries) 
could  be  shared  or  the  legal  and  practical  protocols  for  doing  so.  Cybersecurity  concerns  and 

17  The  Customs  Eastern  and  Southern  Land  Border  Expert  Team  working  under  the  Customs  programme  and 
bringing  together  experts  from  11  Member  States,  see  dedicated  website:  CELBET  -  Customs  Eastern  and 
South-Eastern Land Border Expert Team.  

18 The Customs Laboratories European Network, which was established in 1999 and aims to rationalise, coordinate 

and optimise the use of human and technical resources among customs laboratories in the EU.   

37 

 
 
 
closed  IT  environments  were  also  mentioned  as  obstacles,  as  was  (by  fewer  customs 
administrations) the ineligibility for CCEI funding of IT infrastructure, which in principle could 
be  used  to  build  and  maintain  connections  for  sharing  and  jointly  interpreting  data  between 
countries.  Stakeholders  were of the view that achieving more structural  impacts  would depend 
on  the  increased  harmonisation  and  centralisation  of  EU  customs  practice  foreseen  in  the 
proposed EU Customs Reform.  

Progress towards addressing mutual challenges hampered by lack of targeting and procurement 
difficulties 

The CCEI has been making progress towards its specific objective, the pace of which is expected 
to  increase  over  time  as  more  and  more  equipment  is  purchased  and  deployed.  Since  the 
challenges  faced  by  individual  Member  States  are  by  definition  also  challenges  facing  the 
Customs  Union,  the  CCEI  can  be  said  to  be  making  a  difference  in  this  regard.  However,  it 
should  also  be  emphasised  that  the  CCEI’s  relatively  bottom-up,  open  approach  has  given  the 
Member States significant discretion to decide on which equipment priorities to pursue. This was 
particularly true of the first call for proposals, which focused on countries’ short-term priorities. 
The second call targeted specific policy priorities, while the Member States also had to take into 
account  individual  recommendations  from  DG  TAXUD  in  their  grant  applications.  Still,  both 
calls were open to all Member States (vast majorities of which chose to participate in each case) 
rather  than,  say,  priority  countries  or  BCPs.  Moreover,  even  for  the  second  call,  the  priorities 
were sufficiently broad such that most – if not all – types of eligible equipment could reasonably 
be  justified.  In  contrast,  the  CCEI  expressly  did  not  dictate  in  a  top-down  manner  which 
equipment should be purchased and where it should be deployed.  

It  is  difficult to  determine the appropriate  amount of steering and prescriptiveness.  On the one 
hand,  a  more  centralised,  top-down  approach  –  with  decisions  about  the  equipment  to  be 
purchased and locations for deployment taken at EU-level – could in principle result in a more 
efficient allocation of resources and better address the challenges facing  the Union as a whole. 
On the other hand, the national  competence for  customs controls  limits the amount of steering 
that  would  be  politically  and  legally  feasible,  and  providing  all  Member  States  with  the 
opportunity to take part helps ensure wide support for the instrument. The decision to purchase 
equipment  is  a  complex  one  where  many  factors  need  to  be  taken  into  account  –  including 
existing  infrastructure,  available  space,  geographical  location,  adequate  levels  of  staff  with 
narrow  expertise,  budgetary  restrictions,  traffic  patterns,  etc.  All  these  factors  cannot  easily  be 
factored into a data model; some can arguably only be adequately assessed from a Member State 
perspective (or by on-site inspections from the Commission, which would allow it to assess the 
BCP/customs laboratory in its entirety). And since the CCEI database still lacks comprehensive 
and  accurate  data  on  existing  equipment  deployments  and  needs,  it  would  also  be  difficult  to 
centralise decision-making beyond a certain degree. A balance probably needs to be struck, and 
the second call looks like a step in the right direction, even if somewhat more direction from the 
Commission (e.g., by focusing calls on a narrower set of obligatory priorities) would probably be 
desirable.  

Significant potential for the CCEI when the proposed EU Customs Reform is implemented  

Finally, in assessing whether and how the CCEI has made a difference, it is worth considering 
the programme’s potential in light of a policy and institutional framework that is not static, but 
rather  is  likely  to  evolve  significantly  in  the  coming  years.  Specifically,  this  is  likely  to  be 

38 

 
 
profoundly transformed by the proposed EU Customs Reform19, an ambitious initiative that aims 
to  further harmonise customs practice in  the EU  and make it more risk-based  and data-driven. 
While key provisions of the reform are not scheduled to apply until 2028, it is useful to reflect on 
ways  in  which  the  CCEI  could  potentially  add  more  value  once  the  envisaged  changes  are  in 
place,  in  particular  with  regard  to  certain  shortcomings  and  areas  of  limited  progress.  These 
include a lack of targeting, insufficient procurement guidance and limited use of the instrument 
to foster standardisation, innovation, data sharing and operational collaboration, as well as slow 
progress  towards  joint  procurement,  which  has  not  yet  been  attempted  or  piloted  with  the 
programme. 

Of  the  wide  range  of  legal  and  procedural  novelties  envisaged  in  the  EU  Customs  Reform, 
feedback  from  stakeholders  suggests  that  three  of  these  in  particular  have  strong  links  to  the 
CCEI’s existing problems. These are briefly described below, in terms of the role of the current 
framework  in  causing  and  contributing  to  the  problems,  and  the  potential  that  the  proposed 
reform creates for addressing these: 

•  Harmonisation of customs risk management: under the current Union Customs Code, risk 
management  and  controls  are  largely  the  responsibility  of  national  customs  authorities, 
especially for non-financial risks, based on the national risk frameworks and risk engines 
used to target controls. The Customs Reform will change this by introducing provisions 
by which all Member States will have access  to  real-time data and will be able to  pool 
information to respond more quickly, consistently and effectively to risks and introducing 
a  new  strengthened  risk  management  framework,  which  will  be  based  on  a  common 
prioritisation  of  risks  for  the  whole  EU,  a  mechanism  for  increased  operational 
cooperation.  

o  In  practice,  more  consistency  will  be  needed  in  the  arena  of  customs  control 
equipment,  regarding  increased  standardisation,  the  sharing  and/or  pooling  of 
data,  and 
interoperability  and  coordination  between  customs  authorities 
conducting  controls.  To  facilitate  this,  the  CCEI  could  require  authorities 
applying  for  grants  to  purchase  interoperable  equipment  based  on  common 
standards, and to put in place protocols for sharing the images and other relevant 
data produced using the equipment, and for interpreting those images (potentially 
assisted  by  AI).  Such  requirements  could  also  act  as  an  additional  incentive  for 
Member States to take steps towards joint requirements.  

•  Establishment  of  an  EU  Customs  Data  Hub:  the  impact  assessment  for  the  Customs 
Reform  determined  that  traders  currently  need  to  submit  customs  data  to  up  to  111 
different  IT  systems  and  to  deal  with  the  authorities  in  all  Member  States  where  they 
have operations. While interoperability between certain systems allows some of the data 
involved to be shared, this is seldom the case for the risk data used to target controls and 
images and other information produced using customs control equipment. Cybersecurity 

19 Communication from the Commission to the European Parliament, the Council and the European Economic and 
Social  Committee,  Customs  reform:  Taking  the  Customs  Union  to  the  next  level,  COM(2023)  257  final, 
Brussels, 17.5.2023; see also the Commission’s dedicated website, which provides an overview of the planned 
reform  as  well  as  its  impact  assessment  and  other  documentation:  EU  Customs  Reform  -  European 
Commission.  

39 

 
 
 
concerns and national rules and processes pose additional barriers. The introduction of an 
EU  Customs  Data  hub  will  act  as  an  enabler  for  the  harmonised  risk  management 
described above, as well as making it easier for customs authorities to share information 
securely and thereby coordinate and mutually benefit from each other’s controls.  

o  The  Data  Hub  should  increase  the  potential  added  value  of  more  uniform 
approaches to customs control equipment, which would in turn also make it more 
worthwhile  for  the  CCEI  to  prioritise  the  purchase  of  standardised  and 
interoperable  equipment.  Increased  possibilities  for  the  pooling  and  sharing  by 
means  of  the  data  hub  and  coordinated  use  of  data  could  also  spur  innovation 
through the future CCEI type interventions.  

•  Establishment  of an EU  Customs Authority:  despite the nature of customs policy as  an 
exclusive  EU  competence,  and  the  increased  harmonisation  of  rules  and  processes,  for 
the  most  part  national  customs  authorities  have 
for 
implementation.  The  EU  Customs  Authority  will  change  this  by,  for  the  first  time, 
assigning certain customs operational tasks to a central body. Concretely, these tasks will 
include using the data from the EU Customs Data Hub to conduct EU-level risk analysis 
and make control recommendations to national authorities, and coordinating operations in 
the  event  of  a  crisis.  Potentially,  it  will  also  take  responsibility  for  developing  and 
maintaining the EU Customs Data Hub and executing customs related programmes.  

responsibility 

retained 

o  The EU Customs Authority is likely to open the door to a myriad of possibilities 
for the CCEI. As a centre of expertise on a number of relevant matters  (such as 
technological  developments  and  capabilities,  cybersecurity  and  procurement 
practices),  the  authority  can  ensure  the  use  of  such  knowledge  to  inform  CCEI 
planning,  and  development  of  requirements,  guidance,  templates  etc.  Inter  alia, 
this  could  include  taking  action  to  introduce  standardised  testing  protocols, 
enabling more effective comparisons of equipment.20 Operational staff would be 
able to play a coordinating role vis-à-vis national customs authorities, increasing 
the  chance  that  opportunities  for  sharing  data  and  collaboration  are  grasped.  It 
would also be the central location for enabling the use of shared images, and for 
producing a reference library for both training and interpretation purposes, which 
would in turn help refine algorithms for risk analysis purposes. And finally, were 
the  decision  taken  to  further  streamline  the  procurement  of  customs  control 
equipment for the proposed targeted CCEI type interventions, joint  procurement 
or even carrying out purchases centrally, with the EU Customs Authority in lead 
for these initiatives, could be the way forward.  

4.3 Is the intervention still relevant? 

This section assesses the relevance of the CCEI by examining its alignment with evolving EU 
needs and priorities, its ability to adapt to geopolitical and technological changes, and the extent 

20 This would be in line with the first recommendation of a recent study carried out for DG TAXUD on customs 
detection technologies: European Commission (2024), Customs control detection technologies: state-of-the-art, 
emerging  customs  control  equipment  and  its  testing,  study  prepared  for  the  European  Commission  by  NTT 
Data.  

40 

 
 
 
to which it meets the needs of stakeholders. The evaluation considers the objectives, scope, and 
design  of  the  instrument  in  relation  to  its  intended  role  in  strengthening  the  level  of  customs 
control across the EU. 

The  CCEI  was  established  to  address  critical  disparities  in  customs  control  capacities  across 
Member States by co-financing the procurement, maintenance, and upgrading of customs control 
equipment. Given the dynamic nature of customs challenges  – ranging from security threats to 
digitalisation and organised crime – the instrument’s continued relevance depends on its capacity 
to  remain  aligned  with  EU  policy  priorities,  support  Member  States  in  acquiring  necessary 
equipment, and foster a modern and harmonised approach to customs enforcement. 

CCEI well-aligned with EU customs priorities 

The EU Customs Strategy21 and Customs Action Plan22 provide the overarching framework for 
strengthening  the  Customs  Union,  setting  out  key  priorities  such  as  modernising  customs 
enforcement, enhancing risk management and data sharing, and improving cooperation between 
Member States. These strategic documents emphasise creating a more data-driven and resilient 
customs system,  reinforcing  risk-based control  mechanisms, and  equipping customs authorities 
with  the  necessary  infrastructure  and  technologies  to  improve  enforcement  capabilities.  They 
also  outline  concrete  initiatives  such  as  expanding  data  availability,  streamlining  e-commerce-
related customs procedures, and promoting compliance through simplified reporting tools. While 
the EU Customs Reform is not implemented, the Customs Strategy and the Action Plan remain 
two centrepieces to shaping EU customs policy.  

The CCEI aligns closely with these objectives by providing financial support for customs control 
equipment  across  all  27  Member  States,  and  thereby  aiming  to  ensure  a  more  harmonised 
enforcement  capacity  across  the  Customs  Union.  By  offering  broad  funding  eligibility  for 
essential  detection  and  inspection  technologies,  the  CCEI  is  designed  to  enable  customs 
authorities  to  modernise  and  reduce  disparities  at  external  borders.  The  instrument’s  financial 
scope allows for substantial investments in high-end equipment that might otherwise be beyond 
the reach of national budgets. By ensuring that all Member States can enhance their enforcement 
capabilities,  the  CCEI  seeks  to  contribute  to  the  strategic  goal  of  ensuring  the  Customs  Union 
acts  as  one  and  increasing  control  capabilities  at  external  borders,  which  are  objectives  also  at 
the heart of the Customs Strategy. 

The  CCEI  MAWPs  have  played  a  key  role  in  maintaining  the  programme’s  relevance  by 
adapting  its  scope  to  emerging  priorities.  The  first  MAWP  (2021-22)  focused  primarily  on 
improving  the  general  level  of  equipment  across  the  EU  and  limiting  the  risks  of  the  weakest 
links at the external border. It did so by prioritising equipment shortages and improving customs 
controls  at  the  Union  level,  with  a  focus  on  urgent  and  short-term  needs.  As  new  challenges 
emerged, the second MAWP (2023-24) sharpened the programme’s focus to include: 

•  Supporting sanctions enforcement following Russia’s invasion of Ukraine; 

21 Available at the Commission website: https://taxation-customs.ec.europa.eu/customs-4/eu-customs-strategy_en 

22 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, 
Brussels, 28.9.2020. 

41 

 
 
 
•  Enhancing  detection  capacities  to  counter  illicit  trade  and  organised  crime,  in  line  with 
the EU Roadmap to Fight Drug Trafficking and Organised Crime23 including a European 
Ports Alliance; 

•  Addressing challenges in e-commerce customs controls; 

•  Promoting 

innovation  and 

interoperability 

in  customs 

technology, 

taking 

into 

consideration the proposal for an EU Customs Reform. 

This  adaptability  has  helped ensure that the CCEI remains relevant  in  addressing both  existing 
and evolving customs challenges.  

Relevance to Member States remains high, with some reservations 

The CCEI enjoys strong support among customs authorities, with all 27 Member States having 
sought – and secured – funding in at least one of the two calls. The instrument is widely regarded 
as an essential tool for reducing disparities in customs enforcement capabilities, ensuring that all 
Member States, regardless of national budgetary constraints, can access state-of-the-art customs 
control equipment. 

The  overwhelming  majority  of  customs  administrations  agree  that  the  needs  the  CCEI  aims  to 
address  are  genuine  and  that  the  underlying  issues  have  been  identified  correctly.  The  results 
from the questionnaire analysis show a strong consensus among customs authorities on the need 
to reduce imbalances in customs control capabilities, with 48% considering it very important and 
35%  somewhat  important.  The  most  pressing  concerns  identified  were  financial  disparities 
(48%), administrative capacity (42%), and equipment availability (39%). Several Member States 
stressed that the Customs Union is only as strong as its weakest link, reinforcing the need for an 
EU  funding  instrument  and  EU-level  coordination  on  matters  of  customs  control  equipment. 
Many  respondents  saw  the  CCEI  as  essential  for  raising  levels  of  enforcement  to  a  high  and 
uniform  level,  a  view  echoed  in  interviews,  where  customs  authorities  highlighted  its  role  in 
strengthening security at key BCPs.  

23 Communication from the Commission to the European Parliament and the Council on the EU roadmap to fight 

drug trafficking and organised crime, COM(2023) 641 final, 18.10.2023. 

42 

 
 
 
Figure 9: How important are the following issues and challenges from the perspective of your 
customs administration? 

Source: Questionnaire responses from national customs administrations 

With  regard  to  the  objectives  defined  for  the  CCEI  under  the  first  two  MAWPs  (2021-22  and 
2023-24),  Member  States  were  in  strong  agreement  with  the  specific  priorities  outlined  in  the 
first  and  second  MAWPs.  The  questionnaire  responses  indicate  that  Member  States  strongly 
prioritise  certain  objectives  of  the  CCEI,  particularly  those  related  to  addressing  equipment 
shortages and enhancing customs controls across the Union. The first MAWP’s focus on filling 
critical  gaps in  customs control equipment  was  widely  seen  as aligned  with  national  priorities, 
while the second MAWP’s emphasis on strategic BCPs and mitigating international conflicts and 
crises also received broad support. At the same time, the responses also reveal a disparity in how 
different  objectives  are  valued.  While  enforcement-related  goals  are  widely  supported, 
innovation and sustainability rank lower on the list of priorities. Fewer Member States fully align 
with  objectives  aimed  at  promoting  greener  capabilities  and  fostering 
technological 
advancements.  Interviews  further  confirmed  this  divide.  While  some  customs  administrations 
acknowledged  the  potential  of  the  CCEI  to  drive  innovation,  most  saw  their  primary  focus  as 
maintaining and strengthening existing enforcement and risk management capabilities. 

43 

 
 
  
Figure 10: To what extent are the priorities for the first Multi-Annual Work Programme (2021-
22) still important for your country? 

Source: Questionnaire responses from national customs administrations. 

Figure  11:  To  what  extent  are  the  priorities  for  the  second  Multi-Annual  Work  Programme 
(2023-24) still important for your country? 

Source: Questionnaire responses from national customs administrations. 

While the CCEI design appears well-suited to provide essential equipment, some Member States 
see gaps in its design that limit its ability to fully meet their needs. A key concern is that certain 
complementary  costs,  such  as  infrastructure  and  IT  systems,  are  not  eligible  for  funding,  even 
though they are often necessary for maximising the effectiveness of customs control equipment. 

44 

 
 
 
 
Some  authorities  argue  that  it  reduces  the  programme’s  flexibility  to  address  real-world 
implementation challenges. However, the exclusion of infrastructure is also a justifiable design 
choice.  Expanding  eligibility  to  infrastructure  costs  would  not  only  further  dilute  the 
programme’s already broad scope but also complicate funding allocation by making it difficult to 
define clear boundaries on what constitutes eligible infrastructure. Ensuring a targeted focus on 
customs control equipment prevents the programme from becoming too open-ended and difficult 
to  steer  strategically.  Additionally,  some  specific  needs  are  not  fully  reflected  in  the  eligible 
equipment  list,  with  Member  States  pointing  to  missing  non-intrusive  detection  tools,  officer 
protection  gear,  and  environmental  monitoring  devices.  While  the  current  list  broadly  meets 
customs  needs,  some  authorities  have  called  for  a  more  flexible  and  dynamic  approach  to 
eligibility  to  ensure  the  programme  keeps  pace  with  evolving  enforcement  challenges  and 
technological advancements. This could help maintain the CCEI’s relevance over time, but the 
same considerations on not broadening the programme design too much apply here. 

Limited impact of the CCEI on innovation and standardisation so far 

One of the intended objectives of the CCEI is to support the modernisation of customs control 
equipment,  including  fostering  innovation  and  interoperability  across  Member  States,  as 
highlighted particularly by the second MAWP (2023-24). The programme is designed to provide 
some flexibility in how Member States address their specific needs, allowing them to apply for 
funding to procure a broad range of equipment, including state-of-the-art detection and scanning 
technologies.  The  eligible  equipment  list  includes  a  variety  of  advanced  tools,  and  the  CCEI’s 
scope  is  broad  enough  to  accommodate  forward-looking  investments  in  customs  technology. 
Interoperability  in  terms  of  equipment  requiring  dedicated  software  was  further  specified  as  a 
condition  in  the  second  call  for  proposals.  However,  while  the  design  of  the  programme 
promotes interoperable software solutions and permits investment in innovative solutions, it does 
not  strongly  steer  Member  States  towards  innovation  and  data  sharing.  Member  States  can 
decide if they dedicate a part of their funding request to innovative solutions. 

During  the  first  call,  the  programme  encouraged  investment  in  cutting-edge  technologies  (as 
visible  both  in  the  first  MAWP  and  call  for  application),  but  without  a  structured  incentive  or 
pressure  to  prioritise  them.  Even  though  the  bidding  is  designed  as  a  competitive  process,  the 
fact that the first call was not oversubscribed lead to a non-competitive setting, in which customs 
authorities  largely  received  what  they  applied  for  and  leverage  for  steering  was  limited.  As  a 
result,  the  applications  that  received  a  low  score  on  innovative  elements  in  their  projects  still 
received funding. 

Stronger  guidance  was  introduced  in  the  second  call  for  applications,  seeking  to  encourage 
greater focus on innovation and making interoperable software a condition for applications. This 
included higher scoring thresholds for innovation.  Nonetheless,  the changes to  the approach of 
the  second  call  reflect  a  broader  challenge  in  aligning  the  instrument’s  strategic  goals  with 
Member States’ procurement decisions, given that the CCEI does not impose strict requirements 
for investment in innovative solutions. 

While the CCEI was conceived to encourage Member States to acquire advanced equipment, it 
does  not  currently  include  mechanisms  specifically  aimed  at  supporting  the  pre-procurement 
testing or piloting of emerging technologies for example via dedicated funding. The testing and 
validation of existing R&I technologies not always available in the market is a key stage in the 
innovation  journey,  and  a  unique  opportunity  for  customs  practitioners  to  adapt  existing 

45 

 
 
solutions  to  their  specific  capability  needs  and  operational  environments.  Some  industry 
stakeholders and Member States have suggested that expanding eligibility to include AI-powered 
detection  systems,  or  drone  surveillance  could  increase  the  programme’s  relevance  in  driving 
technological  advancements.  On  the  other  hand,  although  pre-procurement  testing  was 
mentioned by some stakeholders as a missing possibility, it is in fact already eligible under the 
current  framework  and  the  second  call  for  applications  specifies  the  possibility  of  renting  or 
leasing innovative equipment.  

The  design  of  the  CCEI  places  a  focus  on  certain  elements  of  standardisation  and 
interoperability,  particularly  by  requiring  interoperable  software  for  equipment  requiring 
dedicated  software  and  specifying  technical  standards  for  certain  equipment  –  namely  high-
energy  x-ray  scanners  and  radiation  and  nuclear  equipment.24  The  programme  has,  however, 
proved  less  relevant  so  far  in  terms  of  promoting  standardised  testing  protocols25  and  data 
sharing among Member States. On these two aspects, some Member States showed some more 
reluctance than they did on innovation, as they did not necessarily agree that standardisation is a 
must and showed certain reservations on data sharing. They highlighted that efforts to improve 
data-sharing  have  been  slow  to  develop  partly  due  to  cybersecurity  concerns  and  geopolitical 
considerations, expressing concerns about sharing data across borders, particularly when certain 
types of customs equipment are sourced from non-EU manufacturers.  

The programme design, without instruments for joint procurement or for centralised decisions on 
the  most  urgent  needs,  makes  it  difficult  to  drive  a  more  coordinated  approach  to  customs 
technology. Without stronger mechanisms for aligning Member State procurement with EU-wide 
customs  strategies  related  to  innovation,  the  CCEI’s  role  in  fostering  a  harmonised  and 
modernised customs enforcement system remains constrained. 

24  The  first  CCEI  call  specifies  that  x-ray  scanners  must  be  compliant  with  the  WCO  standard  for  Unified  File 
format  2.0,  while  the  second  call  states  that  both  high-energy  x-ray  scanners  and  radiation  and  nuclear 
equipment  should  align  with the  guidance  developed  by  the  CCEI  coordination  group  (compliant  with  WCO 
standard for Unified File format 2.0).  

25  As  mentioned  above,  the  recent  study  on  customs  detection  technologies  recommended  such  protocols,  which 
have not yet been implemented: European Commission (2024), Customs control detection technologies: state-
of-the-art, emerging customs control equipment and its testing, study prepared for the European Commission by 
NTT Data.  

46 

 
 
 
 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

The  CCEI  is  a  funding  programme  designed  to  support  the  purchase,  maintenance,  and 
upgrading of customs control equipment in the EU. It has a budget of just above EUR 1 billion 
for the 2021-2027 period. Its ultimate aim is to help ensure the national customs administrations 
of the EU Member States are equipped to provide an adequate level of control, with equivalent 
results, at all of the EU’s external borders. This is important because the Customs Union is only 
as strong as its weakest link, and the harmonised and effective application of customs controls is 
essential  for  the  protection  of  the  financial  and  economic  interests  of  the  EU  and  its  Member 
States, for ensuring the safety and security of its residents, and for protecting it from illegal trade 
while facilitating legitimate business activity. 

The CCEI has  been implemented via two Multi-Annual  Work Programmes (the first  for 2021-
2022, the second for 2023-2024) and two corresponding  calls for proposals.  These have led to 
the signature of grant agreements via which the CCEI provides co-financing to projects launched 
by national customs administrations to purchase, maintain and/or upgrade the equipment of their 
BCPs and/or laboratories. Following the first call (which closed in January 2022), 42 projects by 
24 Member States were supported with a total of EUR 273 million of CCEI grant funding. Most 
of  these  projects  are  still  ongoing,  and  several  of  them  have  had  their  duration  extended.  The 
second call (which closed in February 2024) granted a total of EUR 284 million for 47 projects 
by 25 Member States. These projects are only just getting started, and the majority are expected 
to end in 2027 or 2028. 

As discussed in detail in the findings in the previous chapter, the CCEI is a valuable instrument 
with some notable emerging achievements in strengthening customs control capacities across the 
EU. However, there are areas that could be improved to maximise its effectiveness, efficiency, 
and impact on the harmonisation of customs practices. The rest of this chapter outlines both the 
main strengths and the problems identified / areas for improvement.  

It  is  important  to  note  that  the  evaluation  findings  are  mainly  informed  by  and  reflect  the 
experience of the first wave of projects, the majority of which started in 2022 and have yet to be 
completed.  It  is  important  to  acknowledge  that  the  first  MAWP  and  call  were  exceptional  in 
several ways, including their very broad priorities (aimed at filling existing gaps and addressing 
the  most  urgent  needs  of  Member  States)  and  the  retroactivity  clause  (which  allowed  Member 
States to apply for co-funding for projects they had already launched and costs they had already 
incurred).  Furthermore,  this  being  the  first-ever  call,  national  customs  administrations  did  not 
have  any  previous  experience  with  the  CCEI,  which  is  also  likely  to  have  contributed  to  the 
difficulties and delays encountered by many projects. There are signs that some of the resulting 
issues and challenges have been addressed to some extent in the second MAWP and call, but the 
early stage of implementation means that tangible evidence of any improvements has not yet had 
time to emerge. Therefore, the conclusions reflect the situation as of early 2025, and that some 
elements may well appear different once the second wave of projects begin to make significant 
progress. 

5.1 Conclusions – main achievements 

Considering the current  stage of progress  with  implementation,  the CCEI can be deemed quite 
successful  overall,  in  that  it  has  responded  to  real  policy  and  practical  needs,  and  begun  to 
provide support for equipment that is clearly relevant to strengthening controls at EU BCPs and 

47 

 
 
customs  laboratories.  It  has  done  so  in  a  way  that  is  broadly  effective  and  efficient.  More 
specifically: 

•  Relevance  and  value:  The  CCEI  directly  addresses  an  important  need  within  the  EU: 
tackling  the  disparities  in  customs  control  equipment  across  Member  States.  This 
disparity, often stemming from budgetary constraints and varying national priorities that 
would  otherwise  have  continued  to  persist,  weakens  the  overall  effectiveness  of  the 
Customs  Union.  The  CCEI's  value  is  underlined  by  the  positive  response  from  all  27 
Member  States,  each  having  applied  for  and  secured  funding  in  at  least  one  of  the  two 
calls  so  far.  This  widespread  participation  demonstrates  the  instrument's  importance  in 
bridging gaps and facilitating the modernisation of customs control equipment across the 
EU. 

•  Coherence with EU priorities: The CCEI operates in strong alignment with the broader 
strategic  objectives  enshrined  in  the  Union  Customs  Code26  and  further  outlined  in  the 
EU  Customs  Strategy  and  Customs  Action  Plan,27  in  particular  the  need  for  more 
modern,  data-driven,  interconnected  and  resilient  customs  systems,  with  enhanced  risk 
management,  data  sharing,  and  cooperation  among  Member  States.  The  CCEI  directly 
contributes to these goals by providing the financial means for Member States to acquire 
state-of-the-art  equipment,  thereby  bolstering  their  capabilities  and  supporting  a  more 
harmonised  approach  to  customs  control  across  the  EU.  The  instrument  has  also 
demonstrated  adaptability,  with  its  MAWPs  evolving  to  address  emerging  challenges 
such as security threats stemming from the war in Ukraine, drug trafficking and the rise 
of e-commerce. 

•  Effective  design,  management  and  support:  The  CCEI’s  main  design  features 
(including its budget, co-financing rate and eligibility criteria) are appropriate in view of 
its  objectives.  The  beneficiaries  regard  the  management  of  the  instrument  by  DG 
TAXUD  as  effective  and  efficient  and  reported  a  high  level  of  satisfaction  with  the 
guidance, communication, and administrative support provided.  

•  Positive  outputs  and  emerging  results:  Despite  some  hurdles  and  delays  (primarily 
related to national procurement processes, discussed further below) that have affected the 
implementation  of  many  projects,  the  CCEI  has  begun  to  deliver  outputs,  namely  over 
900 pieces of equipment that were acquired with CCEI support to date, and are already 
helping to enhance the capabilities of the recipient BCPs and laboratories. While robustly 
measuring the precise impact  of this  equipment  remains  challenging  at  this early stage, 
the available data points to some early, emerging ways in which the instrument is making 
a  positive  contribution  to  strengthening  the  effectiveness  and  efficiency  of  customs 
controls and addresses the most urgent needs in the EU Member States. Feedback from 
Member  States  further  shows  that  there  is  a  high  degree  of  confidence  that  the  CCEI-
supported equipment is being used in ways that do help to strengthen their capacity for, 
speed  and/or  accuracy  of  customs  controls,  and  that,  over  time,  the  CCEI  will  make  a 

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

Union Customs Code 

27 European Commission (2020): Taking the Customs Union to the Next Level: a Plan for Action. COM/2020/581 

final 

48 

 
 
 
significant contribution towards its core objectives. Considering the dynamics, by the end 
of  this  programming  period  including  by  the  end  of  the  concluded  grant  agreements 
under  the  2021-2027  CCEI  calls,  it  is  expected  that  the  most  urgent  needs  for  customs 
control  equipment  in  the  EU  Member  States  would  be  covered  (delays  in  the 
implementation should also be dully considered in this context). 

•  Additionality  of  funding:  The  CCEI’s  financial  support  has  proven  to  be  genuinely 
additional  in  many  (but  not  all)  cases.  For  numerous  Member  States,  particularly  those 
facing  budgetary  constraints  or  with  extensive  external  borders,  the  CCEI  funding  has 
been instrumental in enabling the purchase of customs control equipment that would have 
otherwise been unattainable. Thus, the financial support the CCEI provides contributes to 
a  more  level  playing  field  within  the  Customs  Union,  allowing  all  Member  States  to 
contribute effectively to the common goal of adequate customs controls with equivalent 
results, regardless of their individual financial capacities and constraints 

5.2 Lessons learned – areas for improvement 

The CCEI has already taken important steps to address genuine needs and make a difference for 
many stakeholders. However, it also had to grapple with a complex institutional context in terms 
of the split in competences between customs policies set at European level and implementation 
by  the  Member  States,  which  created  challenges  in  terms  of  both  design  /  structure  and 
implementation. As a new instrument, the CCEI also suffered from some teething problems. The 
following  paragraphs  elaborate  on  the  main  problems  and  areas  for  improvement  identified 
during the evaluation.  

•  Implementation  delays  due  to  national  procurement  challenges:  Nearly  half  of  the 
grants  from  the first  call have had or are having  their duration extended (with  up to  30 
months), which represents a significant delay considering the average initial duration of 
projects under the first call was already quite long (31 months), even without taking into 
account the time needed for the Commission to issue the work programme, run the call, 
evaluate the proposals, prepare and sign the grant agreements (which also took about 18 
months).  Most  of  the  delays  to  project  implementation  were  due  to  problems  with 
procurement  processes.  Member  States  cited  a  wide  range  of  issues,  from  a  lack  of 
expertise to uncertainty about how to exclude risky suppliers, to insufficient resources, all 
of  which  were  problems  in  their  own  right,  as  well  as  creating  knock-on  effects  like 
appeals  and  litigation.  This  is  a  critical  dependency  for  the  CCEI,  because  despite  the 
importance  of  procurement  for  the  success  of  the  instrument,  the  projects  are 
administered based on national legislation and processes over which the Commission has 
no direct control. Moreover, while action has been taken by DG TAXUD to identify and 
spread best practices, it remains a significant bottleneck.  

Overall,  there  is  a  remarkably  extended  period  between  Member  States’  proposal  for 
CCEI  funded  project  and  the  successful  implementation  of  the  equipment  on  the  field, 
exceeding  2 to 3 years in  general  for small projects,  to  up to  6 or 7 years for the most 
complex projects. A situation further aggravated by the above-mentioned delays, which 
justifies reviewing the implementation modalities of the instrument  to  ensure achieving 
its policy objectives. 

49 

 
 
•  Insufficient targeting and prioritisation: The data-driven approach is meant to ensure 
that  CCEI  support  is  focused  on  the  most  significant  risks  and  gaps  across  the  EU. 
However,  due  to  a  combination  of  several  factors  (very  broad  priorities,  lack  of  real 
competition,  issues  with  the  data),  the  first  wave  of  projects  responded  primarily  to 
national needs and priorities as identified by applicants (i.e. Member States) themselves, 
with little steer or corrective action to ensure they addressed the most pressing needs of 
the  Customs  Union  as  a  whole.  These  main  factors  (as  listed  above)  were  still  present 
under the second call, albeit to a lesser degree. Overall, this has meant that the extent to 
which the allocation of the funds has been effectively informed by a rigorous assessment 
of  needs  has  been  limited,  and  it  is  therefore  not  entirely  clear  whether  the  CCEI  as 
implemented to date has ensured that the most significant gaps and needs at EU level are 
addressed as effectively and efficiently as possible. 

•  Issues with the data model and reporting: National customs administrations, while in 
principle  understanding  and  supportive  of  the  need  for  standardised  data  to  inform  and 
guide  CCEI  implementation,  in  practice  found  it  difficult  to  comply  with  the  data 
requirements,  arguing  that  quantitative  data  for  certain  metrics  is  not  collected  in  their 
Member States, is very burdensome to compile from various sources and ‘translate’ into 
the  required  format  and  categories,  and/or  is  open  to  interpretation.  The  data  Member 
States have submitted to DG TAXUD (as part of applications and reports on projects) is 
not  always  comprehensive  or  fully  up  to  date,  and  there  are  significant  concerns 
regarding  its  reliability  and  comparability.  There  are  also  issues  with  the  way  certain 
results  indicators  and  corresponding  targets  have  been  defined  in  the  Monitoring  and 
Evaluation Framework. As a result, so far, the data that has been collected could only be 
used  for  its  intended  purposes  (namely,  to  facilitate  (i)  the  identification  of  gaps  and 
needs  so  that  CCEI  funding  can  be  targeted  at  these,  as  well  as  (ii)  monitoring  and 
evaluation of the CCEI and its impacts) to a much more limited extent than foreseen.  

•  Uneven additionality: While in many cases the CCEI undoubtedly funded the purchase 
of equipment  that would not  have been possible from  other sources, Member States, as 
public authorities, are not required to demonstrate financial capacity in their applications, 
and instances of CCEI funding being used for equipment that would have been procured 
anyway  with  national  resources  were  also  evident.  The  proportion  of  projects  with 
limited additionality was not possible to measure quantitively, but it is worth mentioning 
that  four  of  the  ten  projects  examined  as  in-depth  case  studies  fell  into  this  category, 
though  in  some  of  these  cases  the  CCEI  funding  still  added  value  by  speeding  up 
necessary purchases, and/or potentially increasing (or at least protecting against possible 
budget  cuts)  the  available  resources  for  customs  control  equipment  in  the  medium  and 
longer term.  

•  Limited impact on innovative, standardised and interoperable equipment: The first 
and  second  CCEI  calls  aimed  to  address  urgent  needs  and  security,  respectively,  while 
other important aspects, like innovation, were encouraged but received little attention in 
the  grants  awarded  so  far.  This  misses  the  opportunities  that  more  cutting-edge 
equipment presents for improving the effectiveness and efficiency of customs controls.  

•  Siloed  implementation  and  limited  synergies  with  other  programmes:  Despite  the 
work of the CCEI Coordination Group, which acts as a forum for exchange and produces 
guidance and technical material for use by the Member States, including on aspects like 

50 

 
 
collaboration and the sharing of equipment and data, the implementation of actual CCEI 
grants has been a purely national affair. Applications are made based on national needs 
which lead to national purchase, deployment and operation, while the CCEI has not yet 
been  used  to  any  significant  extent  to  facilitate  interoperability  and  data  sharing  across 
Member  States  or  to  pursue  joint  procurement.  This  represents  a  missed  opportunity  to 
take advantage of the CCEI’s potential to contribute to the mission of EU customs to act 
as  one,  as  well  as  to  improve  controls.  The  problem  is  less  severe  for  customs 
laboratories, since these already collaborate extensively via the CLEN. Though the CCEI 
Coordination Group could  come to  fill  this function for BCPs, it  has not happened yet, 
potentially because of fragmentation across several pre-existing groupings like CELBET 
and  European  Ports  Alliance.  Beyond  the  Customs  programme,  evidence  of  practical 
synergies with other EU programmes was also limited.  

During the remainder of the CCEI’s programming period DG TAXUD will address all aspects 
that have been identified for improvement to ensure the achievement of the Instrument’s general 
and specific objectives.  

51 

 
 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

Directorate-General Taxation and Customs Union (DG TAXUD) was in the lead in the process 
to  prepare  the  interim  evaluation  of  the  Customs  Control  Equipment  Instrument  by  the 
Commission.  

Decide planning reference: PLAN/2024/1189.  

Commission work programme reference: item 33 in Annex II to Commission Work Programme 
202528. 

An inter-service steering group (ISSG) was established to oversee the evaluation exercise. The 
ISSG comprised representatives of the Secretary General, DG BUDG, the Legal Service, OLAF, 
the Joint Research Centre, DG HOME, DG GROW and DG ENV.  

The  preparation  for  the  interim  evaluation  began  in  the  second  half  of  2023.  The  Call  for 
evidence  document  was  finalized  in  May  2024,  after  the  approval  of  the  inter-service  steering 
group.  The  Call  for  evidence  was  published  for  consultation  and  feedback  on  the  EU’s  Have 
Your Say Portal between 12 June 2024 and 10 July 2024.  

The evaluation by the Commission was supported by an external, independent study. The terms 
of reference for the study were approved by the ISSG. The tendering procedure was performed 
by DG TAXUD from May to August 2024. The contract to carry out the study was awarded to a 
consortium led by Economisti Associati. The study was delivered by Ipsos (lead partner for the 
assignment)  and  Syntesia,  on  behalf  of  the  consortium  led  by  Economisti  Associati  from 
September 2024 until May 2025. The inter-service steering group monitored the performance of 
the study by reviewing key deliverables (inception report, progress report, draft final report and 
final  report)  and  improving  their  quality.  The  ISSG  held  nine  meetings  over  the  period  from 
April 2024 to May 2025. The study final report was published in July 2025 on the website of the 
EU Publications Office.  

After  the  final  study  report  was  delivered,  in  June  2025  DG  TAXUD  started  drafting  the  staff 
working document, based on the external  study and the analysis of its own  documents,  reports 
and databases. The contractor used a variety of research methods and sources in the supporting 
study (for more details see annex 2).  

The  fact  that  the  interim  evaluation  took  place  at  an  early  stage  in  the  programme’s 
implementation,  with  only  a  small  number  of  projects  completed  at  the  time  of  the  exercise, 
represents  a  limitation  regarding  the  extent  to  which  firm  conclusions  can  be  drawn  on  results 
and impact. The CCEI is a compact programme in terms of scope of its activities and number of 
beneficiaries. All stakeholder consultation activities were carried out as planned (for more details 
see  annex  5).  All  beneficiaries  of  the  Instrument,  the  27  Member  State  customs  authorities 
participated  in  the  stakeholder  consultation  activities  to  have  sufficient  evidence  base  for  the 
conclusions.  

28 COM(2025) 45 final, dated 11.2.2025 

52 

 
 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

The interim evaluation of the Customs Control Equipment Instrument (CCEI) 2021-2027 by the 
Commission was supported by an external study  carried out by Ipsos and Syntesia. This annex 
outlines the methodology and analytical approach employed by the study. The following sections 
detail  the  overall  approach,  the  data  collection  methods,  and  the  process  of  analysing  and 
interpreting the gathered data underpinning the mid-term assessment of the Instrument. 

Overall approach 

The methodology was designed to answer the evaluation questions (EQs) outlined in the terms of 
reference (as amended during the inception phase) and covers the five evaluation criteria as set 
out in the Better Regulation Guidelines (effectiveness, efficiency, relevance, coherence, and EU 
added value). These EQs were further developed into an evaluation matrix (see Annex 3), which 
also  defined  corresponding  specific  judgment  criteria,  indicators,  and  data  sources  for  each 
evaluation question. 

With respect to the analytical approach for the study, a mixed-methods, theory-based approach 
was  deemed  most  appropriate.  Specifically,  this  entailed  comparing  the  CCEI’s  Intervention 
Logic (developed as part of the Monitoring and Evaluation Framework) – and which includes the 
envisaged  activities,  outputs  and  results,  as  well  as  key  underlying  assumptions  –  with  the 
practical  experience  of  the  Instrument’s  implementation  to  date.  This  approach  aimed  to 
ascertain  the  extent  to  which  the  instrument  is  working  as  intended,  identify  progress  towards 
achieving the objectives, and highlight any shortcomings, challenges or bottlenecks.  

Given  that  the  Instrument  is  at  an  early  stage  of  its  implementation,  the  approach  was  also 
tailored to the interim and formative nature of the evaluation. More specifically, not all first call 
projects were completed when the study was conducted, and the second call projects were just 
getting  under  way.  As  such,  and  in  line  with  the  terms  of  reference,  this  study  and  its 
underpinning approach focus “on confirming the validity of the shared common vision and initial 
design”,  and  on  “identifying  weaknesses  to  increase  the  maturity  of  the  CCEI  data-driven 
approach for policy making for the subsequent invitations to submit proposals and find potential 
improvements”.  To  this  end,  the  study  provided  lessons  learnt  supporting  the  formative 
assessment.  

The study relied on a combination of qualitative and quantitative evidence. In addition to desk 
research, the study drew on a wide range of methods to ensure the key beneficiaries of the CCEI 
(i.e.  customs  authorities)  as  well  as  other  stakeholders  were  consulted  and  provided  with  an 
opportunity to share detailed feedback on their experience of taking part in and benefitting from 
the Instrument. 

Data collection methods 

To collect the primary and secondary, qualitative and quantitative evidence needed to address all 
the  evaluation  criteria  and  questions,  using  the  judgment  criteria,  indicators  and  data  sources 
outlined in the evaluation matrices, the study relied on the following methods: 

•  Desk research; 

•  Stakeholder  consultations,  including  a  written  questionnaire,  in-depth  interviews,  and  a 

stakeholder workshop; and 

•  Case studies. 

These data collection methods are set out in more detail below.  

53 

 
Desk research 

A systematic desk  research programme was  conducted to  compile, review, analyse  and extract 
relevant evidence from a range of sources including policy and programming documents, CCEI 
proposals,  DG  TAXUD  recommendations  and  grant  agreements,  amendments  and  periodic 
reports  submitted  by  Member  States  and,  importantly,  the  data  collected  under  the  CCEI’s 
Monitoring and Evaluation Framework.  

Desk research was crucial in ensuring secondary data on the context, design, implementation and 
performance of the CCEI was duly considered and taken into account. Key documents reviewed 
included:  

•  CCEI legal basis (e.g., CCEI Regulation (EU) 2021/1077). 

•  Customs policy documents. 

•  CCEI planning documents, including MAWPs, calls for proposals, etc. 

•  CCEI monitoring data, e.g. time to notify, time to grant etc. 

•  CCEI application templates and applications for the countries selected as part of the case 

study selection. 

•  DG  TAXUD  recommendations  to  Member  States  (MS)  following  the  review  and 

assessment of their CCEI applications.  

•  CCEI  data  model,  including  the  classification  of  CCE,  the  risk  assessment  matrix  and 

template etc.  

•  MEF data and methodology, including the definition of the monitoring indicators and the 

limitations and issues reported by DG TAXUD 

•  Other relevant documents and studies. 

This  research  provided  context  for  the  CCEI’s  broader  policy  framework,  implementation 
progress,  and  monitoring  efforts.  It  also  informed  the  study’s  assessment  of  the  CCEI  data 
model’s  effectiveness  in  addressing  risk  and  equipment  coverage  at  BCPs  and  customs 
laboratories. 

Stakeholder consultations 

An  extensive  stakeholder  consultation  programme  was  designed  and  delivered.  This  included 
three  forms  of  data  collection,  namely,  (i)  a  written  questionnaire  for  Member  State  custom 
authorities, (ii) in-depth interviews with inter alia CCEI implementers and beneficiaries and the 
CCE industry, and (iii) a validation workshop with customs administrations.  

Written questionnaire  

The purpose was  to  collect  input from  the national  customs administrations of all participating 
Member States, in a way that would facilitate the aggregation and comparison of the responses. 
The rationale for relying on a written questionnaire (rather than an online survey) was based on 
previous  DG  TAXUD  assignments,  where  this  approach  had  been  successfully  trialled  and 
allowed  for  the  collection  of  consolidated  responses  per  Member  State.  In  terms  of  the 
questionnaire’s  content,  it  was  designed  to  balance  simplicity  (with  a  view  to  maximising  the 
response rate) with the need for comprehensive information on the CCEI and its implementation 
to date. A response rate of 100% was achieved, in other words responses were received from all 
27  Member  States.  Most  Member  States  submitted  a  single  response,  but  a  few  sent  separate 
responses  from  those  responsible  for  BCPs  and  customs  laboratories,  respectively.  The  data 
collected provides rich information and important evidence on the CCEI’s implementation. The 

54 

 
responses  are  analysed  and  used  extensively  in  Annex  3  (detailed  answers  to  the  evaluation 
questions).  

Interview programme  

Complementing  the  written  questionnaire,  a  comprehensive  interview  programme  was  also 
delivered and targeted at key stakeholder groups that are important in the implementation of the 
Instrument.  In  total  49  interviews  were  conducted,  including  those  conducted  for  the  case 
studies.  More  specifically,  CCEI  implementers  (i.e.  DG  TAXUD)  as  well  as  other  DGs  (e.g., 
OLAF)  were  consulted  including  as  part  of  the  case  study  research  (i.e.  DG  TAXUD  project 
officers). Second, CCEI beneficiaries, i.e. national customs authorities, were also targeted both 
as part of the main interview programme but also as part of the case study research (see below 
for  more  information).  Third,  seven  CCE  industry  organisations  were  interviewed,  including 
several companies as  well as the European Organisation  for Security (EOS).  In  addition,  three 
interviews  with  expert  groups  were  also  conducted,  which  included  CELBET  and  the  World 
Customs Organization (WCO).  

In  terms  of  the  sequencing  of  the  interviews,  first  five  familiarisation  interviews  with 
representatives  of  various  DG  TAXUD  units  (A.1,  E.3  and  B.5)  were  conducted  during  the 
study’s  inception  phase  to  collect  initial  feedback  and  insight  on  the  Instrument’s  genesis,  its 
policy context, programme management, the data model, and other relevant aspects. The scoping 
interviews also provided valuable initial insights on the CCEI’s implementation towards the third 
and  fourth  quarter  of  2024,  as  well  as  potential  achievements  and  challenges  that  were 
investigated  further  during  the  remainder  of  the  study.  In  addition,  the  interviews  provided  an 
opportunity for DG TAXUD to convey its priorities, specific areas of interest and  expectations 
for the evaluation. 

This was followed by the interview programme ‘proper’, which was conducted in two ‘waves’: 

•  Wave  1:  targeting  relevant  Commission  services  such  as  OLAF  and  the  JRC,  but  also 
CELBET and the WCO as relevant expert groups. In addition, as mentioned above, seven 
industry organisations (including both SMEs and large enterprises) were interviewed. 

•  Wave 2: primarily targeting customs authorities that were not interviewed as part of the 
case  studies  (see  below),  in  order  to  gather  additional  input  from  them  and,  where 
appropriate,  follow  up,  clarify  and  expand  on  their  questionnaire  responses.  In  total, 
interviews were conducted with representatives of 14 Member States.   

In  addition  to  the  above,  a  couple  of  ad-hoc  interviews  with  DG  TAXUD  were  conducted  to 
gather additional evidence on the implementation of the Instrument, discuss any areas of doubt 
raised by the research and review of the MEF data and the underpinning CCEI data model. 

The  table  below  provides  an  overview  of  the  interview  programme  including  the  number  of 
interviews conducted.  

Table 6: Summary of the interview programme 

Main groups  

Interviewees  

Topics discussed 

National 
authorities  

customs 

Wave 2 interviews: 

•  BG, CY, DE, DK, FR, HU, 
IE,  LT,  LU,  LV,  MT,  PT, 
SE and SK. 

Case study interviews: 

•  AT,  BE,  EE,  ES,  HR,  IT, 

FI, NL, PL and RO 

•  Main  needs  as  regards  customs  control  equipment,  and 
extent to which this coincides with CCEI rules and priorities  
•  Views and experiences on CCEI design, incl. MAWPs, calls 

for proposals  

•  Main reasons for applying for CCEI funding (or not)  
•  Views  and  experiences  on  CCEI 

implementation  and 

operations, incl. grant management, data model, etc.  

•  Assessment of progress towards achieving objectives, drivers 
and  barriers  of  success,  (expected)  impacts  on  operational 

55 

 
 
 
Main groups  

Interviewees  

Topics discussed 

Total: 27* 

Relevant expert groups   Wave 1: 

•  CELBET  
•  WCO TEG-NII  

Total: 2 

European  Commission 
and 
EU 
other 
Institutions  

Scoping interviews: 

•  DG TAXUD (x5) 

Wave 1: 

JRC 

• 
•  OLAF (x2)  

Case studies: 
•  DG 

TAXUD 

project 

officers (x3)  

Ad-hoc interviews: 

•  DG TAXUD (x2) 

Total: 13 

Wave 1: 

•  Arktis Detectors 
•  CAEN 
• 

European  Organisation  for 
Security (EOS) 

•  Halo Xrays 
•  Rapsican Systems 
•  Rhode Schwarz 
• 

Smiths Detection 

Customs 
Equipment Industry  

Control 

work  

•  Costs and burdens associated with CCEI  
•  Unmet  needs,  room  for  improvement  and  suggestions  for 

changes  

•  Effectiveness of CCEI governance and coordination  
•  Usefulness of different groups and networks  
•  Extent to which the work and deliverables of relevant expert 
groups are considered in CCEI design and implementation  
•  Main  needs  as  regards  customs  control  equipment,  and 
extent to which this coincides with CCEI rules and priorities  
•  Unmet  needs,  room  for  improvement  and  suggestions  for 

changes  

•  Reasons for and views on CCEI design, incl. MAWPs, calls 

• 

for proposals.  
implementation, 
Practical  experiences  with  CCEI 
quality of applications, functioning of key procedures  
Functioning of the CCEI data model  

• 
•  Assessment of progress towards achieving objectives, drivers 

incl. 

and barriers of success  

•  Coherence, complementarities or overlaps with other key EU 

policies and programmes  

•  Efficiency  of  coordination  with  other  DGs  regarding  the 
preparation  of  work  programmes  to  avoid  overlap  and 
promote synergies  
• 
Scope for further simplifications, other improvements  
•  National  procurement,  including  the  transparency  of  the 

• 
• 
• 

process and requirements.   
Joint procurement  
Supply bottlenecks  
Innovate customs control equipment and the extent to which 
the  CCEI  has  been  successfully  at  supporting 
their 
deployment. 

•  Cybersecurity  

Total  

Total: 7 
49 

* NB: As part of the case studies, more than one interview was carried out with a few national customs authorities. In many other 
cases,  two  or  more  officials  took  part  in  the  same  interview.  The  numbers  above  relate  to  the  number  of  separate  interviews 
conducted, not the number of participants (which would be significantly higher).  

Validation workshop  

In addition, an online validation workshop was held towards the end of the study, when all other 
data  collection  had  been  finalised.  The  workshop  was  designed  to  provide  representatives  of 
national  customs  authorities  with  an  opportunity  to  review,  validate,  and,  where  needed, 
contribute to refining the preliminary and emerging results of the study. The agenda included:  

▪  The presentation of the key preliminary findings by the study team  

▪  Discussion of the findings in breakout groups  

▪  Plenary  discussion  (including  a  summary  of  the  main  points  from  each  breakout  group 

and a discussion of the future of the CCEI)  

▪  Wrap-up and next steps  

In  total,  40  representatives  of  the  national  customs  administrations  from  19  different  Member 
States  attended  the  workshop  (in  addition  to  representatives  from  DG  TAXUD  and  the  study 
team). The workshop confirmed most of the preliminary findings that were presented, but it was 

56 

 
 
 
 
 
 
 
 
also important in refining certain findings and conclusions / lessons learnt as they are presented 
in this report.  

In summary, a critical mass of stakeholder feedback was gathered across all relevant and targeted 
stakeholder groups, which included DG TAXUD involved in the design and implementation of 
the CCEI, other DGs also relevant because, in part, of their involvement in the implementation 
process  as  well  as  expert  groups  on  customs.  Customs  authorities  were  consulted  via  all  three 
stakeholder  consultation  methods  and  were  able  to  provide  expertise  feedback.  To  further 
investigate,  among  others,  issues  with  public  procurement  CCE  industry  representatives  were 
also targeted, and seven manufactures and/or vendors were interviewed to better understand their 
experience with public procurement procedures and practices and assess the overall ability of the 
existing supply of CCE to meet the demand induced, in part, by the CCEI.   

Case studies 

Ten  case  studies  were  conducted  on  projects  launched  in  response  to  the  first  CCEI  call  for 
proposals.  The  purpose  of  the  case  studies  was  to  explore  early  outputs,  results,  procedural 
experiences, and illustrate key factors affecting implementation. 

The  unit  of  analysis  for  each  case  study  was  an  individual  grant  (for  either  a  BCP  or  a  Labs 
project),  rather  than  the  recipient  country,  so  as  to  allow  for  an  in-depth  investigation  of  the 
specifics of the selected projects. Moreover, given that projects from the second call have only 
just commenced (meaning that evaluating their limited progress would be somewhat reductive) 
at the time the research was carried out, the case studies only looked at grants from the first call. 
This approach allowed the study to more closely examine the dynamics and specificities of each 
grant and better explore the effects of CCEI funding, including any difficulties and issues faced 
during  implementation  and  their  root  causes,  as  well  as  illustrate  success  stories  and  good 
practices.  

Within  the  overall  portfolio  of  CCEI  projects  (and  two  principal  categories  of  grants),  there  is 
considerable variety in terms of grant size, project maturity, and equipment type, which the case 
studies  had  to  capture.  Furthermore,  it  was  imperative  that  the  case  studies  cover  different 
regions of the EU as well as the different predominant types of customs entry points, including 
external  land  borders,  sea,  and  airports.  Balancing  these  different  considerations  required  a 
purposeful sampling approach, which included the following criteria:  

•  Balance between BCPS and Labs: eight BCP projects and 2 custom Laboratory projects 

were selected. 

•  Geographical  balance:  The  selected  projects  represent  a  diverse  range  of  EU  Member 
States,  including  both  larger  and  smaller  countries  from  different  regions.  This  ensured 
the  evaluation  captured  varied  national  contexts  and  implementation  challenges  across 
the EU. 

•  Range  of  grant  sizes:  Both  large-scale  projects  with  substantial  funding  and  smaller 
initiatives  were  included.  This  variety  allowed  for  an  assessment  of  how  the  scale  of 
funding impacts project implementation and outcomes. 

•  Variety of equipment types: The case studies cover a wide spectrum of customs control 
equipment,  including  non-intrusive  inspection  systems,  detection  devices  for  hidden 
objects, radiation detection equipment, and laboratory analysis tools. This diversity helps 
evaluate the CCEI’s effectiveness across different technological domains. 

•  Different  stages  of  project  completion:  The  sample  includes  projects  at  various 
implementation  stages,  from  those  recently  initiated  to  those  nearing  completion  or 

57 

 
already finished. This  range provides insights into challenges and successes at  different 
project phases, offering a comprehensive view of the CCEI’s impact over time. 

The table below provides an overview of the sample selected for the case study and the rationale 
for inclusion of the ten grants.  

Table 7: Overview of the ten CCEI first call project case studies 

# 

Project title 

Member State 

EU 
contribution 

BCPs 

Reasons for selection 

1 

Different scan and 
detection equipment 

The 
Netherlands 

EUR 23,681,372 

Selected  due  to  its  strategic  importance,  hosting 
Europe’s  busiest  seaport  (Rotterdam)  and  one  of  its 
busiest international airports. The Dutch BCP grant is 
among 
the 
largest,  offering 
implementation of substantial CCEI funding.  

insights 

into 

the 

2 

3 

4 

5 

6 

7 

Purchase of mobile 
X-ray for seaports 

Estonia 

EUR 2,404,000 

for 

its  unique  challenges,  particularly 
Chosen 
security-related  procurement  issues  identified  during 
scoping interviews. It represents a smaller BCP grant 
focused  on  a  strategically  significant  border  point, 
providing  perspective  on  CCEI  implementation  in 
smaller-scale projects. 

Belgian customs – 
proposal for BCP 

Belgium 

EUR 19,879,200 

Development the 
efficiency of the 
customs control 
activity of the 
Romanian Customs 
Authority 

Strengthening the 
operational 
capabilities of the 
Polish National 
Revenue 
Administration 

Spanish Customs 
Non- Intrusive 
Inspection Capacity 
Enhancement 

Romania 

EUR 13,746,640 

Poland 

EUR 25,840,800 

Spain 

EUR 3,707,652 

Securing Europe, 
improving Finnish 
BCPs 

Finland 

EUR 16,807,401 

58 

interviews  due 

mid-implementation 

to 
Highlighted  during  scoping 
project 
significant 
into 
modifications,  offering  valuable 
adaptive  project  management.  The  large  grant  size 
reflects  Belgium's  importance  in  EU  trade,  hosting 
one of Europe's busiest seaports in Antwerp. 

insights 

Selected  for  its  sizeable  grant  (EUR  14  million)  and 
strategic  location  on  the  EU’s  southeastern  external 
land border. The case study explored identified risks 
such  as  staffing  issues  and  procurement  difficulties, 
as  well  as  the  reasons  for  and  implications  of  the 
project extension. 

Chosen as the second-largest BCP grant, supporting a 
major land border that has gained increased strategic 
importance  following  Russia’s  invasion  of  Ukraine. 
This case study examined how CCEI funding adapts 
to evolving geopolitical contexts. 

in 

Included  as  a  completed  and  successful  grant,  as 
identified 
ensures 
representation  of  southwestern  Europe  and  smaller 
BCP  grants,  providing  insights  into  efficient  project 
implementation and closure. 

interviews. 

scoping 

It 

Selected  for  its  innovative  features,  including  a 
unique  collaboration  structure,  reverse  procurement 
processes,  and  specialised  equipment  (radiation  and 
nuclear  detection).  The  involvement  of  the  national 
nuclear  authority  adds  an  interesting  dimension  to 
multi-agency cooperation. In addition, Finland's large 
external  land  border  also  adds  to  its  strategic 
relevance. 

 
 
 
# 

Project title 

Member State 

EU 
contribution 

Reasons for selection 

8 

9 

10 

Customs Control 
Equipment fulfilling 
the gaps on external 
EU border for 
Croatian Customs 

Equipment for food 
analysis and analysis 
of mineral oil and 
mineral oil 
preparations 

Upgrade and 
improvement of 
customs control 
equipment for the 
development of trade 
and interinstitutional 
cooperation – 
Customs 
Laboratories 

Croatia 

EUR 2,099,392 

Chosen for its varied and comprehensive approach, as 
noted in scoping interviews. As a smaller BCP grant, 
it 
and 
Mediterranean  Europe,  offering  insights  into  diverse 
equipment needs and implementation strategies. 

representation 

southern 

ensures 

of 

Customs Laboratories 

Austria 

EUR 162,879 

Selected  as  one  of  the  few  completed  laboratory 
projects,  also  noted  as  successful  during  scoping 
interviews. This case study provides valuable insights 
into  the  full  project  lifecycle  and  outcomes  for 
customs laboratories. 

EUR 4,880,000 

Italy 

Chosen  as  the  largest  laboratory  grant,  offering 
perspective on substantial CCEI funding for customs 
labs.  Italy’s  extensive  maritime  border  adds  context 
to 
importance  of  well-equipped  customs 
laboratories in supporting border control efforts. 

the 

For each case study, relevant documentation was reviewed, and interviews were conducted with 
project  stakeholders  (namely,  representatives  of  the  national  customs  administration  who  were 
involved in the implementation and coordination of the project in question, and the responsible 
DG  TAXUD  project  officers).  This  approach  provided  concrete  examples  of  CCEI 
implementation and its effects on customs operations. The information from the case studies was 
triangulated  with  the  evidence  from  the  other  research  strands  and  fed  into  the  evaluation 
findings and conclusions.  

Data analysis and interpretation  

During the study’s final stage, the collected evidence across all research strands was synthesised 
and  analysed  to  develop  robust  conclusions  and  practical  recommendations.  Key  elements 
included: 

•  Quantitative  analysis:  Numerical  data,  including  CCEI  monitoring  and  MEF  data  and 
quantitative  responses  from  the  customs  administrations  questionnaire,  was  processed 
using Excel. Results were presented in  tables, charts, graphs, and maps to illustrate key 
findings.  

•  Qualitative  analysis:  A  substantial  portion  of  the  evidence  base  consisted  of  qualitative 
data  capturing  feedback,  views  and  satisfaction  with  the  Instrument,  particularly  in  the 
case  of  customs  administrations.  Stakeholder  feedback  was  systematically  analysed 
against the evaluation  questions (see Annex 3). To support the analysis, a data analysis 
grid was created to harvest and compare feedback within and across stakeholder groups.  

•  Follow-up  research:  Where  necessary,  the  team  re-contacted  stakeholders  to  verify 
findings  and  clarify  ambiguities,  ensuring  the  accuracy  of  our  interpretations.  These 
included,  for  instance  ad-hoc  interviews  with  DG  TAXUD  to  further  discuss  the  data 
model and MEF data.  

59 

 
 
 
•  Triangulation  and  interpretation:  Finally,  the  findings  and  evidence  were  compared 
across different methods and key differentiators to assess their validity and consistency. 
This process involved: 

▪  cross-referencing findings from various sources; 

▪  assessing the strength of underlying evidence; 

▪ 

▪ 

reconciling inconsistencies where possible; 

formulating  responses  to  each  evaluation  question  based  on  the  weight  of 
evidence; and 

▪  clarifying caveats, uncertainties, and limitations of the evidence. 

The results of the triangulation exercise and interpretation of the data are presented in the next 
annex  which  contains  the  detailed  answers  to  the  evaluation  questions  against  the  evaluation 
framework.  

60 

 
 
ANNEX III. EVALUATION MATRIX AND ANSWERS TO THE EVALUATION QUESTIONS 

This  annex  contains  the  detailed  responses  to  the  14  evaluation  questions  under  the  five 
evaluation  criteria  of  effectiveness,  efficiency,  relevance,  coherence  and  EU  added  value.  An 
evaluation  “matrix”  consisting  of  judgment  criteria,  indicators  and  sources  of  evidence  was 
developed  to  clarify  how  each  question  was  to  be  answered.  These  matrices  are  reproduced  in 
the  ensuing  sections  for  each  evaluation  criterion,  followed  by  the  responses  to  the 
corresponding questions. 

Effectiveness 

Under  effectiveness,  the  evaluation  set  out  to  answer  four  questions.  These  questions,  and  the 
corresponding judgment criteria, indicators and data sources are shown in the table below. The 
subsequent  sub-sections  present  the  evidence  and  answers  question  by  question,  following  the 
criteria and indicators as previously defined to the greatest extent possible.  

Table 8: Evaluation matrix for Effectiveness 

Evaluation questions 

Judgment criteria 

Indicators 

1. How effective has the 
CCEI been in progressing 
towards its objectives? 
To what extent is this 
progress in line with 
initial expectations? What 
have been the most 
prominent qualitative and 
quantitative benefits of the 
CCEI to date, and for 
whom? 

Extent to which the 
envisaged activities have 
been delivered 

Budget execution rate to date (i.e. total amount 
of grant agreements signed vs available funds) 
Number of projects completed / ongoing / 
delayed / cancelled 

Progress made towards the 
envisaged outputs 

Progress made towards the 
envisaged results and 
impacts 

Feedback from stakeholders on CCEI 
implementation, in particular on the extent to 
which the main assumptions to move from inputs 
to activities (as spelled out in the MEF) have 
held true  

Evolution of output indicators as defined in the 
MEF: equipment purchased, maintained or 
upgraded (OP 1.1); use of equipment (OP 1.2); 
satisfaction of customs administrations with 
CCEI support (OP 1.3) 

Feedback from stakeholders on CCEI outputs, in 
particular on the extent to which the main 
assumptions to move from activities to outputs 
(as spelled out in the MEF) have held true  

Evolution of results indicators as defined in the 
MEF: Specific results achieved by MS 
(RES 1.1); contribution to equivalent results 
(RES 1.2); adherence to the common list of 
equipment (RES 1.3); coverage of risks and 
threats (RES 1.4); contribution to the 
implementation of the CRMF (RES 2)  

Feedback from stakeholders on CCEI results, in 
particular on the extent to which the main 
assumptions to move from outputs to results (as 
spelled out in the MEF) have held true  

Extent to which CCEI has ensured equipment is 
secure and safe (in terms of protection of data, 
cyber-resilience) and environmentally-friendly 
(incl. as regards the disposal of the replaced 
equipment)  

61 

Data sources 

•  CCEI monitoring 

data 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

•  CCEI monitoring 

data 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

•  CCEI monitoring 

data 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

•  MS questionnaire 

responses 

Stakeholder 
interviews 

In-depth case 

• 

• 

 
Evaluation questions 

Judgment criteria 

Indicators 

Extent to which internal 
factors (within the remit 
of the CCEI) are driving 
or hindering progress 

2. What were the factors 
driving or hindering 
progress towards the 
objectives and to what 
extent are they linked to 
the CCEI or to external 
factors (outside the remit 
of the CCEI)? 

Extent to which external 
factors (outside the remit 
of the CCEI) are driving 
or hindering progress 

Internal drivers and barriers identified in CCEI 
APRs, M&E data, policy and programming 
documentation and relevant external sources 

Feedback from stakeholders on the effectiveness 
of key CCEI provisions and parameters, incl. 
timeframes, general eligibility rules, funding 
priorities per call, needs assessment, data 
requirements, guidance, programme 
management, etc. 

Concrete effects (positive and/or negative) of 
different internal factors on the implementation, 
progress and results of specific CCEI projects 

External drivers and barriers identified in CCEI 
APRs, M&E data, policy and programming 
documentation and relevant external sources 

Feedback from stakeholders on the effects of 
external factors, incl. MS customs’ resources and 
administrative capabilities, geopolitical factors, 
supply issues (price volatility, cybersecurity 
concerns), etc. 

Concrete effects (positive and/or negative) of 
different external factors on the implementation, 
progress and results of specific CCEI projects 

3. To what extent is the 
CCEI used by the 
Member States and what 
are the factors that 
encourage or hinder its 
use? 

Level of demand for CCEI 
funding 

Number of MS that have applied for CCEI 
funding in response to the 1st and 2nd calls for 
proposals per category (BCPs / labs) 

Reasons that encourage or 
hinder MS use of CCEI 

Amount of funding requested and awarded to 
date (per MS) relative to the available amount 
per call and category (BCPs / labs) and type of 
BCP 

Feedback from MS customs administrations on 
the reasons for (not) applying for (more) CCEI 
funding, e.g. level of alignment with key needs 
and challenges, absence / scarcity of alternative 
funding sources, administrative capacity, 
awareness, other factors 

Concrete effects (positive and/or negative) of 
different internal or external factors on the use of 
CCEI in the context of specific CCEI projects 

4. What factors are 
limiting the use of the 
CCEI data model and 
what is necessary to use it 
to its full potential? 

Relevance, quality and 
practicality of the CCEI 
data model 

Assessment of the comprehensiveness, 
granularity, clarity and user-friendliness of the 
data model and requirements 

Level of MS compliance with data requested by 
the EC (in terms of quantity and quality), and 
ease / difficulty for national customs to provide 
the data  

Extent to which the CCEI 
data model is fit for its 
purpose 

Stakeholder feedback on the usefulness in 
practice of the data that has been collected to 
date for the purpose of CCEI programming, 
priority setting, identification of needs and 
assessment of applications 

Stakeholder feedback on the usefulness in 

62 

Data sources 

studies 

•  Document review 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

• 

In-depth case 
studies 

•  Document review 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

• 

In-depth case 
studies 

•  CCEI monitoring 

data 

•  CCEI monitoring 

data 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

• 

In-depth case 
studies 

•  Document review 

• 

Stakeholder 
interviews (DG 
TAXUD) 

•  Document review 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

 
Evaluation questions 

Judgment criteria 

Indicators 

practice of the data that has been collected to 
date for the purpose of CCEI reporting, 
monitoring, analysis and evaluation 

Stakeholder suggestions for improvements of the 
model, and extent to which these would be likely 
to facilitate its greater use 

Data sources 

• 

In-depth case 
studies 

EQ 1. How effective has the CCEI been in progressing towards its objectives? To what extent is 
this  progress  in  line  with  initial  expectations?  What  have  been  the  most  prominent  qualitative 
and quantitative benefits of the CCEI to date, and for whom? 

To  respond  to  this  evaluation  question,  the  different  levels  of  the  intervention  logic  were 
considered, namely whether the envisaged activities have been delivered, and to what extent they 
have facilitated progress towards the expected outputs and results.  It is considered how far key 
assumptions needed for the causal chain to function as expected (as identified in the intervention 
logic) have proven to be correct, what benefits have been obtained to date, and what additional 
benefits  the CCEI is  likely  to  contribute to  going forward. The key factors that have driven or 
hindered progress are discussed in more detail under subsequent questions, in particular EQ 2. 

Extent to which the envisaged activities have been delivered 

The main activity envisaged for the CCEI is the provision of financial support for the purchase, 
maintenance and upgrade of customs control equipment. In practice, this support (up to 80% of 
the total cost of the equipment in question) is provided to specific projects implemented by the 
national  customs  administrations  of  EU  Member  States,  which  are  selected  by  the  European 
Commission  based  on  applications  submitted  by  the  Member  States  in  response  to  calls  for 
proposals. 

Two Multi-Annual Work Programmes (MAWPs) and corresponding calls for proposal have been 
published  under  the  CCEI.  The  first  call,  in  November  2021,  led  to  the  signature  of  grant 
agreements for 42 projects, which were awarded a total of EUR 273 million of EU co-financing. 
Most of these projects were still ongoing in mid-2025. Several of the original grant agreements 
have  been  subject  to  amendments,  in  many  cases  extending  their  duration.  The  second  call, 
launched  in  December  2023,  is  expected  to  lead  to  the  signature  of  grant  agreements  for  47 
projects (most of which were signed at the end of 2024, but one still pending in mid-2025) with 
EU  co-financing  totalling  EUR  284  million.  Some  of  these  projects  were  officially  started  in 
2024, but the majority is to be launched in the first half of 2025. The EU co-financing amounts 
mentioned above for the grants awarded after the two calls for proposals correspond to a budget 
execution rate very close to 100% of the available funds. 

All 27 Member States have received support for one or more projects under at least one of the 
calls; the majority has benefited and/or is benefiting from both. However, the size of the grants 
varies  significantly,  with  Bulgaria,  Poland,  Italy,  the  Netherlands  and  Romania  having  been 
awarded the highest amounts (totalling more than EUR 40 million each for projects under both 
calls). Across all calls, projects and countries, around 88% of the EU funding was for equipment 
for  BCPs,  while  a  much  smaller  amount  (approx.  12%)  was  for  equipment  for  customs 
laboratories. 

Among  the  key  assumptions  identified  in  the  MEF  that  are  needed  to  move  from  inputs  to 
activities and beyond is the availability of sufficient financial and human resources at both EU 
and  national  levels.  Based  on  the  questionnaire  responses,  national  customs  authorities  viewed 
the resources at EU level as sufficient: a large majority of responding MS officials at least tended 
to agree that the CCEI budget is sufficient for filling performance gaps and making a difference 

63 

 
to their customs controls, and was highly satisfied with the support that TAXUD is providing to 
the implementation. In this context, it is also worth noting that neither of the first two calls were 
significantly  oversubscribed,  i.e.  that  the  demand  for  EU  funding  was  closely  aligned  with  the 
supply,  suggesting  that  the  CCEI  budget  has  not  been  a  constraining  factor  so  far  (for  further 
details on this, see EQ 3). However, there were much lower levels of agreement, as well as an 
element  of  disagreement,  with  statements  relating  to  the  availability  of  resources  at  national 
level, suggesting that not all MS find it easy to obtain the necessary national co-funding, or have 
available sufficient human resources to implement the CCEI. In their additional comments, some 
MS  stressed  that  co-funding  can  pose  a  significant  problem  in  some  cases,  and  that  not  all 
customs authorities have staff specifically dedicated or trained for this type of grant management 
and implementation. 

Figure 12: Please express your level of agreement with the following assumptions related to the 
available resources for the instrument 

Source: Questionnaire responses from national customs administrations 

Another important set of assumptions / prerequisites identified in the MEF concerns the ability to 
effectively assess, identify and address needs. Again, based on their questionnaire responses, all 
national customs authorities agreed or tended to agree that the list of equipment that is eligible 
for  CCEI  co-funding  is  aligned  with  their  needs  (though  with  some  caveats,  which  are 
considered  under  EQ 2  below).  The  majority  also  believed  that,  by  and  large,  the  needs  are 
identified appropriately, and that they were able to provide the information necessary to inform 
the CCEI priorities. However, only a small proportion agreed strongly – and a similar proportion 
disagreed – that the information they have to submit as part of CCEI grant applications (via the 
detailed budget sheets) is relevant for identifying the needs of their administration. This is in line 
with  other  concerns  raised  about  the  CCEI  data  model,  which  are  discussed  in  greater  detail 
under EQ 4. 

64 

 
 
Figure  13:  Please  express  your  level  of  agreement  with  the  following  statements  about  the 
CCEI’s ability to identify the needs of your country. 

Source: Questionnaire responses from national customs administrations 

The final set of assumptions at this level in the MEF relates to  the transparent  and appropriate 
allocation of the funds. In this respect, national customs authorities did not have any concerns: in 
their questionnaire responses, at  least  90% agreed (including 65% who  agreed  “strongly”) that 
CCEI funding is allocated by the Commission transparently based on the defined award criteria, 
and that funding allocated conforms to the CCEI’s priorities. Not a single respondent disagreed 
with either of these statements.  

The  interviews  and  case  studies  provided  additional  insights  into  the  various  factors  that  have 
driven or hindered progress; these are discussed under EQ 2 below. 

Progress made towards the envisaged outputs 

The  envisaged  outputs  of  the  CCEI  are  improvements  in  the  extent  to  which  customs  offices 
(BCPs  and  laboratories)  are  equipped  with  customs  control  equipment  that  is  properly 
functioning, modern, reliable, safe, and environmentally friendly. The progress towards this is to 
be measured via a series of Output (OP) indicators defined in the MEF. 

The  first  indicator  (OP 1.1)  concerns  the  number  of  pieces  of  equipment  that  were  purchased, 
maintained or upgraded through CCEI funds. Based on the data submitted by the Member States, 
the  total  achieved  by  end  2024  was  907  pieces  of  equipment,  which  is  47%  of  all  pieces  that 
Member States originally intended to purchase, maintain or upgrade as part of projects under the 
first call. The highest numbers corresponded to ‘Radiation detection and nuclide identification’ 
(227  units  purchased,  maintained  or  upgraded)  and  ‘Non-intrusive  inspection’  (175  units) 
equipment for BCPs, and ‘Analytical Instruments and Analysers’ (110 units) for laboratories.  

Table 9: Pieces of equipment purchased, maintained or upgraded through CCEI funds 

Equipment supported by the CCEI (as of end 2024) 

Purchased  Maintained 

Upgraded 

Total 

Target 
under call 1 

% of target 
achieved 

BCPs 

Laboratories 

546 

299 

20 

35 

573 

334 

1,398 

524 

41% 

64% 

7 

0 

65 

 
 
 
 
Total 

845 

55 

7 

907 

1,922 

47% 

The second indicator (OP 1.2) concerns the utilisation of the equipment purchased, maintained or 
upgraded  through  CCEI  funds,  which  is  measured  by  the  ‘occupancy  rate’,  indicating  the 
frequency of equipment  use (a 100% occupancy rate means “daily use”).  Analysis of the 2024 
data  reveals  that  the  actual  usage  is  closely  aligned  with  the  targets  for  all  equipment  types. 
Equipment at BCPs is used very frequently, with occupancy rates above 90% for most categories 
of BCP equipment. Occupancy rates of laboratory equipment tend to be a little lower (between 
50  and  70%),  but  also  in  line  with  targets.  This  suggests  that,  overall,  the  equipment  is  used 
extensively and in line with expectations.  

The third output indicator (OP 1.3) measures national customs administrations’ satisfaction with 
the  guidance,  programme  management,  and  timeliness  of  support  provided  by  the  CCEI.  It 
incorporates  data  from  surveys  addressed  to  MS  in  2022,  2023,  and  2024,  which  show  that 
satisfaction levels have been consistently high – with nearly 100% of respondents either satisfied 
or  fully  satisfied  with  all  aspects  (namely,  the  quality  of  (1)  the  guidance  provided  at  the 
application stage, (2) the information  contained in the call documentation, and (3) the ongoing 
guidance provided during implementation). However, the indicator on adherence to deadlines / 
timelines set out in the relevant grant agreements was only 91% in 2024  – the first time it fell 
below 100%. 

Several  of  the  projects  that  were  supported  by  CCEI  grants  under  the  first  call  are  subject  to 
delays  which,  overall,  has  meant  that  progress  towards  the  envisaged  outputs  has  been  slower 
than  expected.  In  May  2025  only  13  projects  have  been  completed,  while  20  of  the  42 
call 1 projects have had or are having their duration extended, which has certainly contributed to 
the  relatively  slow  progress  with  the  OP  indicators.  It  is  worth  noting  that,  although  the 
application evaluation  and grant  signature process  took  a significant  amount of time (251 days 
on average for call 1 in 2022, and 257 days for call 2 in 2024), it was completed within the “time 
to grant” deadline defined by DG TAXUD (275 days) in all cases except one29. Thus, the main 
factor  in  the  slower  than  expected  implementation  of  the  CCEI  is  the  slow  progress  of  many 
projects. In the questionnaire, national customs administrations were asked to assess the progress 
in implementing the CCEI grants awarded to their country so far; based on the responses, over 
half (53%) of projects have been progressing slower than expected. 

The main reasons for these delays were external, i.e. not related to the design or management of 
the CCEI as such. In the majority of cases, problems with procurement procedures at the national 
level  were  to  blame  for  the  delays  experienced  by  many  projects.  In  their  questionnaire 
responses, only  52% of national  customs authorities agreed (and only  half of these “strongly”) 
that  procurement  processes  at  national  level  function  sufficiently  well  to  allow  the  effective 
purchase  of  the  equipment  in  question.  In  their  responses  and  during  interviews,  customs 
authorities  mentioned  inter  alia  appeals  or  complaints  from  unsuccessful  tenderers,  a  lack  of 
bidders, uncertainty about if and how to exclude certain suppliers due to cybersecurity concerns, 
a  lack  of  experts  and  human  resources  in  the  national  procurement  units,  cumbersome 
procedures involving multiple permits and approvals, and budget freezes as factors that slowed 
down  the  procurement  of  the  equipment  in  question.  During  interviews,  manufacturers  of 
customs  control  equipment  also  noted  difficulties  navigating  different  rules  and  procedures 
across  EU  MS,  particularly  for  more  sensitive  technologies,  and  expressed  a  desire  for  clearer 

29 The preparation of four grant agreements in the second call are not taken into account in the calculation because 

the causes for the delays were outside the control of DG TAXUD.  

66 

 
 
guidance  on  topics  like  licensing  requirements,  cybersecurity  standards,  and  how  to  get  new 
technologies approved for CCEI funding. 

Further to this, changes in the geopolitical situation – in particular the Russian full-scale invasion 
of Ukraine and resulting changes to traffic patterns and volumes at certain BCPs – led some MS 
to  revisit  and  amend  their  procurement  plans,  and  re-orient  their  CCEI  projects,  which  also 
resulted  in  delays.  On  the  other  hand,  supply-side  issues  do  not  appear  to  have  played  a 
significant role: 84% of respondents to the questionnaire for national customs authorities agreed 
that the required  equipment  is  available on the  market.  In the  relatively few cases where there 
seem  to  have  been  supply  problems,  bottlenecks  may  have  been  partly  caused  –  according  to 
some  interviewees  –  by  a  simultaneous  surge  in  demand  for  certain  types  of  equipment  from 
several  MS  due  to  the  CCEI.  However,  there  is  no  evidence  to  suggest  that  this  has  been  a 
widespread or significant constraint for projects. 

Progress made towards the envisaged results and impacts 

Judging  –  let  alone  measuring  quantitatively  –  the  results  and  impacts  of  the  CCEI  is  difficult 
given  the  early  stage  of  implementation.  In  principle,  results  are  measured  via  a  series  of 
indicators  defined  in  the  MEF,  but  all  of  these  are  subject  to  significant  challenges  and 
limitations as regards the completeness, quality and/or comparability of the underlying data. 

Indicator RES 1.1 is intended to measure the specific results achieved by Member States through 
use  of  CCEI  funded  equipment,  by  comparing  actual  results  with  MS’  commitments  (with 
reference  to  baselines  or  targets,  e.g.  in  terms  of  the  number  or  value  of  seizures  of  different 
types  of  goods  or  substances,  the  number  of  controls  conducted  or  the  hit  rate).  The  available 
data shows limited progress, with only between 10% and 21% (depending on the objective) of 
commitments achieved as of 2024. However, it needs to be re-emphasised that the quantity and 
quality  of  the  data  is  poor  due  to  significant  reporting  issues  and  inconsistencies,  meaning  the 
results should not be taken at face value. 

Indicator RES 1.2 shows the proportion of national administrations who agree that the CCEI has 
contributed  to  adequate  customs  controls  with  equivalent  results,  based  on  the  responses  to  an 
annual  survey  sent  out  by  DG  TAXUD.  Agreement  rates  are  consistently  high,  with  between 
95% and 100% of respondents agreeing or fully agreeing with the statements for each risk/threat 
category.  

Indicator  RES 1.3  attempts  to  measure  the  degree  of  adherence  of  BCPs’  equipment  to  the 
common  list  of  equipment  that  should  be  available  per  type  of  BCP.  It  is  calculated  by 
comparing the data provided by the MS regarding the equipment that is available and the main 
risks encountered, with targets for recommended equipment levels per BCP. The available data 
shows  a  small  increase  in  the  adherence  rates  (i.e.  the  proportion  of  BCPs  that  have  the 
recommended equipment) for all types of BCPs from the baseline (2022) to 2024, but the rates 
remain low (between 9% and 17% for air, land, postal, rail and sea BCPs), far below the target 
set for 2024 (60%). These consistently low rates indicate that the targets as defined are likely to 
be  unrealistic,  i.e.  overly  ambitious,  and  not  sufficiently  taking  into  account  specificities  of 
individual BCPs and the prevalent risks. 

Finally, indicator RES 1.4 is about the coverage of risks and threats, and more specifically, the 
extent to which BCPs have the necessary equipment available to mitigate identified financial and 
non-financial  risks.  Based  on  the  available  data  for  2024,  the  coverage  rates  vary  significantly 
between  types  of  BCPs  and  risks.  Overall,  mobile  BCPs  generally  demonstrate  the  highest 
coverage across the spectrum of risks and threats considered, suggesting greater effectiveness in 
risk mitigation compared to other types of BCP. However, again, the data limitations mean care 
needs to be taken when interpreting these results.  

67 

 
In the questionnaire, MS were asked to  rate, based on their experience of the  CCEI so far and 
expectations for the rest of the programming period to 2027, its likely contribution to its specific 
objective, which is to “contribute to adequate and equivalent results of customs controls through 
the  transparent  purchase,  maintenance  and  upgrading  of  relevant  and  reliable  state-of-the-art 
customs control  equipment  that is  secure, safe and environmental-friendly, thereby helping the 
customs authorities act as one to protect the interests of the Union”. Nearly three quarters (74%) 
of  respondents  believed  that  the  CCEI  would  make  a  “significant”  contribution  toward  this 
objective; the remainder expected “some” contribution (16%) or responded “don’t know” (10%). 
Not a single respondents believed the CCEI would make only a “small” or no contribution at all. 

National customs administrations were also asked a series of questions about the results achieved 
so far. The responses suggest that the equipment that has been purchased and deployed to date is 
being  used  effectively  and  as  intended  (i.e.  primarily  for  customs  controls).  The  majority  of 
respondents  reported  that  the  equipment  has  already  noticeably  improved  the  performance  of 
both  BCPs  (especially  by  improving  detection  accuracy,  but  also  by  increasing  the  speed  of, 
capacity  for  and  possible  number  of  controls)  and  customs  laboratories,  although  it  is  worth 
noting  that  there  were  a  relatively  high  number  of  neutral  or  “don’t  know”  responses  to  these 
questions.  

The data on relevant performance metrics that is available for the (few) projects that have been 
finalised  shows 
the  difficulties  of  quantitatively  measuring  and  substantiating  such 
improvements.  For  example,  in  the  case  of  the  Spanish  BCP  project,  which  was  finalised  in 
September 2024, the final report includes data on the number of controls, average process time, 
and % hit rate at the 16 BCPs that received the equipment. This shows that all of these metrics 
increased at most but not all BCPs. According to Spanish customs, the reasons for the variations 
can be manifold, and include changes in traffic volumes (e.g. significant increases in traffic can 
lead  to  longer  average  processing  times).  But  it  is  also  clear  that  some  metrics  are  open  to 
interpretation,  in  particular  the  hit  rate,  which  can  be  influenced  by  many  factors  (including 
possible deviations  of illicit  traffic flows to  other BCPs), but  also  that, when an old  scanner is 
replaced with a newer one using similar technology, one would not necessarily expect to see a 
change  in  (all  of)  the  metrics.  Overall,  in  the  Spanish  case,  interviewees  felt  that  the  lack  of 
progress on certain indicators does not necessarily mean the equipment in question is not used 
effectively.  Other  national  customs  administrations  responded  along  similar  lines.  Some  also 
provided  examples  of  how  the  CCEI  had  facilitated  more  effective  and  efficient  controls  that 
may  not  be  picked  up  by  relatively  crude  standardised  metrics.  For  example,  CCEI  support 
enabled Sweden to acquire large, fixed scanners for certain key BCPs, and allowed it to redeploy 
existing  mobile  scanners  to  other  BCPs,  reportedly  resulting  in  a  more  efficient  overall 
distribution  of  resources;  while  Germany's  acquisition  of  new  substance  detectors  expedited 
control procedures at BCPs by reducing reliance on laboratory analyses. 

On  the  other  hand,  there  were  lower  levels  of  agreement  that  the  CCEI  has  led  to  increased 
standardisation  of  equipment,  more  practical  cooperation  and/or  data  sharing  between  EU 
customs authorities. These are not aspects that have been the focus of projects and grants under 
the  first  call.  On  the  issue  of  the  lack  of  standardisation,  several  manufacturers  of  customs 
control  equipment  who  were  interviewed  noted  that  different  countries  have  varying 
specifications for similar equipment, which can lead to inefficiencies and increased costs. On the 
other  hand,  a  few  representatives  of  MS  customs  administrations  (during  interviews  and  the 
workshop) warned that, while a certain level of standardisation may be desirable for certain types 
of  equipment,  full-scale  standardisation  of,  for  example,  scanning  equipment  across  the  EU 
would fail to take into account the sometimes varying national needs, and could imply security 
risks, as criminals could also adapt to and learn to take advantage of such common standards.  

68 

 
Figure 14: If your customs administration has already purchased and deployed customs control 
equipment using one or more CCEI grants, please provide your insight on the results achieved 
so far? 

Source: Questionnaire responses from national customs administrations 

Finally, it is worth considering the extent to which the CCEI has contributed to the procurement 
of  modern  /  innovative  equipment,  and  ensured  the  equipment  is  secure  and  safe  (in  terms  of 
protection of data, cyber-resilience) and environmentally-friendly (incl. as regards the disposal of 
the  replaced  equipment).  Taking  these  elements  in  turn,  the  questionnaire  responses  from 
national customs authorities suggest the situation varies somewhat: 

•  91% agreed (incl. 52% “strongly”) that the CCEI encourages and facilitates the purchase 

of innovative, cutting-edge equipment. 

•  87% agreed (incl. 58% “strongly”) that implementation of the CCEI takes due account of 

safety and environmental considerations. 

•  77% agreed (incl. 42% “strongly”) that implementation of the CCEI takes due account of 

data protection, cyber-resilience and the security of the equipment purchased. 

•  However,  only  67%  agreed  (incl.  35%  “strongly”)  that  all  aspects  related  to  the 
equipment, including its security, could be covered by the current procurement rules. 

This suggests that, while beneficiaries (i.e. MS customs) agree with the importance of all these 
aspects in principle, in practice they do not  always play an (equally) important role in projects 
and  procurements.  The  case  studies  and  interviews  show  clearly  that  some  but  not  all  of  the 
equipment  procured  is  innovative  or  cutting-edge;  environmental  considerations  are  usually 

69 

 
 
considered  but  rarely  as  a  decisive  factor;  and  while  cyber-security  is  generally  taken  very 
seriously,  many  customs  authorities  felt  ill-equipped  to  effectively  address  concerns  in  this 
respect, namely with regard to a specific provider of scanning equipment and services.  

Summary response 

Overall,  based  on  the  evidence  outlined  previously,  it  is  reasonable  to  conclude  that  the  CCEI 
has been progressing towards its objectives relatively effectively. The activities implemented and 
outputs achieved to date are broadly in line with expectations. However, progress has been quite 
slow – partly because the first wave of grant agreements could not be signed until late 2022 (and 
the second until  late 2024), but  mainly  because at  least  half of the projects  under the first  call 
have been progressing more slowly  than expected by the national  customs  administrations that 
are  responsible  for  them.  The  two  main  reasons  for  this  are,  most  importantly,  problems  and 
delays experienced with national procurement processes and, in a few cases, changing equipment 
needs  due  to  the  evolving  geopolitical  context.  As  such,  the  slower  than  expected  pace  of 
progress is primarily a consequence of factors that are external to the CCEI, rather than of any 
significant design flaws of the CCEI, or of the way in which DG TAXUD has implemented the 
instrument. 

In spite of the slow progress, there are encouraging early results, including the fact that, by end 
2024,  over  900  pieces  of  customs  control  equipment  had  been  purchased,  maintained  or 
upgraded  with  CCEI  co-funding, and are  reportedly  being  used effectively  and thus  helping to 
improve the performance of the BCPs and customs laboratories that have received them. Once 
all  projects  under  the  first  call  are  completed,  this  number  is  expected  to  more  than  double. 
Beneficiaries (i.e. the national customs administrations) are confident that, over time, the CCEI 
will make a significant contribution to the objective of achieving adequate and equivalent results 
of customs controls across the EU. 

However,  measuring  this  contribution  quantitatively  is  and  will  continue  be  difficult  given  the 
shortcomings of the available indicators and data (see EQ 4), and the difficulty  of establishing 
the exact additionality of the EU funding (see EQ 13).  

EQ 2. What were the factors driving or hindering progress towards the objectives and to what 
extent are they linked to the CCEI or to external factors (outside the remit of the CCEI)? 

The second question under the  criterion of effectiveness  focuses on the  “why” progress  has or 
has  not  been  made,  and  on  specific  elements  that  may  have  contributed  to  this,  namely  the 
internal as well as external factors that have driven or hindered progress. 
Extent to which internal factors (within the remit of the CCEI) are driving or hindering progress 
The main internal factors that might have driven or hindered progress towards the achievement 
of  the  CCEI’s  objectives  include  the  overall  design  of  the  instrument  (including  the  available 
budget,  co-financing  rate,  and  criteria  that  define  what  equipment  is  eligible  for  co-financing), 
the priorities defined in the MAWPs, the framework for implementing the CCEI and the way it 
has been managed by DG TAXUD, as well as the extent to which the allocation of the funds is 
informed  by  a  rigorous  assessment  of  needs,  so  as  to  ensure  the  most  effective  and  efficient 
possible use of the EU’s resources. 

As  noted  above,  the  CCEI  budget  has  not  hindered  or  constrained  progress.  The  fact  that  the 
demand for co-financing has been so closely aligned with the supply suggests that the amount of 
funding available is sufficient to meet the Member States’ main needs (also see EQ 3). 

As for the co-financing rate (up to 80% of the total eligible costs of an action), several national 
customs administrations reported that obtaining the remaining 20% from national budgets can be 

70 

 
challenging, and has constrained the scope and level of ambition of some projects under the first 
and second calls. A few noted that a higher co-financing rate (potentially even 100%) would help 
to  encourage  Member  States  to  procure  more  highly  innovative,  cutting-edge  (and  thus 
expensive)  equipment.  On  the  other  hand,  most  acknowledged  that  the  co-financing  rate  is 
already  quite  generous,  and  that  expecting  the  EU  to  purchase  equipment  for  BCPs  and 
laboratories without any national contribution to the costs would be unrealistic (and potentially 
counterproductive). 

National customs authorities had a mostly positive view on how the eligibility criteria align with 
their  equipment  needs  and  priorities.  Based  on  their  questionnaire  responses,  the  level  of 
alignment is especially high for laboratory equipment, but only 30% found the criteria for BCP 
equipment  to  be  “fully”  aligned  with  their  needs.  In  their  responses  and  during  interviews, 
several Member States identified additional needs that are not or only partly eligible under the 
current  criteria (though it should be noted that these can potentially be addressed via other EU 
programmes or funds; see EQ 12); the main  gaps (ordered based on how  frequently they were 
mentioned) were: 

•  Several Member States saw the ineligibility of costs associated with infrastructure and/or 
training  as  a  constraint,  since  some  equipment  can  only  be  used  (effectively)  if  the 
relevant  infrastructure  (e.g.  new  lanes  for  lorries)  and/or  suitably  qualified  staff  is 
available.  A  few  interviewees  believed  that  this  might  lead  some  administrations  to 
prioritise relatively easy to use and install (in particular mobile or handheld) equipment 
when applying for CCEI funding.  

•  Several  Member  States  applied  (or  would  have  liked  to  apply)  for  co-financing  for  IT 
equipment  (including  both  hardware  and  software)  that  can  facilitate  the  effective 
functioning  of  BCP  equipment,  in  particular  by  enabling  the  connection  between, 
integration, centralised control and/or analysis of equipment at, and data / images from, 
different BCPs. However, such equipment is not eligible, and the associated costs were 
therefore excluded from CCEI grants.  

•  A  few  Member  States  expressed  disappointment  that  maintenance  costs  were  not 
covered. While the CCEI can support not only the purchase and upgrading, but also the 
maintenance of equipment (and in a few instances this was the case), they reported that it 
had not been possible to obtain co-financing for the cost of maintaining (existing) BCP 
equipment under the second call. 

•  More  generally,  a  few  administrations  argued  that  the  eligibility  criteria  should  be 
defined more flexibly and dynamically, to better allow for the inclusion of cutting-edge, 
innovative,  potentially  “game  changing”  technologies  such  as  AI-powered  systems  or 
drones. 

Figure 15: To what extent do the eligibility criteria align with the equipment needs and priorities 
of your administration? 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Eligibility criteria for BCPs

30%

53%

10%

7%

Eligibility criteria for customs laboratories

52%

22%

4%

22%

Fully aligned

Mostly aligned

Partly aligned

Not aligned at all

Don’t know

71 

 
 
Source: Questionnaire responses from national customs administrations 

The priorities defined in the MAWPs were deemed to be relevant by beneficiaries, and thus seem 
to have facilitated, and certainly not hindered, progress (for more on this, see EQ 8). At the same 
time, it is worth noting that these priorities were quite broad and all-encompassing, and as such 
have not necessarily contributed to channelling funding towards the most significant needs and 
gaps (as discussed in more detail below).  

The framework for implementing the CCEI (including the process for defining the priorities, the 
work of the CCEI Coordination Group, and in particular the guidance provided by DG TAXUD) 
were viewed favourably  by beneficiaries, and there are no indications that  this has in  any way 
hindered progress. In interviews, almost all national customs authorities were complimentary of 
the  way  the  Commission  manages  the  instrument,  and  especially  of  the  hands-on  support 
provided,  and  of  the  flexibility  and  pragmatism  shown,  by  DG  TAXUD  project  officers. 
However,  they  were  more  critical  of  the  data  model,  with  many  expressing  concerns  and 
reservations about (some of) the data that applicants and grantees are required to provide to DG 
TAXUD. For further details on the data model, please see EQ 4. For more information about the 
efficiency of the CCEI framework as a whole, see EQ 5.   

Finally,  another  internal  factor  that  warrants  a  nuanced  consideration  is  the  way  needs  are 
assessed  and  used  to  determine  the  allocation  of  CCEI  funding.  As  per  the  CCEI  Regulation 
(recital  24),  “implementation  should  be  supported  by  assessments  of  needs”  with  the 
involvement of national customs authorities and based on a clear methodology; the Commission 
should  use  this  information  to  determine  the  allocation  of  the  funds  to  MS,  taking  into 
consideration factors including volumes of trade, relevant risks, and the administrative capacity 
of  the  customs  authorities.  To  contribute  to  budgetary  discipline,  “the  conditions  for  the 
prioritisation  of  grants  should  be  clearly  defined  and  based  on  such  an  assessment  of  needs”, 
driven  by  data  on  the  available  customs  control  equipment  at  each  BCP,  compared  with  a 
common list of equipment that should be available (Article 11(4)). 

In  the  first  instance,  priorities  are  defined  in  each  MAWP  to  address  specific  needs.  The  first 
(2021-2022) MAWP and call corresponded to a short-term approach dedicated to addressing the 
most urgent needs and raising customs control performance. To facilitate this, the priorities were 
kept very general and flexible, and MS were even allowed to apply for funding retroactively (i.e. 
include  costs  that  had  already  been  incurred).  The  second  (2023-2024)  MAWP  and 
corresponding  call  were  based  on  a  “comprehensive  mapping  of  the  entire  customs  union  to 
determine areas that need particular attention”, based on the data collected from MS in the first 
call.  This  showed  that  there  were  still  urgent  needs  (in  terms  of  missing  and  inadequate 
equipment), and meant it was “essential to identify concrete policy priorities to ensure targeted 
and efficient use of the available funds.” The priorities of the second call were narrowed to focus 
on  more  specific  policy  areas,  namely  (1)  Safety  and  Security;  (2)  Mitigating  international 
conflicts and crises; (3) e-Commerce; (4) Building Green Capabilities; and (5) Interoperability & 
Innovation.  All  five  priorities  were  included  within  the  “Added  value”  criterion  against  which 
proposals were evaluated, but only for the Safety and Security criteria did the evaluation criteria 
explicitly require “mandatory coverage of at least one of the relevant risks/threats.” Thus, while 
the second call did aim to introduce an increased focus on specific priorities informed by actual 
needs,  it  should  be  noted  that  most  (if  not  all)  types  of  eligible  equipment  could  still  be 
reasonably  justified as  addressing  at  least  one, and potentially  several  of the five priorities. As 
such, it does not seem that these priorities significantly limited the types of equipment for which 
MS could apply for co-financing. 

In the second instance, focusing the available funding at the most significant needs is meant to 
happen  at  the  level  of  individual  proposals  and  projects,  by  ensuring  the  evaluation  of 

72 

 
applications duly considers the extent to which the equipment MS apply for responds to the main 
risks and needs. In theory, this is achieved via the award criteria, in particular “Relevance” and 
“Added  value”,  which  should  ensure  that  the  projects  that  are  most  closely  aligned  with  the 
identified needs achieve higher scores, and are thus prioritised for funding.  

However, in the first call, in practice this prioritisation only happened to a very limited extent, 
for the following main reasons: 

•  Very broad priorities: As noted above, the first call was designed to help Member States 
address  their most urgent  equipment  needs and raising  performance overall. Therefore, 
national  customs  authorities  were  free  to  apply  for  any  eligible  equipment.  The  case 
studies show that different MS took different approaches, with some but not all of them 
focusing on the highest risks. Many projects included equipment that had to be replaced 
or  added  for  different  reasons  (in  several  cases  taking  advantage  of  the  retroactivity 
clause), but not necessarily for especially high-risk BCPs. 

•  No  competition:  As  also  noted  previously,  the  first  call  was  barely  oversubscribed, 
meaning  there  was  essentially  no  competition  for  funding,  and  hence  no  need  for  the 
Commission  to  prioritise proposals  or work packages that  were more aligned with  key 
needs or risks over others that were less aligned. In essence, MS received co-financing 
for  whatever  equipment  they  chose  to  apply  for,  if  it  was  eligible  under  the  CCEI 
criteria. 

• 

Issues with the data: The data on which needs assessments are to be based  – including 
what equipment is currently available at each BCP, compared with what should ideally 
be available in view of traffic volumes and risk profiles – is to some extent fraught. As 
discussed elsewhere in this report (including EQ 4), MS frequently struggled to interpret 
and  provide  all  of  the  data  that  was  requested,  leading  to  concerns  about  its 
comprehensiveness,  reliability  and  comparability.  In  addition,  the  “ideal”  list  of 
equipment  per  BCP  as  defined  (which  forms  the  basis  for  the  “adherence”  indicator 
RES 1.3)  appears  overly  ambitious,  and  unlikely  to  provide  a  clear  steer  as  to  which 
equipment is most needed to address key risks and gaps. 

All  in  all,  therefore,  the  envisaged  data-driven  approach  to  identifying  needs  and  allocating 
funding could only be applied to a very limited extent under the first call. As a result, it is clear 
that, by and large, the first wave of projects responded primarily to national needs and priorities 
as identified by applicants (i.e. MS) themselves, with very little steer or corrective action at EU 
level to ensure they addressed the most pressing needs of the Customs Union as a whole. 

In the second call, the situation changes somewhat. On the one hand, based on the data provided 
by MS as part of their applications for and reporting on projects under the first call (as well as 
data  from  selected  other  sources),  DG  TAXUD  provided  individual  recommendations  to  each 
national  customs  administration  regarding  which  types  of  equipment  and  risks  they  should 
prioritise under the second call. Draft recommendations were first sent in November 2023, and 
subsequently  discussed  in  bilateral  meetings,  before  a  final  version  was  sent  to  MS  as  a 
complement  to  the  call  documentation  in  December  2023.  Under  this  call,  the  Relevance 
criterion made explicit reference to the individual recommendations, and applicants were asked 
to justify the needs based on these. At the same time, the minimum passing score for Relevance 
was  increased  by  one  point  (from  5  to  6  out  of  10)  to  try  to  emphasise  the  importance  of  this 
criterion.  All  applicants  addressed  the  individual  recommendations,  some  in  a  major,  others  in 
more  minor  ways.  During  interviews,  several  national  customs  administrations  referred  to  and 
welcomed the recommendations, describing them as helpful and relevant. 

73 

 
As such, the recommendations provided an important use case for the data collected from MS, 
and,  along  with  the  more  specific  priorities,  are  likely  to  have  had  at  least  a  modest  effect  in 
terms of making applications under the second call more responsive to key needs at the level of 
the Customs Union as a whole. Nonetheless, competition for funding was again limited (the call 
was  only  oversubscribed  by  around  8%),  meaning  the  lion’s  share  of  applications  could  be 
funded, and only a limited level of selection and prioritisation was needed. As noted previously, 
no applications were rejected entirely, although some had their scope reduced with the exclusion 
of certain work packages. 

Extent  to  which  external  factors  (outside  the  remit  of  the  CCEI)  are  driving  or  hindering 
progress 

Based on the evidence collected, by far the most significant external factor that has hindered the 
progress  made  by  CCEI  projects  to  date  are  difficulties  experienced  with  completing  the 
procurement  procedures  at  national  level.  As  already  mentioned  under  EQ 1,  only  52%  of 
national  customs  authorities  who  responded  to  the  questionnaire  agreed  that  procurement 
processes  at  national  level  function  sufficiently  well  to  allow  the  effective  purchase  of  the 
equipment in question, with many citing problems with appeals or complaints from unsuccessful 
tenderers,  a  lack  of  bidders,  uncertainty  about  if  and  how  to  exclude  certain  suppliers  due  to 
cybersecurity concerns, a lack of experts and human resources in the national procurement units, 
cumbersome procedures involving multiple permits and approvals, and budget freezes as factors 
that slowed down the procurement of the equipment in question. 

The interviews and case studies helped to shed further light on how and why so many projects 
under the first call have been affected by procurement issues. Six of the ten projects that were the 
subject of case studies (the BCP projects of Belgium, Croatia, Estonia, the Netherlands, Poland 
and  Romania)  have  experienced  or  are  experiencing  delays  because  they  were  unable  to 
complete certain  procurement procedures as planned. The specific reasons for this varied from 
case  to  case,  and  included,  according  to  interviewees,  instances  where  no  (compliant)  tenders 
were  received  for  certain  lots;  appeals  from  unsuccessful  bidders;  the  need  to  re-launch 
procedures  due  to  various  reasons  including  tenderer  errors;  delays  caused  by  bureaucratic 
procedures  related  to  permits  and  land  ownership;  and  backlogs  created  by  high  volumes  of 
CCEI-supported procurement procedures, and in some cases others that had been delayed by the 
COVID-19  pandemic,  which  exceeded  the  capacity  of  the  customs  officials  and  units  in 
question.  In  interviews,  several  officials  from  other  (non-case  study)  MS  mentioned  having 
encountered similar issues. It appears that these were especially prevalent in larger projects that 
sought to procure high volumes of equipment, and in projects that targeted equipment that was 
new and/or innovative for the customs administrations in question, and with which they therefore 
had no or only limited procurement experience. 

A  few  MS  also  mentioned  having  encountered  supply  issues,  including  extended  delivery 
timelines for equipment due to a supply crunch at a particular point in time, and rising prices for 
certain types of equipment. 

In three of the ten case studies (Belgium, Estonia and Netherlands), as well as in several other 
projects,  cybersecurity  concerns  played  a  significant  role.  Specifically,  there  have  been  and 
continue to be significant concerns that a specific provider of scanning equipment and services 
could  facilitate  the  leakage  of  sensitive  data  to  unauthorised  users.  This  company  has  been  a 
preferred supplier to many EU MS, in large part because it offers very competitive prices, but in 
recent years, as concerns have emerged and intensified, there have increasingly been attempts to 
exclude it from procurement procedures for sensitive equipment, and to ensure it does not benefit 
from  EU  (incl.  CCEI) funding.  However, several MS have  reported difficulties with  achieving 
this  in  practice,  with  national  legislation  reportedly  offering  different,  more  or  less  effective, 

74 

 
ways  of  addressing  these  concerns.  At  EU  level,  security  and  cybersecurity  protection  of  the 
equipment  funded  was  reaffirmed  in  2023  through  the  work  carried  out  under  the  CCEI 
Coordination Group, and further clarified in the 2023-2024 CCEI MAWP and in the second call 
for  proposals,  which  provided  additional  guidance  to  increase  the  stringency  of  security  and 
cybersecurity  requirements,  and  made  allowance  for  the  granting  authority  to  request 
substantiating  documentation  of  compliance  with  reference  to  key  security  requirements 
(including the NIS2 Directive30 and security guidance issued by the Commission). Nonetheless, 
some national customs administrations reported a continued lack legal certainty in this area. In 
certain countries, procurement processes had to be cancelled, re-launched and/or specifically re-
designed to avoid results deemed incompatible with national security priorities.  

During  interviews,  manufacturers  of  customs  control  equipment  also  noted  difficulties 
navigating  different  rules  and  procedures  across  EU  MS,  particularly  for  more  sensitive 
technologies, and expressed a desire for clearer guidance on topics like licensing requirements, 
cybersecurity standards,  and how to  get  new technologies approved for CCEI funding. Several 
European manufacturers expressed concern about competition from non-EU (particularly Asian) 
suppliers based primarily on price, and expressed a desire for procurement criteria to give more 
weight to factors like security, quality, and European content, rather than focusing primarily on 
price.  Some  also  suggested  incentives  or  preferences  for  European-based  manufacturers  to 
support EU strategic autonomy in this sector. 

Another geopolitical factor that has affected the implementation of the CCEI is the Russian full-
scale  invasion  of  Ukraine,  which  has  significantly  influenced  the  customs  control  equipment 
procurement  strategies  and  priorities  of  certain  MS,  especially  those  that  share  a  border  with 
either Ukraine or Russia. In response, the MAWP 2023-2024 included the priority “Mitigating 
international  conflicts  and  crises”,  with  a  specific  emphasis  on  equipping  BCPs  to  correctly 
implement the sanctions imposed against Russia under elevated customs security risks, as well as 
performing the necessary controls to enable the flow of trade through the EU-Ukraine Solidarity 
Lanes. But some projects under the first MAWP and call were also affected by these factors; for 
example,  the  closure  of  Finland’s  Eastern  border  necessitated  substantial  changes  to  its  BCP 
project, and led the Finnish customs authority to re-focus the equipment away from land BCPs 
bordering  Russia  and  Norway,  and  towards  ports  in  Western  Finland;  these  changes  were  the 
main  reason  for  the  delayed  implementation  of  the  project.  Similarly,  Poland  reported  that  the 
purchase  of  equipment  for  a  specific  BCP  was  abandoned  due  to  the  combined  effects  of  the 
COVID-19 pandemic and the Russian invasion of Ukraine. On the other  hand, some  countries 
including  Bulgaria  and  Slovakia  reported  that  the  CCEI  had  already  helped  them  address 
challenges resulting from the war. 

As  noted  above,  the  combination  of  these  external  factors  made  it  necessary  to  amend  a 
significant  number  of  grants  agreements  to  extend  the  project  duration.  During  interviews, 
national customs authorities provided mostly positive feedback on how DG TAXUD has handled 
amendments, variably describing its approach as flexible, pragmatic and proactive. 

Summary response 

Several factors have had a positive or negative effect on the progress made by the CCEI towards 
its  objectives  to  date.  A  number  of  external  factors  have  been  responsible  for  the  delayed 
implementation  of  many  projects,  most  important  among  them  challenges  with  national 
procurement rules and procedures; many processes encountered problems that meant they could 
not be completed on time. Capacity constraints among national customs administrations were a 

30 Directive (EU) 2022/2555 on measures for a high common level of cybersecurity across the Union 

75 

 
 
contributing  factor  to  this,  especially  for  larger  and/or  more  complex  projects.  In  a  number  of 
cases, cybersecurity concerns also played an important role, while in others, projects underwent 
significant changes due to evolving geopolitical challenges and priorities, mainly resulting from 
the Russian full-scale invasion of Ukraine in 2022 and its aftermath. In a few cases, supply-side 
issues (temporary unavailability and/or rising prices of certain types of equipment) also affected 
procurement processes. Between them, these external factors have been the main reason for the 
slower than expected progress of many projects under the first call. 

By  and  large,  internal  factors  (namely  the  design  of  the  instrument,  the  available  budget,  co-
financing  rate,  and  eligibility  criteria,  the  priorities  defined  in  the  MAWPs,  the  framework  for 
implementing the CCEI and the way it has been managed by DG TAXUD) have contributed to 
driving rather than hindering progress. There is no evidence to suggest that any of these elements 
have  acted  as  a  significant  constraint  to  the  implementation  of  the  CCEI,  with  beneficiaries 
providing almost entirely positive feedback on all of them. 

Nonetheless,  a  combination  of  both  internal  and  external  factors  have  meant  that  the  extent  to 
which  the  allocation  of  the  funds  has  been  effectively  informed  by  a  rigorous  assessment  of 
needs  has  been  limited  under  the  first  and,  to  a  slightly  lesser  extent,  second  call.  There  is  no 
doubt  that  the  equipment  that  has  been  supported  by  the  CCEI  to  date  is  both  eligible  for  co-
financing  under  the  applicable  rules,  and  relevant  to  address  the  overarching  objectives. 
However,  it  responds  more  to  needs  as  identified  by  individual  MS,  which  may  not  always 
coincide with the most significant gaps and needs at EU level. Therefore, it is not entirely clear 
whether the CCEI as implemented to date ensures the most effective and efficient possible use of 
resources. 

EQ  3.  To  what  extent  is  the  CCEI  used  by  the  Member  States  and  what  are  the  factors  that 
encourage or hinder its use? 

The  response  to  this  question  considers  the  level  of  demand  from  Member  States  for  CCEI 
funding, and the main reasons that encourage or hinder their use of the instrument. 

Level of demand for CCEI funding 

All 27 MS have now used and/or are using CCEI funding. In response to the first call, 24 MS 
applied  for  and  were  awarded  funding.  All  three  MS  that  did  not  apply  under  the  first  call 
(Denmark, Greece and Malta) applied (successfully) under the second call. By contrast, two MS 
that were active under the first call chose not to apply under the second (Estonia and Portugal). 
Under  each  call,  the  majority  of  MS  applied  for  funding  for  equipment  for  both  BCPs  and 
laboratories, but a few went only for BCPs. 

Table 10: Number of EU Member States that applied for CCEI funding, per call 

First call (2021-2022) 

Second call (2023-2024) 

For BCPs and laboratories 

Only for BCPs 

Only for customs laboratories 

Total 

18 

6 

0 

24 

22 

3 

0 

25 

The amount of co-financing per MS was capped at 15% of the topic budget, meaning that, under 
the first call, each MS could have applied for up to EUR 40.7 million of co-financing (EUR 32.5 
million  for  BCPs,  and  EUR  8.1  million  for  laboratories).  In  practice,  the  vast  majority  of  MS 
chose to apply for significantly less – around EUR 11.4 million on average under the first call, 

76 

 
 
with half of the proposals (21, including all except three of the laboratories projects) requesting 
co-funding  of  less  than  EUR  2  million,  and  only  four  (all  BCP  projects)  requesting  more  than 
EUR 20 million. The table below shows the aggregate amounts that were available and applied 
for under each call. It shows that, in both cases, the total demand for funding was only slightly 
higher than the supply: the first call was oversubscribed by less than 1%, and the second by 8%. 
It should also be noted that 80% of the budget of each call was earmarked for BCPs, and 20% for 
Labs. In view of this, under both calls the demand for support for BCP equipment was actually a 
little  higher  than  the  supply  (by  14%  and  17%,  respectively),  while  the  demand  for  Lab 
equipment was significantly lower (by 52% and 28%, respectively). In the event, the unneeded 
funding for Labs was re-allocated to meet the demand from BCPs.  

Table 11: Aggregated demand for CCEI co-financing per call 

Available budget for BCPs 

Applied for BCPs by MS 

Available budget for laboratories 

Applied for laboratories by MS 

Available budget – Total  

Applied for by MS – Total  

Amounts available and applied for (EUR ) 

First call (2021-2022) 

Second call (2023-2024) 

217,211,200 

247,193,266 

54,302,800 

26,282,097 

271,514,000 

273,475,363 

227,170,400 

266,382,600 

56,792,600 

40,726,128 

283,963,000 

307,108,728 

Reasons that encourage or hinder MS use of CCEI 

In  their  questionnaire  responses  and  during  interviews,  the  vast  majority  of  national  customs 
administrations emphasised their conviction that there is a clear need to ensure all MS have the 
equipment needed to ensure adequate and equivalent results of customs controls throughout the 
Customs  Union,  and  that  the  objectives  and  priorities  of  the  CCEI  were  and  continue  to  be 
relevant (for further details see EQs 8 and 9 below). Thus, the main reason that encourages MS’ 
use  of  the  instrument  is  their  desire  to  obtain  financial  support  that  enables  them  to  procure 
additional and/or upgrade existing equipment, and thereby to enhance the performance of their 
BCPs and/or customs laboratories.  

At the same time, MS took different approaches to their applications, and this is reflected in the 
amount  of  co-financing  they  requested.  In  response  to  the  first  call,  some  submitted  highly 
ambitious  projects  that  clearly  went  above  and  beyond  what  they  would  have  been  able  to 
procure  without  CCEI  support.  In  at  least  one  case,  this  was  done  in  the  expectation  that  they 
were unlikely to be awarded co-financing for all of the equipment included in their applications 
(which turned out to be false due to the limited aggregate demand). Other MS opted for a more 
cautious approach; for various reasons, including a lack of familiarity with the instrument, and 
uncertainty about their ability to secure national funds beyond what had already been approved 
for existing plans to purchase customs control equipment, they chose to only apply for relatively 
small  amounts  of  EU  co-financing.  However,  in  several  cases  (e.g.  Germany,  Czechia, 
Luxembourg), MS became more proactive and ambitious in the second call, applying for higher 
amounts  for  more  expensive  equipment  that,  according  to  interviewees,  would  have  been 
challenging to finance solely through national budgets. On the other hand, it appears likely that 
difficulties and/or delays encountered in projects under the first call appear to have led some MS 
(e.g.  Cyprus,  Slovenia)  to  scale  back  their  ambitions  under  the  second  call,  or  even  not 
participate at all.  

77 

 
 
The three MS that did not participate in the first call provided broadly similar reasons for this – 
namely, a lack of preparedness within the customs administration to deal with the requirements 
of  preparing  and  submitting  a  proposal  within  the  time  available,  and/or  the  absence  of  a 
comprehensive  needs  assessment  that  could  be  used  to  determine  what  additional  equipment 
should  be  procured.  In  one  case  (Denmark),  there  was  reportedly  also  a  sense  within  the 
administration  that  the  country  did  not  really  need  additional  resources  for  customs  control 
equipment.  As  noted  above,  all  three  MS  did  engage  with  the  second  call,  based  on  a  more 
detailed understanding of their needs and gaps that they had developed in the meantime, and/or a 
re-assessment of their priorities. 

The two MS that did not participate in the second call did so because of the significant delays in 
procuring and installing equipment from the first call, which led them to decide they lacked the 
internal resources to embark on additional projects for the time being. 

Summary response 

The CCEI has now been / is being used by all 27 MS, which confirms it is seen as a valuable and 
relevant instrument by customs administrations across the EU. On the other hand, the fact that 
the level of demand under both calls to date has been relatively low (only marginally higher than 
the  available  budget)  shows  that  the  absorption  capacity  of  MS  is  not  unlimited.  The  main 
factors that hinder the more intensive use of the CCEI relate to (1) the ability to secure sufficient 
national co-funding, in particular for (more expensive / innovative) equipment that is not covered 
by  “business  as  usual”  purchase,  upgrade  and  replacement  strategies  and  plans,  and  (2)  the 
challenges, difficulties and delays experienced with national procurement procedures, which can 
make  MS  reluctant  to  be  more  ambitious  and/or  faster  in  their  endeavours  to  add  to  and 
modernise their equipment.  

EQ 4. What factors are limiting the use of the CCEI data model and what is necessary to use it 
to its full potential? 

The  CCEI  data  model  was  designed  to  facilitate  the  implementation  of  the  Instrument.  This 
section focuses on the hindering factors which have limited the ability of the CCEI data model to 
be  fully  leveraged  by  DG  TAXUD.  In  line  with  the  CCEI  Regulation,  the  data  model  was 
designed  to  serve  two  key  functions.  The  first  was  to  identify  CCE  gaps  and  needs  and 
concomitantly  to  target  CCEI funding in  line with  recital  24. Another key function of the data 
model is to support the monitoring of the Instrument.  

However,  the  extent  to  which  the  data  model  was  used  to  steer  CCEI  funding  is  difficult  to 
assess. While it does seem that, on occasion, the model was used to target funding the gathered 
evidence  remains  sparse  and  anecdotal.  Given  the  lack  of  material  over-subscription  to  the 
Instrument during the first but also second call, it seems that there was no pressing need exerted 
on DG TAXUD to target funding as there was enough CCEI funding to meet all the (CCE) needs 
identified by customs authorities.  

Beyond the lack of competing pressure on the CCEI funding pot, four key limiting factors were 
identified  preventing  the  overall  effectiveness  of  the  model.  Overall,  these  factors  can  be 
classified in two broad categories: (i) factors that are external (i.e. exogenous) to the model and 
therefore not within DG TAXUD’s direct sphere of control and (ii) factors that are internal (i.e. 
endogenous) and linked to the design of the model. These limiting factors are set out below at a 
high level and subsequently analysed in more detail in the ensuing section. 

Exogenous factors:  

•  Administrative burden  

78 

 
•  Lack of understanding and buy-in from customs authorities  

•  Poor data completeness and accuracy 

Endogenous factor:  

•  Dynamic and unpredictable nature of customs threats (risk-based approach)  

The  analysis  below  discusses  the  above  factors  in  more  detail.  The  judgement  criteria  are 
substantively addressed in the overall summary response provided at the end of this section.  

Administrative burden  

One of the key issues linked to the implementation of the data model has been the administrative 
burden  it  has  created  on  customs  authorities.  Indeed,  interview  feedback  have  consistently 
highlighted  that  a  recurring  issue  for  many  customs  authorities  at  application  stage  was  filling 
out the data collection sheets to feed into the data model. More specifically, interview feedback 
from  most  customs  authorities  suggests  that  this  process  involved  duplicating  existing 
information and/or required significant manual effort, diverting resources from core operational 
tasks. In addition, at a technical level, several customs authorities noted that completing the data 
tables  was  not  only  time-consuming  but  also  not  aligned  with  national  procedures  and 
frameworks.  In  practice,  this  meant  that  some  of  the  requested  information  was  not  readily 
available  from  existing  national  and  regional  databases  and  that  additional  and  novel  data 
collection was needed. 

Linked to the above, several authorities also reported resource constrains as further compounding 
the administrative burden created by the data model. For example, the data requirements linked 
to  the  model  led  to  a  heavy  workload  placed,  in  some  cases,  on  a  single  customs  coordinator 
without  dedicated  staff.  Overall,  while  all  interviewed  parties  expressed  a  generally  positive 
view  of  the  CCEI  and  praised  the  support  from  CCEI  personnel  at  the  Commission,  the 
application  process  received  more  criticism  than  praise  primarily  linked  to  the  administrative 
burden it involved, to which the information requirements linked to the data model contributed 
significantly.  

In  addition,  reporting  requirements,  which  are  also  important  for  the  effective  (continued) 
implementation of the data model, also seem to have contributed to the sustained burden across 
several CCEI projects. Several interviewees reported that the Excel component of reporting was 
perceived as burdensome to  collect  information  for and to complete. Several  delays have been 
witnessed in the submission of annual progress reports by grant recipients.  Receiving data in a 
timely manner has not been the case thus far for a large number of projects.  

Last, the lack of centralisation of data collection within some MS and the diverging frameworks 
between some MS have also been a driver of the administrative burden linked to the CCEI’s data 
model. Indeed, several MS’s customs authorities rely on their regional offices to provide the data 
needed for the model and lack a centralised database from which data could be extracted more 
seamlessly. As a result, as reported by several interviewees significant burden was put on CCEI 
project  coordinators  (sometimes  with  limited  resources  themselves  as  outlined  above)  as  they 
had to disseminate and coordinate inputs from several regional customs offices and hubs, which 
in turn contributed to the patchy data gathered at application stage and the timeliness of reporting 
during the implementation stage.  

Lack of understanding and buy-in from customs authority 

Another  key  issue  that  emerged  from  the  research  lies  in  the  lack  of  understanding  linked  to 
some  components  of  the  data  model.  More  specifically,  a  lack  of  understanding  regarding  the 
definitions and classifications of CCE was reported by several CCEI beneficiaries. For instance, 
the list of eligible equipment for customs labs was described as having caused some confusion 

79 

 
by  the  Austrian  customs  authority  despite  alignment  efforts  conducted  as  part  of  the  CCEI 
Coordination Group. In addition, several customs authorities reported that the spreadsheets (Part 
B of the application template) were not user-friendly and difficult to navigate.  

A further issue was a lack of understanding on the part of some MS regarding the metrics and 
indicators  embedded  within  the  data  model.  Specifically,  several  customs  authorities  reported 
these are unclear, ill-defined and open to interpretation. In addition, the risk categorisation and 
ranking  was  also  reported  by  some  customs  authorities  as  not  having  been  clear  and  easy  to 
make sense of, therefore suggesting that a degree of erroneous inputting may be present and that 
the results from the risk model may not be completely reflective of the risk levels at BCPs and 
Labs.  

Moreover,  though  not  applicable  to  all  MS,  for  some  there  also  seems  to  be  a  lack  of 
understanding  of  what  role  and  purpose  the  data  model  serves.  This  became  evident  during 
discussions held during the validation workshop, which revealed that beyond the administrative 
burden required to operationalise the data model, there was a lack of understanding among some 
customs authority representatives on what the model was used for. It seems reasonable to assume 
that this lack of understanding and therefore buy-in from customs authorities may have led to a 
sub-optimal  engagement  with  the  data  model  and  further  exacerbated  the  issues  linked  to 
administrative capacity set out above.  

Poor data completeness and accuracy 

As a result of the above issues, there have been inconsistent and poor levels of completeness and 
quality  of  the  data  received  by  DG  TAXUD  to  operationalise  the  data  model.  This  was  the 
fundamental  hurdle  by  far  to  successfully  implementing  and  leveraging  the  data  model  as 
envisaged. The review of the applications submitted for the case study projects aligns with the 
feedback from customs authorities in terms of the difficulty in providing complete and accurate 
data. 

The  10  grant  agreements  selected  as  part  of  the  case  studies  were  reviewed  with  a  view  to 
informing an assessment of data completeness and quality at proposal stage. While this review is 
not  systematic,  it  does  provide  some  insights  as  to  what  types  of  data  have  been  proving 
particularly problematic to collect. In addition, it should be noted that it is difficult to assess the 
quality of the data using objective means in the absence of audits of BCPs and labs. Therefore, 
interview  feedback  was  used  to  assess  this  aspect,  and  triangulating  feedback  from  both  DG 
TAXUD and the beneficiaries allows for a somewhat balanced assessment.  

Table 12: Assessment of the data quality and completeness gathered at application stage  

Type of data  

Excel Sheet #   RAG rating  

Overview of data completeness and quality  

Inventory data 

3 

High 

Overall, this was found to be fairly exhaustive in the reviewed 
applications. Breakdowns at BCP and lab-level were consistently 
provided.  

In terms of accuracy, feedback from customs authorities also confirmed 
that the mapping they provided is on the whole comprehensive and 
reflective of the situation on the ground at BCPs and labs.  

Traffic data 

Risk assessment 

4 

5 

Low  

Overall, several datapoints were not reported in the reviewed 
applications. This includes traffic volumes at several BCPs.  

The feedback gathered on quality was mixed.  

Low  

As for traffic data, the data reported by customs authorities was found to 
be inconsistent in terms of completeness across the 10 applications 
reviewed. More specially, risk ratings were left blank for several risk 

80 

 
Type of data  

Excel Sheet #   RAG rating  

Overview of data completeness and quality  

categories and BCPs.  

In terms of quality, as noted further down in this section, the ranking of 
threats suffers from important limitations linked to the dynamic nature of 
customs threats. In addition, interview feedback suggests that some CCEI 
applicants may not have fully understood the framework for the risk 
assessment, which may have had an impact on the quality of the inputted 
data.  

Dynamic and unpredictable nature of customs threats (risk-based approach) 

In  addition,  there  are  intrinsic  limitations  with  the  risk  assessment  linked  to  the  dynamic  and 
unpredictable  nature  of  customs  threats.  Several  customs  authorities  reported  that  carrying  out 
the risk assessment (i.e. identifying and ranking the risks on sheet 5) was challenging because of 
the dynamic nature of threats faced at BCPs. Recent changes in geopolitics have highlighted the 
shifting  nature  of  trade  flows.  For  example,  the  sanctions  imposed  on  Russia  and  the 
humanitarian  and  military  aid  being  channelled  to  Ukraine  have  changed  the  nature  of  goods 
transiting  via  certain  areas  of  the  EU’s  external  border.  Another  example  of  this  is  the 
humanitarian corridor put in place to provide aid to Gaza following Israel’s special operation in 
October  2023.  Linked  to  this,  Cyprus’  customs  authority  reported  that  their  customs  needs 
changed as there was an increase in sea-borne cargo at their BCPs, which led in turn to a change 
in  their  CCE  needs,  and  which  itself  led  to  an  amendment  request  being  made  to  their  CCEI 
grant agreement.  

As  such,  there  may  be  a  need  to  complement  the  risk-based  approach  underpinning  the  data 
model  by  embracing  a  more  standardised  coverage  of  equipment  for  some  BCPs.  This  could 
allow the data model and underlying logic to aim for more well-rounded BCPs with a versatile 
set  of  equipment  to  allow  customs  authorities  to  be  better  positioned  to  respond  to  unknown 
threats swiftly.  

Summary response  

Data quality, reliability and completeness is  found to be low for major parts of the data model 
(see also EQ 7). Overall, the evidence suggests that the data model has not been fully leveraged 
thus far in the implementation of the Instrument. This is due to a combination of endogenous and 
exogenous factors, not least the lack of adequate data required to operationalise the model by DG 
TAXUD. With respect to the extent to which the data model has been used to target funding, the 
evidence  is  scant.  However,  regarding  the  extent  to  which  the  data  model  has  allowed  DG 
TAXUD to acquire a better understanding of Customs Union needs, arguably the implementation 
of the data model via the CCEI can be seen as a step in the right direction. As outlined above, the 
inventory data appears to  be robust and has provided DG TAXUD with  a first  mapping of the 
inventory  of  CCE  at  national  and  regional  level.  No  such  mapping  exercise  had  ever  been 
conducted before the CCEI. Despite the reported and discussed issues with the rest  of the data, 
the  inventory  data  alongside  this  first  data  collection  effort  by  DG  TAXUD  and  customs 
authorities appears to be a step in the right direction towards more standardised data collection 
and  reporting  practices  across  the  EU-27.  Looking  ahead,  however,  there  may  be  a  need  for 
simplification (see response to EQ 7) and adopting more user-friendly tools to further facilitate 
data collection and to make the CCEI data model more fit for its purpose. 

81 

 
 
 
Efficiency 

As  per  the  Better  Regulation  Guidelines,  the  efficiency  evaluation  criterion  is  concerned  with 
assessing  the  extent  to  which  European  interventions  provide  value-for-money  and  make  the 
most optimal use of EU funding. In the case of the CCEI interim evaluation, as noted previously, 
it  is  too  early  to  comprehensively  and  robustly  assess  the  benefits,  much  less  to  attempt  to 
quantify  and  express  these  in  monetary  terms  (which  would  be  needed  for  a  full  cost-benefit 
analysis).  Instead,  the  focus  of  the  assessment  of  efficiency  focuses  mostly  on  the  CCEI’s 
operational efficiency; that is how efficiently the different components and stages of the process 
and  overall  implementation  framework  have  been  delivered  to  date.  Nevertheless,  in  order  to 
provide  some  degree  of  quantification,  estimates  of  the  administrative  burden  placed  by  the 
CCEI on its beneficiaries are also provided (see EQ 6).  

As  per  the  evaluation  matrix  below,  the  ensuing  analysis  assesses  the  extent  to  which  the 
processes  through  which  the  CCEI  have  been  implemented  and  managed  have  been  efficient, 
drawing  on  stakeholder  feedback  primarily,  and  monitoring  data  to  a  lesser  extent  (EQ  5).  As 
noted above, the analysis also aims to estimate the direct costs incurred by customs authorities 
taking part in the CCEI and whether these are justified in light of the results achieved thus far but 
also those expected to be achieved in the more medium term (EQ 6). Last, the analysis considers 
potential avenues for simplification, mostly related to the data model and reporting requirements 
as  these  two  interrelated  elements  have  been  identified  as  being  the  main  drivers  of  the 
administrative burden linked to the Instrument.  

Table 13: Evaluation matrix for Efficiency 

Evaluation questions 

Judgment criteria 

Indicators 

Data sources 

5. To what extent is the 
framework for managing and 
implementing the instrument 
efficient in order to achieve its 
objectives? 

Extent to which MS are 
satisfied with the 
framework for managing 
and implementing the 
CCEI 

Extent to which 
procedural and 
management tasks are 
carried out in a timely 
manner 

Satisfaction of customs administrations 
with the efficiency of the implementation 
process (OP 1.3) 

Stakeholder feedback on the efficiency of 
specific CCEI processes and tools (incl. 
priority-setting and programming; 
submitting and evaluating applications; 
contracting, grant management and 
amendment, and payments; reporting, data 
management, monitoring and evaluation) 

•  CCEI monitoring 

data 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

Examples of inefficiencies and their root 
causes encountered on specific CCEI 
projects 

• 

In-depth case 
studies 

Avg. time to inform, time to signature, and 
time to grant  

•  CCEI monitoring 

data  

Stakeholder feedback on the timeliness of 
specific CCEI processes and tools (as 
above) 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

•  Workshop 

Examples of delays and their root causes 
encountered on specific CCEI projects 

• 

In-depth case 
studies 

6. To what extent are the costs 
(incl. direct & indirect costs, e.g. 
administrative burden) of the 
intervention justified, given the 
effects it has achieved? Could the 
intervention have been done in a 
more efficient way and if so, 

Extent to which the costs 
of implementing the 
CCEI are proportionate 
to the benefits achieved 
(cp. EQ 1 above) 

Direct financial costs (CCEI grants 
awarded) 

Direct compliance costs, in particular 
administrative costs linked to application, 
grant management and reporting processes 

•  CCEI monitoring 

data 

•  MS questionnaire 

responses 

• 

Stakeholder 
interviews 

82 

 
Evaluation questions 

Judgment criteria 

Indicators 

how? 

7. What is the simplification 
potential of the intervention? 
How could procedures be 
optimised? How can the 
monitoring and reporting be 
improved? 

Extent to which aspects 
of the CCEI framework 
and processes that imply 
unnecessary / unjustified 
complexity, costs, 
burdens and/or delays 
could be improved 

Indirect costs (if any), such as potentially 
transaction (e.g. as a result of having to re-
negotiate contracts with existing suppliers 
of CCE) or opportunity costs 

Suggestions from national customs 
authorities and other stakeholders for 
further improvements and simplifications 

Assessment of the likely benefits and 
drawbacks of potential changes (drawing, 
where possible, on experiences of similar 
programmes / instruments) 

Data sources 

• 

In-depth case 
studies 

•  MS questionnaire 

• 

• 

responses 

Stakeholder 
interviews 

In-depth case 
studies 

•  MS questionnaire 

• 

• 

responses 

Stakeholder 
interviews 

In-depth case 
studies 

•  Document 
review 

• 

Stakeholder 
interviews 

•  Workshop 

EQ 5. To what extent is the framework for managing and implementing the instrument efficient 
in order to achieve its objectives? 

To assess this evaluation question, the analysis focuses first (i) on the framework and processes 
used  to  deliver  the  CCEI,  incl.  the  application  stage,  grant  signing  and  amendment  process, 
reporting mechanisms and overall delivery of the Instrument. Second (ii), the analysis looks into 
the envisaged and actual timescales for the implementation of the Instrument and, in particular, 
the delays that have been accrued since the CCEI has been launched.  

Extent to which MS are satisfied with the framework for managing and implementing the CCEI 

Overall, the majority of customs authorities (i.e. CCEI beneficiaries) have been pleased with the 
way  the  Instrument  has  been  managed.  More  specifically,  the  majority  of  respondents  to  the 
questionnaire reported that the guidance provided by DG TAXUD to participate in the CCEI was 
sufficiently clear, with 52% strongly agreeing and 39% tending to agree (see figure below). No 
respondent reported disagreeing with the statement that the ‘guidance was clear and useful’. This 
was  also  further  confirmed  by  interview  feedback  where  several  customs  authorities  reported 
that  beyond  the  guidance  provided  by  DG  TAXUD,  the  communication  and  ad-hoc  support 
provided  by  the  Commission  was  particularly  well  appreciated.  Moreover,  several  interviewed 
customs authorities stated that plenty of notice was given to customs authorities to ensure they 
were ready to respond to CCEI calls in time.  

The  process  for  managing  /  delivering  the  CCEI  is  examined  in  more  detail  below  via  a 
procedural lens. 

While the outputs of the priority setting process were reported as broadly aligned with customs 
authorities’  needs,  the  process  through  which  these  were  defined  seemed  to  have  generated 
mixed  sentiment  in  terms  of  the  extent  to  which  it  took  into  account  the  needs  of  customs 
administrations.  Indeed,  data  collected  by  the  questionnaire  revealed  that  39%  of  respondents 
thought  the  process  took  their  needs  into  account,  while  another  39%  indicated  that  they  only 
tended  to  agree  with  this  statement.  Also  worth  noting,  the  CCEI  Coordination  Group,  i.e.  the 
forum via which inter alia CCEI priorities were set also generated slightly less positive feedback, 
with  55%  of  respondents  tending  to  agree  with  the  statement  the  Coordination  Group  is  an 

83 

 
effective  forum  for  collaboration.  The  figure  below  provides  an  overview  of  the  views  and 
perspectives shared by customs authorities on the key elements associated with the process and 
framework to deliver the Instrument.  

Figure  16:  Please  consider  your  level  of  agreement  with  the  following  statements  of  the 
management structure and processes of the CCEI  

Source: Questionnaire responses from national customs administrations 

Second, with respect to the CCEI’s application process, proposals were evaluated via a three-step 
process as follows:  

1. Individual evaluations by assessors; 

2. Consensus meetings with three evaluators and a moderator; and 

3. Final panel meeting involving DG TAXUD to ensure consistent application of the rules, 
with some flexibility for score adjustments subject to agreement of the evaluation committee.  

Overall,  evaluators  from  other  Commission  services  and  the  CCEI  beneficiaries  described  the 
process as working well from a procedural perspective. However, a number of issues linked to 
the assessment process were nevertheless noted: 

•  Exclusion  of  infrastructure  costs:  it  was  reported  by  stakeholders  involved  in  the 
assessment  process  that  a  key  challenge  was  distinguishing  between  the  infrastructure 
component  and  the  equipment,  especially  in  cases  like  high-energy  scanners.  The 
separation between these two categories is not always clear-cut, as they often overlap in 
terms of function and procurement needs. Additionally, it was also reported that a lack of 
adequate guidance further compounded this issue.  

•  Assessment of Lab proposals: some stakeholders involved in the assessment process also 
noted  that  the  highly  specific  and  technical  nature  of  these  proposals  was  challenging, 
requiring expertise beyond the assessor’s expertise in some cases. 

•  Length of the assessment process: While some customs officials reported that the time to 
review  applications  was  lengthy  on  occasion,  they  also  conceded  that  it  was 
understandable that CCEI assessors needed time  to  review  applications, particularly  for 

84 

 
 
large-scale projects involving a large number and type of instrument as well as significant 
EU  funding  (see  next  sub-section  for  a  more  detailed  analysis  of  timescales  for  the 
application process).  

Despite the relatively positive views on the application process from a procedural perspective, a 
majority  of  stakeholders  reported  being  dissatisfied  with  the  significant  administrative  burden 
linked to the preparation and submission of CCEI applications. As one stakeholder noted: “From 
what we’ve learned from other countries, the reporting process can be quite challenging. If we 
find  that  we’re  going  to  spend  too  much  time  on  that,  we  may  reconsider  participating  again, 
especially given our limited budget. This experience is important for us to evaluate whether we 
want  to  stay  involved  in  the  future.”  This  issue  is  further  discussed  under  the  next  evaluation 
question (EQ 6) and under EQ 4 on the data model.  

Concerning  the  amendment  process,  as  was  shown  in  the  case  studies,  a  large  number  of 
amendments  were  requested  by  grant  recipients  concerning  both  the  duration  of  their  projects 
and  the  equipment  in  scope.  The  majority  of  amendments  involve  requesting  extensions  to 
project durations which pushes out the project completion date to 2026 or 2027.  

This amendment process was reported to be lengthy by some stakeholders, however, for the most 
part the delays seemed to have originated at the national level rather than at the European level. 
Overall, the majority of interviewed customs authorities reported having been satisfied with the 
flexibility  provided  by  the  amendment  process  notwithstanding  the  protracted  nature  of  the 
process in some cases.  

Last, with respect to the reporting process, similar to the application process and as mentioned 
under EQ 4, there have in some cases been significant delays in submitting progress reports (this 
is  evidenced in  the case studies). While the key driver of this is  the administrative burden and 
lack of capacity within customs authorities, this is further exacerbated by the (perceived) lack of 
rigid and binding rules linked to reporting requirements. Indeed, although in principle, customs 
authorities are obliged to submit reports annually throughout the duration of their projects, there 
are  no  direct  consequences  for  them  if  they  fail  to  do  so.  The  only  report  that  is  linked  to  a 
payment is the final report that has to be submitted at project completion.  While it is clear that 
the lack of capacity and high burden associated with data collection are the main obstacles, the 
lack of stricter measures may have also contributed to a lesser degree of efficiency with regard to 
the timely and adequate collection of reporting data needed to monitor the CCEI.   

Extent to which procedural and management tasks are carried out in a timely manner 

While some customs authorities reported that the time taken to review applications was lengthy 
on some occasions, overall the time taken was under the maximum amount of foreseen. Under 
the first call, the average "time to inform" (TTI) – the time taken to notify beneficiaries about the 
outcome of their proposal – was 125 days after the Call closing date. This is 58 days ahead of 
DG TAXUD’s target. Furthermore, the average “time to sign” was 124 days, while the average 
"time to grant" (TTG) was 251 days from the call closing, which is 24 days before the target. 

The  second  call,  similarly  to  the  first  one,  proceeded  mostly  on  schedule,  albeit  with  some 
delays.  More  specifically,  the  average  "time  to  inform"  (TTI)  was  124  days  after  the  second 
call’s closing date, 59 days ahead of the DG TAXUD target. The average "time to sign" (TTS) 
was  133  days,  not  taking  into  account  four  grants  that  experienced  some  additional  delays  for 
various reasons outside the control of DG TAXUD. The average "time to grant" (TTG) was 257 
days from the call closing, 18 days ahead of the target – also without the above mentioned four 
grants.  

With  respect  to  the  effective  implementation  of  CCEI  projects,  overall,  the  CCEI  has  suffered 
from important delays in both of its first calls. However, most of these delays have been driven 

85 

 
by issues at the national level, particularly public procurement as noted under EQ 1. The ensuing 
analysis provides further insights into the timescales to date drawing on the metrics listed in the 
evaluation matrix for this criterion.  

In  the  first  call  project  durations  initially  set  at  the  time  of  signature  ranged  from  12  to  36 
months. However, significant delays have been witnessed in several first call projects which led 
to amendments of twenty grants extending their durations by up to 30 months. As of May 2025, 
13  projects—perhaps  not  coincidentally,  including  the  five  smallest  grants—have  been 
completed. Most of the remaining projects (14) are now expected to finish in 2025, while 11 are 
projected to conclude in 2026 and four in 2027.   

In the second call, the maximum project duration was also 36 months.  18 grants started by the 
end of 2024, while the remaining are set to start in 2025.  

Summary response  

The  framework  for  managing  and  implementing  the  CCEI  has  been  generally  efficient,  with 
most customs authorities satisfied with  the guidance, communication, and support provided by 
DG TAXUD. Over 90% of beneficiaries found the guidance clear and useful, and the application 
evaluation process was viewed as procedurally effective. However, some concerns were raised, 
particularly the high administrative burden of preparing applications. 

While the amendment process was appreciated for its flexibility, it was often lengthy, primarily 
due  to  delays  at  the  national  level.  Reporting  delays  were  also  significant,  driven  by 
administrative burdens and limited capacity within customs authorities, exacerbated by reporting 
requirements during projects that were not perceived as binding by all beneficiaries. Timeliness 
in  procedural  tasks,  such  as  application  reviews  and  grant  approvals,  were  generally  under  the 
defined  targets,  though  some  delays  were  noted  in  the  second  call.  Project  implementation, 
however, has been facing substantial delays, with many first-call projects requiring extensions of 
6  to  14  months,  pushing  completion  dates  to  2025–2027,  largely  due  to  national-level 
procurement issues. 

Overall,  the  CCEI’s  management  framework  has  been  effective,  but  challenges  such  as 
administrative  burdens,  reporting  delays,  and  national-level  inefficiencies  need  addressing  to 
enhance efficiency further. Streamlining processes and reducing administrative complexity could 
strengthen the framework and better achieve the CCEI’s objectives. The scope for simplification 
is addressed under EQ 7.  

EQ 6. To what extent are the costs (incl. direct & indirect costs, e.g. administrative burden) of 
the  intervention  justified,  given  the  effects  it  has  achieved?  Could  the  intervention  have  been 
done in a more efficient way and if so, how? 

This  question  is  concerned  with  the  costs  linked  to  the  intervention  and  whether  these  are 
justified in light of the results achieved. To answer this, the analysis considers the (i) total CCEI 
funding allocated, (ii) the administrative costs linked to the CCEI, and last (iii) perceptions from 
stakeholders on whether the costs and overall burden are justified. 

CCEI funding allocated 

The total funding allocated to first call projects was  EUR 273.5 million. Regarding the second 
call, the full EUR 283.9 million have been allocated. In total, to date the CCEI has been endowed 
with EUR 557.4 million of EU funding.  

For the first call alone over 1,300 pieces of equipment are expected to be purchased and installed 
with the support of CCEI funding for BCPs. Additionally, another 500 pieces of equipment are 
also funded for customs Labs. This represents a total of over 1,800 pieces of equipment. The cost 

86 

 
of an equipment item ranges from a few thousand euro (e.g. sniffer dog) to several millions (e.g. 
high  energy  X-ray).  The  average  cost  per  item  is  EUR  151,944.  At  a  more  granular  level,  for 
BCPs the average cost would be EUR 190,153, and for Labs EUR 52,400. These unit costs are 
for CCE under the first call. Given the lack of data on the definitive number of equipment to be 
provided under the second call, it is not possible at this stage to provide an estimate of the unit 
cost taking into account second call equipment.  

Administrative costs 

This  EQ  is  also  concerned  with  the  administrative  costs  incurred  by  customs  authorities  who 
have participated to the CCEI. As per the EU Standard Cost Model (SCM), to calculate the total 
administrative costs both direct and indirect costs should be considered. However, in the case of 
the CCEI assessing – let alone quantifying – indirect costs is highly challenging due to, in large 
part, the paucity of data, e.g. on training costs etc. As such, this section only focuses on direct 
costs, relying on staff time drawing on primary data collected as part of the questionnaire.  

The  responses  to  the  questionnaire  allowed  for  the  quantification  of  the  amount  of  time 
(expressed in staff days) needed to participate to the CCEI. The number of staff days required to 
handle CCEI tasks varied widely among MS given the variety of the team’s composition dealing 
with  CCEI  tasks,  as  well  as  the  different  sizes  of  grants.  In  total,  respondents  from  national 
customs authorities estimated that they had spent an average of just under 119 staff days per year 
on  tasks  related  to  their  participation  in  the  CCEI.  Within  this,  the  two  most  time-intensive 
activities  are  managing  an  active  CCEI  grant,  which  requires  an  average  of  69  staff  days 
annually, and preparing a CCEI grant application, which takes approximately 40 days. Looking 
in more detail, the wide gap between answers becomes visible, with some authorities indicating 
less than 10 staff days per year to  manage an  active grant,  while others indicated it to  be over 
100 staff days or a full-time job. However, it should be noted that, for each task, a majority of 
respondents  responded,  but  non-respondents  are  between  26%  and  42%,  including  irregular, 
where  Member  States  responded  to  some  tasks  but  not  for  others.31  This  is  an  important 
limitation to keep in mind when interpreting the estimates.  

To  monetise  the  administrative  burden,  the  analysis  draws  on  Eurostat  data  on  the  average 
remuneration  of  national  civil  servants  in  central  public  administrations32.  In  2024,  when  the 
questionnaire was disseminated and the responses collected, the average salary for civil servants 
at  EU-level  was  EUR  3,170  per  month33.  However,  it  should  be  noted  that  this  is  an  average 
which  does  not  take  into  the  account  regional  differences  in  remuneration  across  the  EU. 
Moreover,  while  customs  personnel  may  be  considered  to  fall  into  this  occupational  category, 
there is likely to be a degree of variation within this group (and within the staff who have been 
involved in the management of the CCEI) in terms of remuneration based on tenure, role, level 
of expertise and other factors.  

Nevertheless, working with the following assumptions based on the SCM: 

•  1 working day: 8 working hours  

•  1 working month: 20 working days 

•  Total working hours per month: (20 days) × (8 hours) = 160 hours 

31 Malta and France (France only partly) provided explicitly irregular responses, meaning that they specified to use a 

different metric, we exclude them from the average.  

32 Dataset: prc_rem_avg.  

33 https://ec.europa.eu/eurostat/databrowser/view/prc_rem_avg/default/table?lang=en.  

87 

 
 
• 

(Average) customs personnel hourly wage = (monthly salary) / (total working hours per 
month) = EUR 3,170 / 160 = EUR 19.81 per hour 

With the above, the costs per MS linked to taking part in the CCEI can be estimated to be around 
EUR  18,833.76  annually.  To  this,  in  line  with  the  SCM,  overhead  costs  of  20%  should  be 
included, which would increase the amount to EUR 22,598.61. 

In light of this, the total annual administrative cost across all MS (EUR 22,598.61 × 27) can be 
estimated at EUR 610,162.47 per year at the Instrument level. The total administrative cost over 
the lifecycle of the CCEI (i.e. 7 years) can be projected to be approx. EUR 4,271,100.  

The  table  below  provides  an  overview  of  the  average  staff  time  needed  to  deliver  key  tasks 
linked  to  the  delivery  of  the  CCEI  and  their  associated  monetised  direct  costs  drawing  on  the 
same methodology outlined above. It is important to note that the frequency of the different tasks 
can vary – during the period in question (2021-2024), different MS were managing two, one or 
no CCEI grants, and applications obviously did not have to be submitted each year. Therefore, 
the estimated total staff resources per year (last row of the table) are not simply the sum of all the 
activities  listed  previously;  instead,  questionnaire  respondents  were  asked  to  estimate  these 
individually and separately. 

Table 14: Overview and breakdown of average staff days needed to take part in the CCEI (per 
MS and year)  

CCEI activity  

Avg. number of 
staff days  

Direct costs (staff 
time only)  

Direct costs with 
(20%) overhead  

Managing an active CCEI grant (per year and 
per grant) 
Compiling a CCEI grant application, incl. the 
data required for the data model  
Fulfilling reporting obligations for an active 
CCEI grant  
Taking part in the CCEI Coordination Group  
Other tasks  
Total staff resources to take part in and 
manage the CCEI (per year so far on 
average)34*  

68.88 

EUR 10,916.10 

EUR 13,098.22 

39.76 

EUR 6,301.16 

EUR 7,560.86  

15.00 

13.60 
21.20 

EUR 2,377.20 

EUR 2,852.40  

EUR 2,155.33 
EUR 3,359.78 

EUR 2,586.18  
EUR 4,031.39  

118.84 

EUR 18,833.76 

EUR 22,598.61 

Source: Questionnaire responses from national customs administrations 

Customs authorities’ feedback on the administrative burden  

Data from the questionnaire suggest that the majority of customs authorities considered the total 
amount of time dedicated to taking part in the CCEI to be acceptable (65%), while only a small 
minority (10%) thought it was excessive. However, a notable 23% of respondents reported not 
finding the amount of time at application stage to be acceptable. This was also further confirmed 
by interview feedback from customs administrations who noted that the data requirements were 
excessive and burdensome.  

34 Given not all tasks listed are always carried out once per year, the total is not the sum of the previous rows, but 

was put to questionnaire respondents as a separate question.  

88 

 
 
Figure 17: Level of acceptance of the number of staff days on average 

Source: Questionnaire responses from national customs administrations 

Moreover,  survey  data  collected  by  DG  TAXUD  as  part  of  the  monitoring  of  the  Instrument 
shows  that  adherence  to  timelines  set  out  in  the  grant  agreements  while  initially  being  fully 
compliant (100%) in 2022 and 2023 subsequently dropped to 91% in 2024, most likely reflecting 
the  delays  linked  to  public  procurement  discussed  under  effectiveness.  Nevertheless,  the 
overwhelming majority of customs administrations reported being satisfied with the programme 
management and support, which – in contrast to the adherence to deadlines / timelines indicator 
– steadily increased from 96% in 2022 to 100% in 2024 – see figure below.  

Figure 18: Adherence to deadlines/timelines set out in the relevant grant agreements, 2022-2024 

100%

100%

91%

80%

100%

2022

2023

2024

2023 Target

2027 Target

Source: MEF Data 

89 

 
 
 
Figure 19: Satisfaction with the programme management support and guidance provided, 2022-
2024 

96%

97%

100%

70%

70%

2022

2023

2024

2023 Target

2027 Target

Source: MEF Data 

Summary response  

Overall,  the  costs  linked  to  the  CCEI  appear  to  be  largely  justified  given  the  scale  of  funding 
provided to  beneficiaries and the feedback gathered through these same beneficiaries. National 
customs  authorities  reported  spending  an  average  of  119  staff  days  annually  on  CCEI-related 
activities, translating to about EUR 22,600 per authority in administrative costs. This translates 
into approx. EUR 610,000 of administrative costs per year for the 27 MS taken together – which 
is equivalent to less than 0.5% of the annual CCEI budget. A significant proportion of these costs 
were  spent  on  preparing  and  submitting  proposals,  suggesting  that  there  is  scope  for  further 
streamlining this step of the process to reduce lead times and the overall administrative burden. 
The potential for simplification is discussed in the next section (EQ 7). 

EQ  7.  What  is  the  simplification  potential  of  the  intervention?  How  could  procedures  be 
optimised? How can the monitoring and reporting be improved? 

This evaluation question is concerned with the scope for simplification of the CCEI. As set out 
under  EQ  4,  from  a  process  perspective  significant  administrative  costs  are  associated  with 
preparing  and  submitting  a  CCEI  application  and  relatedly  with  fulfilling  data  reporting 
obligations.  Interview  feedback  also  confirms  that  these  two  elements  constitute  the  largest 
driver  of  the  CCEI’s  administrative  burden  on  its  beneficiaries.  At  an  operational  level,  these 
elements are linked to the data model (discussed under EQ 4) and the Monitoring and Evaluation 
Framework (MEF).  

There  are  important  issues  across  several  of  the  MEF  indicators  in  terms  of  their  quality  / 
reliability.  More  specifically,  the  reliability  of  the  data  that  has  been  collected  to  date  was 
assessed  to  be  ‘low’  for  RES  1.1,  RES  1.2,  RES  1.3,  and  ‘medium’  for  RES  1.4  (see  table 
below). The low degree of reliability stems from a number of issues including but not limited to 
incomplete and late reporting, difficulties aggregating data expressed in different units etc.  

Table 15: Overview and assessment of the reliability of MEF indicators  

Indicator  Explanation 

Reliability of 
data 

Explanation 

90 

 
 
Indicator  Explanation 

Reliability of 
data 

Explanation 

OP 1.1 

OP 1.2 

RES 1.1 

Number of equipment items 
requested under the 2021-
2022 CCEI call that have 
been purchased/ 
maintained/ upgraded 

Occupancy rate, that is the 
percentage of how many 
equipment items are used in 
a specific frequency, 
compared to the total items 
that are for that equipment 
category 

Specific results related to 
seizures, controls, and hit 
rates achieved by MS 
through use of CCEI 
funded equipment 

RES 1.3 

Degree of adherence, that is 
the list of equipment that 
should be available per 
BCP/labs depending on the 
risks/threats that they are 
facing and what equipment 
items can address those 
risks/threats. 

High 

High 

Low 

Low 

RES 1.4 

Coverage of risks and 
threats, which is calculated 
taking into account the 
matrix of equipment and 
risks.  

Medium 

91 

Data quality is assessed as high since no particular 
issue was identified. 

Data quality is assessed as high since no particular 
issue was identified. 

Data quality is assessed as low due to significant 
reporting issues and inconsistencies. Out of 4,283 
expected measurements, only 2,483 provided usable 
data after multiple corrective steps, with merely 823 
offering updated figures from the initial baseline. The 
diversity of measurement units (e.g., samples, units, 
EUR , grams, time, percentages) further complicates 
data aggregation and interpretation. Consequently, the 
aggregated figures should be viewed as relative 
indicators rather than absolute values, as they 
effectively combine disparate measurement types 

Data quality is assessed as low due to challenges in the 
three-step calculation process.  

1.  Inventory data collection: MS self-report the 
equipment available at each BCP. This step is 
generally considered representative of the 
situation on the ground. 

2.  Risk assessment: The risks encountered by 

each MS are complex and influenced by a 
variety of factors, such as the type of BCP and 
its geographical location. Conducting a 
comprehensive and reliable risk assessment is 
therefore challenging. This is exacerbated by 
the dynamic nature of risks, where initially 
identified threats may no longer be relevant. 
3.  Equipment recommendations: Targets for 

recommended equipment levels are set for 
each BCP type by considering existing 
equipment and the results of the risk 
assessment. However, targets seem to have 
been set too ambitiously, affecting 
achievability. 

Data quality is assessed as medium. The calculation of 
RES 1.4 is more representative than RES 1.3, as one 
relevant equipment item can cover multiple types of 
seizures/samples and threats. While challenges in risk 
assessment still exist, their impact is less significant 
than for RES 1.3. The main points highlighted for RES 
1.3 are relevant but have a reduced impact on this 
indicator's reliability. 

 
 
Feedback  gathered  from  customs  authorities  has  consistently  underscored  the  difficulty  in 
collecting the wide breadth of datapoints required by the CCEI. This is reflected in the lack of 
data  completeness  and  poor  quality  of  the  data  mentioned  above.  For  example,  57%  of  the 
expected  datapoints  for  RES  1.1  (2,483  out  of  4,283  expected  measurements)  have  been 
provided by customs authorities so far. 

Additionally, a recurring suggestion in the responses to the questionnaire was to streamline the 
grant application process by minimising the requirement for extensive statistical data. This aligns 
with  the  analysis  under  EQ  6  which  highlights  that  a  significant  portion  of  the  administrative 
burden linked to the CCEI is attributable to the application process. At the same time, the actual 
use that has been made of the data so far (for the identification of needs, and for the monitoring 
and evaluation of progress) has been more limited than expected. 

As  such,  the  most  significant  simplification  potential  for  the  CCEI  lies  in  revisiting  the  data 
requirements  for some of the indicators in terms of their scope and level  of granularity, with a 
view  to  prioritising  the  most  critical  data  that  directly  align  with  the  CCEI’s  objectives.  At 
present,  there  is  a  high  level  of  ambition  with  respect  to  the  data  collection  which  could  be 
revisited in light of the issues and shortcoming identified by this evaluation.  

More  practically,  potential  avenues  to  achieve  simplification  in  terms  of  the  reporting  could 
include: 

•  Consider  removing  some  indicators,  particularly  those  that  have  been  proven  to  be 
challenging to collect data for. This may include some of the traffic data (sheet 4), as well 
as  some  of  the  “metrics  to  be  used  to  measure  the  outcome  /  impact  of  the  project”, 
including the targets (sheet 5). With respect to traffic data, some of the indicators, such as 
the number of seizures, can be difficult to interpret as they do not always directly reflect 
whether customs controls are more effective.  

•  Consider streamlining the framework, particularly the risk assessment. At present, there 
are  a  large  number  of  individual  threats  to  assess  and  rank  in  the  application  and 
reporting  forms.  The  drawback  from  this  would  be  that  a  less  detailed  risk  assessment 
would be achieved, potentially not capturing as many threats. However, given the lack of 
consistent  and  exhausting  ranking  of  threats,  a  ‘simplified’  risk  assessment  is  arguably 
likely to lead to more comprehensive and higher quality risk assessments in future.  

Other  alternatives  for  simplification  could  be  considered  beyond  revisiting  the  reporting 
requirements  and  the  overall  monitoring  framework.  For  example,  more  innovative  measures 
could be used to facilitate data collection. This would include dedicating some CCEI funding to 
support  software  and  other  IT  tools  to  help  automate  the  process  of  data  collection  and 
centralisation, which could then feed into the CCEI’s MEF. Another potential for simplification 
is transitioning to a more user-friendly data collection tool potentially hosted on a secure online 
platform where data could be inputted in real time to encourage for more regular reporting.  

These possibilities for simplification should be explored as part of the CCEI Coordination Group 
in  order  to  ensure  that  any  simplification  measure  is  deemed  useful  and  understood  by  CCEI 
beneficiaries. 

92 

 
 
 
Relevance 

Table 16: Evaluation matrix for Relevance  

Evaluation questions 

Judgment criteria 

Indicators 

Data sources 

8. To what extent have the 
objectives, scope and design of 
CCEI remained relevant, 
considering evolving EU needs 
and priorities in the field of 
customs?   

Extent to which CCEI is 
aligned with relevant EU 
policy and priorities in 
the field of customs 

Extent to which CCEI 
has adapted to new and 
emerging EU policies, 
priorities  

9. To what extent do stakeholders 
support the CCEI? 

Extent to which 
stakeholders are 
favourable towards the 
objectives and design of 
CCEI 

Extent to which CCEI 
meets stakeholder needs 

10. To what extent has CCEI 
been able to adapt to 
developments in technology and 
the wider geopolitical and 
policy context beyond customs? 

Extent to which CCEI is 
able to adapt to key 
contextual changes and 
new challenges 
concerning customs 
control equipment  

Alignment between CCEI’s objectives and 
EU customs policies and priorities 
Alignment between the design of CCEI and 
EU customs policies and priorities  
Stakeholder views on whether CCEI’s 
objectives and design respond to EU policy 
needs and priorities in the field of customs 

Alignment between CCEI planning 
documents (e.g. MAWPs) with newly 
published customs policies and priorities 
(e.g. 2023 Customs Reform proposal, 
Roadmap to fight Drug Trafficking and 
Organised Crime) 
Stakeholder views on whether CCEI has 
successfully adapted to evolving EU 
policies and priorities  

Proportion of MS customs authorities 
agreeing that CCEI is (1) necessary, and 
(2) appropriately designed 
Views of MS customs authorities on 
specific aspects of the CCEI objectives and 
design 
Level of MS interest in participating in 
CCEI 

Alignment between CCEI objectives and 
planning documents with documentary 
evidence of MS needs (to the extent 
available, e.g. on national customs 
websites)  
Credibility / suitability of the needs 
assessments and related analysis done in the 
frame of CCEI 
Stakeholder views on the suitability of the 
needs assessment process  
Views of MS customs authorities on 
whether CCEI meets their specific needs 
Requests for additions to the list of eligible 
equipment and outcomes of these  

•  Document review 

• 

Stakeholder 
interviews with EU 
officials  

•  Workshop 

•  Document review 

• 

Stakeholder 
interviews with EU 
officials  

•  Workshop 

•  Document review 

•  CCEI monitoring 

data 

•  MS questionnaire 

• 

• 

responses 

Stakeholder 
interviews 

In-depth case 
studies 

•  Document review 

•  CCEI monitoring 

data 

•  MS questionnaire 

• 

• 

responses 

Stakeholder 
interviews 

In-depth case 
studies 

Existence of changes in equipment needs 
due to emerging challenges (e.g. the war in 
Ukraine, growing e-commerce, 
developments in drug trafficking and 
production)  
Reflection of any new equipment needs 
related to contextual changes in CCEI list 
of eligible equipment and MAWPs 
Stakeholder views on ability of CCEI to 
adapt to contextual changes  

•  Document review 

•  CCEI monitoring 

data 

•  MS questionnaire 

• 

• 

responses 

Stakeholder 
interviews  

In-depth case 
studies 

Extent to which the 
CCEI responds to the 
latest technological 

Alignment of CCEI list of eligible 
equipment / MAWPs with international best 
practice for customs control equipment 

•  Document review 

•  CCEI monitoring 

data 

93 

 
 
Evaluation questions 

Judgment criteria 

Indicators 

developments in customs 
control equipment 

Qualitative evidence on proposals / grants 
that concern innovative equipment 
Uptake of pilot projects for innovative 
equipment  
Alignment of programming / funding cycle 
with the timing of technological 
developments 
Degree to which eligible equipment is 
interoperable / uses standardised data 
formats 
Stakeholder views on the ability of CCEI to 
support the purchase of innovative / state-
of-the-art equipment 

Data sources 

•  MS questionnaire 

• 

• 

responses 

Stakeholder 
interviews 

In-depth case 
studies 

EQ  8.  To  what  extent  have  the  objectives,  scope  and  design  of  CCEI  remained  relevant, 
considering evolving EU needs and priorities in the field of customs? 

Extent to which CCEI is aligned with relevant EU policy and priorities in the field of customs 

The CCEI was introduced to support adequate and equivalent customs controls across the EU by 
co-financing the purchase, maintenance, and upgrading of customs control equipment. Ensuring 
high-performance customs enforcement is a core objective of the EU Customs Union, making it 
essential  that  the  CCEI  aligns  with  the  strategic  priorities  of  the  Union.  Given  the  evolving 
nature  of  customs  challenges,  including  geopolitical  shifts,  digitalisation,  and  organised  crime 
threats,  the  instrument's  relevance  depends  on  its  ability  to  address  the  most  pressing 
enforcement needs while adapting to emerging policy frameworks. 

An important indication for EU customs policies and priorities can be found in the EU Customs 
Strategy  and  the  Customs  Action  Plan,  which  outline  the  long-term  vision  and  immediate 
priorities  for  strengthening  the  Customs  Union.  The  strategy  focuses  on  creating  a  more  data-
driven, integrated, and resilient customs framework, ensuring that customs authorities across the 
EU  operate  as  a  single  entity.  Key  priorities  include  modernising  customs  controls  through 
digitalisation, improving risk management and data sharing, and enhancing cooperation between 
Member  States  to  address  security  threats  and  trade  challenges.  The  Customs  Action  Plan 
translates these goals into concrete initiatives, such as expanding data availability and analytics 
for customs supervision,  reinforcing  risk-based  control mechanisms, streamlining e-commerce-
related customs procedures, and promoting compliance through simplified reporting tools. Both 
documents  emphasise  equipping  customs  authorities  with  the  necessary  infrastructure  and 
technologies to improve enforcement capabilities, combat fraud, and facilitate legitimate trade.  

The  CCEI  aligns  strongly  with  the  needs  outlined  in  the  EU  Customs  Strategy  and  Customs 
Action Plan by addressing key priorities through its scope, objectives, and design. One of its key 
strengths  is  its  broad  scope,  which  allows  customs  authorities  across  all  27  Member  States  to 
access funding for a diverse range of customs control equipment. The instrument provides broad 
coverage  of  customs  control  equipment,  supporting  both  BCPs  and  customs  laboratories,  and 
covering a wide range of equipment, from large-scale non-intrusive inspection systems to small-
scale analytical tools. Its significant financial capacity allows Member States to make substantial 
upgrades,  including  investments  in  high-end,  cutting-edge  equipment  that  might  otherwise  be 
financially out of reach. Crucially, the instrument is available to all 27 Member States, ensuring 
that the entire EU Customs Union benefits from improved enforcement capabilities and reducing 
the  risk  of  weak  links  at  external  borders.  This  supports  the  overarching  strategic  goal  of 
ensuring that the Customs Union acts as one. 

94 

 
In terms of objectives, the CCEI contributes directly to the EU’s customs priorities, as set out in 
the  MAWPs.  The  first  MAWP  (2021-2022)  focused  on  addressing  equipment  shortages  and 
improving  customs  controls  at  the  Union  level,  with  a  focus  on  urgent  and  short-term  needs, 
while  the  second  MAWP  (2023-2024)  expanded  its  focus  to  include  mitigating  international 
conflicts,  supporting  the  implementation  of  EU  sanctions,  addressing  e-commerce  challenges, 
and  promoting  interoperability  and  innovation.  These  priorities  align  well  with  the  Customs 
Strategy’s emphasis  on digitalisation, data-driven risk management, and enhanced enforcement 
capabilities. Furthermore, by aiming to fund advanced detection technologies, the CCEI plays a 
role in strengthening security at EU borders, a core objective of the Customs Action Plan. 

The  design  of  the  CCEI  reflects  its  broad  scope  and  strategic  objectives.  The  instrument  is 
structured with a comprehensive list of eligible equipment, ensuring that customs authorities can 
tailor their applications to their specific needs while still contributing to the broader goals of the 
Customs Union. Moreover, its needs assessment and data reporting requirements are designed to 
support  a  more  data-driven  approach  to  customs  operations,  which  is  a  central  pillar  of  EU 
customs policy. By collecting detailed data on customs control equipment and risk management 
practices  at  the  national  level,  the  CCEI  design  not  only  aims  at  ensuring  that  investments  are 
targeted and effective but also tries to lay the groundwork for future policy decisions, reinforcing 
the  Customs  Strategy’s  long-term  vision  for  smarter,  more  integrated  customs  management. 
There is an overall strong alignment of the CCEI with EU customs priorities. The programme is 
a  well-structured  instrument  that  effectively  addresses  the  most  pressing  challenges  in  the 
customs field. 

While the broad scope of the CCEI is a key strength, it also presents challenges. The flexibility 
of the instrument, while ensuring broad participation, has led to a situation where it is difficult to 
ensure that all objectives are covered equally. Some limitations in the design of CCEI weaken its 
ability to align with all EU policy priorities equally. Specifically, the flexibility of the instrument 
has  led  to  an  uneven  prioritisation  of  objectives,  with  innovation,  sustainability,  and 
interoperability  receiving  less  emphasis  compared  to  traditional  enforcement  and  equipment 
replacement. 

Some  stakeholders  noted  that  the  lack  of  competition  in  the  grant  applications  during  the  first 
call contributes to this imbalance. Since funding is distributed across Member States without a 
strong  competitive  element,  there  is  limited  incentive  for  customs  administrations  to  propose 
innovative or interoperable solutions. This is reflected in  feedback from a Commission official 
who  reviewed  applications  and  customs  experts,  noting  that  while  some  projects  demonstrated 
innovative elements, many focused primarily on replacing outdated equipment. Importantly, this 
was largely in line with the focus of the first call, during which Member States were invited to 
target important shortages and also conduct upgrades of equipment. While innovation was still 
among  the  priorities  during  the  first  call,  the  Commission  didn’t  actively  steer  authorities 
towards it and the absence of a competitive bidding process (due to a lack of oversubscription) 
meant that leverage was limited.  

Another  limitation  stems  from  the  grant  evaluation  and  allocation  process.  One  evaluator  (i.e. 
Commission  staff  involved  in  evaluation  of  applications)  expressed  concerns  that  technical 
evaluation  criteria  were,  in  some  instances,  deprioritised  in  favour  of  ensuring  geographical 
balance  in  funding  allocation  or  other  political  considerations.  This  approach,  while  ensuring 
equal access across Member States, may have reduced the emphasis on strategic priorities such 
as  interoperability  or  innovation.  This  approach  may  reduce  the  CCEI’s  potential  to  drive  the 
next generation of customs enforcement technologies. 

A final challenge relates to the relevance of data collection mechanisms. The needs assessment 
process  has  played  a  crucial  role  in  providing  a  structured  inventory  of  customs  control 

95 

 
equipment  across  the  EU.  However,  some  Member  States  reported  inconsistencies  in  how  the 
process  aligned  with  their  national  tracking  methods,  leading  to  difficulties  in  assessing  real 
needs. Some Member States reported that the process does not always align with how they track 
and  categorise  their  customs  control  capabilities.  This  has  resulted  in  gaps  in  the  quality  and 
consistency of the data collected, potentially limiting the programme’s ability to fully contribute 
to a data-driven customs enforcement model. 35 

Extent to which CCEI has adapted to new and emerging EU policies and priorities 

As  EU  customs  policies  and  enforcement  challenges  continue  to  evolve,  it  is  critical  that  the 
CCEI remains aligned with emerging priorities to ensure that customs administrations across the 
EU  are  adequately  equipped  to  meet  new  demands.  The  instrument  has  demonstrated  a  high 
degree of adaptability in being able to align itself with new strategic priorities while maintaining 
its core objective of supporting customs control across the EU. The instrument did so primarily 
through adapting its objectives in the second MAWP, as well as incorporating these changes into 
the second call for applications. Additionally, the instrument’s flexibility towards existing grants 
allowed for some timely adjustments in specific projects affected by the war in Ukraine. CCEI 
has particularly responded to geopolitical shifts, legislative developments, and changes in trade 
and  enforcement  challenges,  notably  through  adjustments  in  the  second  MAWP  for  2023-24. 
However,  while  the  CCEI  has  shown  flexibility  in  adapting  to  shifting  policy  priorities,  some 
design features may have limited the extent to which the adaption of the priorities can translate 
into reality. 

The  geopolitical  landscape  has  played  a  defining  role  in  shaping  CCEI’s  priorities.  Following 
Russia’s  full-scale  invasion  of  Ukraine,  EU  customs  administrations  faced  new  enforcement 
challenges,  including  the  implementation  of  EU  sanctions,  changes  in  border  security 
requirements, and shifts in trade flows along the EU’s eastern frontier. The CCEI responded by 
incorporating  these  geopolitical  developments  into  its  second  MAWP,  prioritising  support  for 
Member  States  in  enforcing  sanctions  and  securing  alternative  trade  routes  through  the  EU-
Ukraine  “solidarity  lanes”.  Regarding  ongoing  projects  after  the  first  call,  in  practical  terms, 
funding  allocations  were  adjusted  to  reflect  the  shifting  needs  of  customs  administrations.  For 
example,  resources  initially  allocated  to  BCPs  with  Russia  were  redirected  to  support  other 
enforcement needs, demonstrating the programme’s flexibility. However, it cannot be said with 
certainty  whether  these  reallocations  fully  reflected  operational  necessities,  or  whether  some 
Member States redirected funding for convenience rather than to meet pressing needs. In the case 
study of the Finnish grant, foreseen equipment for BCPs at the Russian border was cancelled and 
replaced with equipment for smaller BCPs in the western part of the country. The analysis didn’t 
suggest a structured reassessment mechanism to ensure that the new allocations were optimally 
deployed. While Finnish authorities linked the equipment needs to specific risks (i.e. smuggling 
routes along those ports), it did not become clear whether the revised project was of comparable 
urgency or priority to the originally proposed one.  

Another important  area of alignment is  the fight against organised crime and illicit trafficking, 
particularly following the adoption of the EU Roadmap to Fight Drug Trafficking and Organised 
Crime (2023), including a European Ports Alliance.36 This initiative highlights the critical role of 
customs authorities in preventing the infiltration of illicit goods into the EU and stresses the need 
for  advanced  scanning  and  detection  technologies.  The  CCEI  aligns  well  with  this  priority  by 

35  For  further  insight  on  the  data  model  and  its  implementation,  see  the  sections  above  on  effectiveness  and 

efficiency. 

36 Communication from the Commission to the European Parliament and the Council on the EU roadmap to fight 

drug trafficking and organised crime, COM(2023) 641 final, 18.10.2023. 

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financing  non-intrusive  detection  systems,  mobile  scanners,  and  chemical  analysis  equipment, 
strengthening customs capacity to detect illegal substances and contraband. 

One of the most significant policy developments in recent years has been the proposal for an EU 
Customs Reform, published in 2023. Even though the reform has not been adopted, it serves as 
an illustration of the changing needs and priorities in the field of customs at the  EU-level. The 
reform  seeks  to  modernise  customs  operations  by  making  them  more  data-driven,  harmonised, 
and  risk-based,  including  the  creation  of  a  centralised  EU  Customs  Data  Hub  and  an  EU 
Customs  Authority  to  oversee  integrated  risk  assessment  and  digital  customs  processes.  CCEI 
was designed to  align with these aspects  as well by fostering a needs  and risk assessment that 
was  aimed  to  inform  funding  decisions  and  make  the  Customs  Union  more  data  driven.  The 
second MAWP further acknowledged some of these emerging needs by placing greater emphasis 
on  interoperability  and  innovation,  aligning  partially  with  the  Customs  Reform’s  push  towards 
enhanced data-sharing and intelligence-driven customs enforcement.  

The difference in  approach between the first  and second  calls  for applications  under the CCEI 
further  illustrates  the  instrument’s  adaptive  capacity,  but  also  its  limitations  in  ensuring 
consistent  alignment  with  evolving  EU  priorities.  The  first  call  was  relatively  open,  allowing 
Member States to focus on replacing outdated equipment and filling critical capacity gaps. The 
second  call  introduced  more  targeted  priorities,  reflecting  new  geopolitical  and  enforcement 
challenges, and providing Member States with specific recommendations on priority equipment 
needs.  Notably,  the  second  call  made  safety  and  security  a  mandatory  priority,  requiring  all 
project  proposals  to  address  at  least  one  security-related  risk,  whereas  other  policy  priorities 
remained  optional.  Additionally,  while  the  types  of  equipment  eligible  for  funding  remained 
unchanged, the second call introduced stricter security and cybersecurity requirements, including 
references to the NIS2 Directive37 and Commission security guidance to ensure compliance with 
EU security standards. 

A difference in the second call was the introduction of more top-down elements to the bottom-up 
approach of the first call, where Member States had significant discretion in selecting equipment 
and  project  focus.  These  elements  contained  the  granting  authority  providing  specific 
recommendations  that  Member  States  were  invited  to  address  in  their  applications.  This 
adjustment  aimed  to  ensure  that  funded  projects  aligned  more  closely  with  the  EU’s  strategic 
customs  priorities.  The  second  call  also  increased  the  minimum  passing  score  from  48  to  53, 
raising  the  threshold  for  Relevance  and  Innovation,  effectively  making  it  slightly  more 
demanding  for  applications  to  succeed.  However,  while  the  second  call  sought  to  strengthen 
alignment with key policy areas, most types of equipment could still be justified under the new 
framework with only minor adjustments in project rationale. For example, conventional baggage 
x-ray  machines  could  be  justified  under  both  detection  of  drugs  and  of  smuggled  antiquities, 
making  it  difficult  to  determine  whether  the  more  targeted  approach  significantly  changed  the 
nature of funded projects. 

Despite these challenges, interviews with European Commission officials and groupings such as 
CELBET  confirmed  the  adaptability  of  CCEI.  Its  ability  to  adjust  priorities  between  funding 
cycles  is  a  positive  feature  of  its  design,  which  ensures  continued  alignment  with  emerging 
needs. Having said that, the slow implementation of many projects has made it difficult to assess 
whether the equipment being purchased across the EU is leading to evolving relevance for future 
calls  and  WPs.  With  many  projects  from  the  first  call  still  ongoing,  it  seems  too  early  to 

37 Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a 
high  common  level  of  cybersecurity  across  the  Union,  amending  Regulation (EU)  No  910/2014  and  Directive 
(EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive). 

97 

 
 
comment  on  whether  the  newly  acquired  equipment  has  significantly  improved  customs 
operations and altered the needs and priorities that the programme should align with. 

Summary response 

Overall, CCEI shows a high level of relevance, aligning well with EU needs and priorities in the 
field  of  customs.  Its  broad  scope,  including  extensive  lists  of  equipment  for  both  BCPs  and 
customs  laboratories,  its  EU-wide  coverage,  and  its  significant  financial  scope  are  designed  to 
allow  Member  States  to  upgrade  critical  enforcement  capabilities.  By  financing  modern 
detection  technologies  and  addressing  key  enforcement  gaps,  the  instrument  also  directly 
supports  EU  objectives  in  customs  modernisation,  and  working  towards  the  Customs  Union 
acting as one with raising the general level of equipment. 

The instrument has also demonstrated adaptability, particularly through adjustments made in the 
second  MAWP  (2023-24).  These  shifts  reflect  geopolitical  changes,  such  as  supporting  EU 
sanctions enforcement after Russia’s full-scale invasion of Ukraine, and addressing new customs 
challenges  in  e-commerce  and  organised  crime  prevention.  CCEI  has  also  shown  flexibility  in 
reallocating  funding,  though  it  remains  unclear  whether  these  shifts  fully  reflected  operational 
needs. 

Despite its strong relevance, the CCEI’s breadth and flexibility hinder its ability to place focus 
on certain priorities. The lack of competitive bidding during the first call and the high degree of 
Member  State  discretion  have  led  to  some  objectives,  such  as  innovation,  interoperability,  and 
sustainability, receiving less emphasis in funded projects. While the second call for applications 
introduced more targeted priorities, Member States maintain considerable leeway in selecting the 
equipment to target.  

Finally,  while  CCEI’s  continued  relevance  is  widely  acknowledged  by  stakeholders,  the  slow 
implementation of many projects makes it difficult to assess the changing relevance of CCEI as a 
whole and for future calls and WPs. With many first-call projects still ongoing, it remains to be 
seen  whether  the  procured  equipment  requires  adjustments  to  the  programme’s  design  and 
objectives for it to stay as relevant. Moving forward, ensuring that Member States' applications 
better align with EU-wide customs objectives may require stronger strategic steering and clearer 
guidance on priority investments. 

EQ 9. To what extent do stakeholders support the CCEI? 

Extent to which stakeholders are favourable towards the objectives and design of CCEI 

Ensuring  effective and harmonised customs control across the EU is  a shared objective among 
Member  States,  and  the  CCEI  is  widely  supported  as  a  tool  for  strengthening  customs 
enforcement  capacity. Stakeholder feedback indicates that  national  customs authorities broadly 
endorse  the  instrument’s  objectives  and  see  it  as  a  necessary  mechanism  for  addressing 
disparities  in  customs  control  capabilities.  While  there  is  some  divergence  in  perspectives 
regarding  certain  design  aspects,  overall,  Member  States  have  shown  strong  interest  in 
participating in the CCEI, with all 27 countries securing grants under at least one of the two calls 
for proposals. 

Customs  administrations  generally  perceive  the  CCEI  as  a  relevant  and  useful  instrument, 
reflecting  a  widely  held  view  that  EU-level  financial  support  is  needed  to  enhance  customs 
control  equipment.  As  shown  in  the  graph  below  from  the  questionnaire,  customs  authorities 
overwhelmingly agreed on the importance of reducing imbalances in customs control capabilities 
(48%  considered  it  very  important  and  35%  somewhat  important),  with  a  large  majority 
identifying  disparities  in  financial  resources  (48%),  administrative  capacity  (42%),  and 
availability of customs control equipment (39%) as key concerns. The principle that the Customs 

98 

 
Union  is  only  as  strong as  its  weakest  link  was  emphasised  by  several  Member  States  in  their 
explanatory remarks to that question, reinforcing the rationale for an EU funding instrument and 
EU-level coordination on matters of customs control equipment. Many respondents viewed the 
CCEI as a means of ensuring a baseline standard of enforcement across all Member States. This 
sentiment was echoed in interviews, with several customs authorities, highlighting that the CCEI 
has been instrumental in reinforcing security at key BCPs.  

Figure 20: How important are the following issues and challenges from the perspective of your 
customs administration? 

Source: Questionnaire responses from national customs administrations 

When  it  comes  to  the  objectives  of  CCEI,  Member  States  showed  strong  agreement  with  the 
specific priorities outlined in the first and second MAWPs. In the questionnaire, a vast majority 
of  respondents  (71%)  found  that  addressing  equipment  shortages  in  the  first  MAWP  fully 
aligned  with  their  national  priorities,  while  65%  supported  the  focus  on  improving  customs 
controls across the Union. Similarly, in the second MAWP, 81% of responding authorities fully 
agreed with the prioritisation of strategic BCPs and their related risks, while 68% supported the 
emphasis on mitigating international conflicts and crises. However, innovation and sustainability 
were  ranked as  lower priorities by customs administrations, with  only  26% fully aligning  with 
the  goal  of  building  greener  capabilities.  In  interviews,  some  Member  States  recognised  the 
potential for the CCEI to drive innovation in customs controls, while others maintained that their 
primary focus remained on enforcement and risk management. 

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Figure 21: To what extent are the priorities for the first Multi-Annual Work Programme (2021-
22) still important for your country? 

Source: Questionnaire responses from national customs administrations. 

Figure  22:  To  what  extent  are  the  priorities  for  the  second  Multi-Annual  Work  Programme 
(2023-24) still important for your country? 

Source: Questionnaire responses from national customs administrations. 

Despite broad support for the programme’s objectives, some aspects of its design received mixed 
feedback. One recurring concern among stakeholders relates to the procurement process, which 
has been a source of difficulty for several Member States. With CCEI being designed in a way 
that  leaves  equipment  procurement  entirely  to  the  discretion  of  Member  States,  some  case 
studies  highlighted  that  procurement  delays  can  significantly  disrupt  project  implementation. 

100 

 
 
 
Officials suggested that additional EU-level guidance could help mitigate challenges, particularly 
for  customs  authorities  with  limited  experience  in  managing  large-scale  equipment  tenders.  A 
few  Member  State  authorities  suggested  that  a  form  of  joint  procurement  or  centralised 
procurement  at  the  EU-level  could  facilitate  the  instrument.  However,  views  on  potentially 
incorporating such elements  into the design  of the CCEI vary, with  some countries advocating 
for  greater  standardisation  or  even  centralised  procurement  while  others  prefer  maintaining 
national discretion.  

Similarly, when it comes to the question of enhancing EU-level guidance on what equipment to 
purchase in the design of the instrument, some authorities suggested that the Commission could 
play a more active role in coordinating equipment needs to better address the most urgent needs 
of the Customs Union as a whole and to improve standardisation. This was met with scepticism 
by  others,  who  rather  wished  for  a  more  trust-based  approach,  in  which  Member  States  are 
trusted to select the correct type of equipment. This difference in opinion on the design reflects 
the conflict  between the bottom-up approach that  CCEI has largely  taken so  far, and the more 
top-down elements, which the Commission started to introduce during the second round of grant 
applications.   

In terms of interest in participation, engagement with the CCEI has been strong across the EU, 
with all Member States securing funding in at least one of the two calls so far. The size of the 
grants  varies  significantly,  and  a  few  Member  States  have  indicated  that  participation  is 
somewhat  burdensome,  particularly  those  that  applied  for  smaller  grants.  Some  smaller 
recipients  have  questioned  whether  the  administrative  effort  required  to  apply  for  and  manage 
CCEI projects is proportionate to the funding received. Moreover, the motivation to participate 
seems impacted by the availability of resources at the national level, with a few Member States 
not  assessing  the  need  as  high  enough  to  apply  for  the  instrument  repeatedly.  Nonetheless, 
overall  participation  levels  indicate  that  most  customs  authorities  continue  to  see  value  in  the 
programme. 

Taken  together,  the  evidence  suggests  that  the  CCEI  enjoys  strong  support  from  national 
customs authorities, both in principle and in practice. While there are areas where the design of 
the  programme  could  be  refined,  stakeholders  widely  agree  on  the  necessity  of  an  EU-level 
financial instrument to support customs control equipment. The high level of participation in the 
first  two  calls  reflects  Member  States’  continued  interest  in  leveraging  CCEI  funding  to 
modernise and enhance their customs operations.  

Extent to which CCEI meets stakeholder needs 

The extent to which the CCEI meets stakeholder needs is a key factor in assessing its relevance. 
While  the  CCEI  has  been  broadly  welcomed  by  Member  States  as  a  valuable  funding 
mechanism, perspectives on whether it fully meets their needs vary. In particular, some customs 
administrations  have  questioned  aspects  of  the  needs  assessment  process,  while  others  have 
pointed  to  gaps  in  the  eligibility  criteria  that  may  limit  the  programme’s  effectiveness  in 
addressing their specific requirements. 

The  responses  from  Member  States  suggest  that  CCEI  largely  aligns  with  their  operational 
needs, with most authorities considering the programme to be a valuable source of funding. In 
the  questionnaire,  a  majority  of  respondents  agreed  that  the  eligibility  criteria  align  with  their 
equipment needs and priorities, particularly in relation to customs laboratories, where over half 
of  authorities  (52%)  found  full  alignment.  With  that  being  said,  for  BCPs,  the  level  of  full 
alignment  was  lower  at  30%,  with  most  respondents  (53%)  viewing  the  criteria  as  ‘mostly 
aligned’. In elaborating on these responses, several customs authorities expressed concerns that 
while  the  eligible  equipment  list  broadly  covers  necessary  items,  it  does  not  go  far  enough  in 
addressing  specific  gaps.  For  example,  it  was  emphasised  that  certain  non-intrusive  detection 

101 

 
tools,  officer  protection  equipment,  and  monitoring  devices  such  as  CO₂  and  F-gas  analytical 
detectors are missing. Similarly, infrastructure costs, which are often essential for the installation 
and effective use of customs control equipment, remain ineligible for CCEI funding. However, 
the  exclusion  of  infrastructure  is  also  a  justifiable  design  choice.  Expanding  eligibility  to 
infrastructure costs would not only further dilute the programme’s already broad scope but also 
complicate  funding  allocation  by  making  it  difficult  to  define  clear  boundaries  on  what 
constitutes  eligible  infrastructure.  Ensuring  a  targeted  focus  on  customs  control  equipment 
prevents the programme from becoming too open-ended and difficult to steer strategically. 

Figure 23: To what extent do the eligibility criteria align with the equipment needs and priorities 
of your administration? 

Source: Questionnaire responses from national customs administrations. 

Summary Response 

The CCEI enjoys strong overall support from national customs authorities, with Member States 
widely  recognising  its  role  in  strengthening  customs  enforcement  across  the  EU.  Stakeholders 
largely endorse its objectives, particularly in addressing disparities in customs control capacities 
and ensuring a more harmonised Customs Union. All 27 Member States have participated in at 
least  one  of  the  two  calls  for  proposals.  This  demonstrates  a  high  level  of  engagement  and 
continued interest in leveraging CCEI funding, even though participation and engagement have 
differed between Member States, with a few authorities not assessing the need as high enough to 
make  it  worth  the  effort.  The  instrument  is,  nonetheless,  widely  perceived  as  a  necessary  tool, 
particularly  for  addressing  financial  and  resource  imbalances  between  Member  States,  which 
was  a  key  concern  highlighted  in  the  questionnaire  and  interviews.  However,  while  customs 
authorities  broadly  support  the  programme,  perspectives  on  certain  design  elements  vary, 
particularly  in  relation  to:  whether  equipment  selection  and  procurement  should  be  left  to  the 
Member States or be coordinated more at an EU-level; whether the design of reporting structures 
is appropriate or should be tailored more to daily operations of customs authorities; and to what 
extent standardisation efforts should be at the centre of the CCEI or not. 

The  extent  to  which  CCEI  meets  stakeholder  needs  is  somewhat  more  nuanced.  While  most 
Member  States  consider  it  a  valuable  funding  instrument,  some  have  raised  concerns  about 
whether it fully addresses their specific needs. The eligibility criteria are generally seen as well-
aligned  with  national  priorities,  particularly  for  customs  laboratories,  but  gaps  remain  – 
especially  for  BCPs  –  where  infrastructure,  software,  and  certain  types  of  detection  and 
protection equipment are missing from the eligible list. Additionally, some Member States would 
prefer  greater  flexibility  in  the  eligibility  framework  to  allow  for  emerging  technological 
solutions and better meet their needs.  

102 

 
 
EQ  10.  To  what  extent  has  CCEI  been  able  to  adapt  to  developments  in  technology  and  the 
wider geopolitical and policy context beyond customs? 

Extent to which CCEI is able to adapt to key contextual changes and new challenges concerning 
customs control equipment 

Customs  enforcement  operates  within  a  dynamic  environment  shaped  by  geopolitical 
developments,  evolving  security  threats,  and  technological  advancements.  As  trade  flows  shift 
and new risks emerge, such as the war in Ukraine, drug trafficking, and cyber threats, customs 
authorities  must  continuously  adapt  their  control  measures.  The  CCEI  is  designed  to  support 
these efforts by financing the purchase and upgrade of customs control equipment, but its ability 
to  keep  pace  with  evolving  needs  depends  on  how  flexibly  it  can  accommodate  emerging 
challenges. This section examines how the CCEI has responded to contextual changes, including 
whether  new  equipment  priorities  have  influenced  funding  allocations  and  whether  customs 
administrations perceive the instrument as sufficiently adaptable to their operational realities. 

A  key  example  of  changing  needs  due  to  geopolitical  developments  is  the  impact  of  Russia’s 
full-scale  invasion  of  Ukraine  on  customs  enforcement.  The  case  studies  illustrate  how  border 
closures and shifts in trade flows have altered the deployment of customs control equipment. For 
instance, Finland originally planned its CCEI-funded project to enhance BCPs along its eastern 
frontier  with  Russia  and  Norway.  However,  following  Russia’s  invasion  of  Ukraine  and  the 
subsequent closure of Finland’s eastern border, the project was revised substantially. The Finnish 
authorities  reallocated  funding  away  from  traffic-related  customs  control  equipment  such  as 
ANPR systems at now-closed BCPs and redirected it to strengthen control capabilities at ports in 
western  Finland,  which  experienced  increased  traffic  due  to  trade  route  diversions.  Similarly, 
Lithuanian customs officials reported a shift in focus from import controls to export enforcement 
to ensure compliance with EU sanctions. The flexibility of the CCEI allowed these adjustments 
to take place, supporting customs authorities in addressing evolving needs without requiring an 
entirely new round of funding. 

More broadly, the adaptability of the CCEI has been reflected in its MAWPs, which incorporate 
evolving  priorities.  The  second  MAWP  (2023–24)  explicitly  integrates  policy  developments 
such as the EU Roadmap to Fight Drug Trafficking and Organised Crime, reinforcing the role of 
customs  control  equipment  in  countering  illicit  trade  and  financial  crime.  The  MAWP  aligns 
CCEI support with the European Ports Alliance initiative, which seeks to enhance drug detection 
capacities  at  key  maritime  entry  points.  This  reflects  an  awareness  of  customs  authorities’ 
growing need for high-performance scanning and analytical equipment to manage the increasing 
volume of illicit drugs trafficked through European ports. The CCEI’s ability to integrate these 
priorities into its funding calls suggests a strong level of responsiveness to external policy shifts. 

However, while CCEI has been effective in accommodating shifts in customs control priorities, 
some  stakeholders  expressed  concerns  about  gaps  in  adaptation,  particularly  in  relation  to 
cybersecurity  and  procurement  security.  As  geopolitical  tensions  have  intensified,  customs 
administrations  have  become  increasingly  wary  of  sourcing  customs  control  equipment  from 
certain non-EU manufacturers due to concerns over data security and potential vulnerabilities in 
critical  infrastructure.  Several  Member  States  reported  encountering  difficulties  when  trying  to 
factor security considerations into their procurement processes. The absence of explicit guidance 
from  the  Commission  on  security-related  procurement  standards  has  left  some  authorities 
uncertain  about  how  to  approach  these  concerns  while  ensuring  compliance  with  EU 
procurement  rules.  Industry  stakeholders  also  raised  concerns  about  the  dominance  of  non-EU 
suppliers,  particularly  from  China,  in  the  customs  control  equipment  market.  Some  suggested 
that  the  CCEI  could  do  more  to  encourage  European  strategic  autonomy  in  this  sector,  for 

103 

 
example by introducing procurement criteria that place greater emphasis on security and quality 
over cost alone. 

While the flexibility of the CCEI has been largely praised, Member States have pointed to areas 
where  further  improvements  could  be  made  in  anticipating  rather  than  reacting  to  emerging 
challenges. One recurring issue is the ability of the needs assessment process to fully capture the 
evolving  risk  landscape.  Discrepancies  between  reported  risk  scores  for  BCPs  and  actual 
equipment  inventories  were  identified  for  some  Member  States,  affecting  the  prioritisation  of 
investments.  The  risk  scoring  methodology  was  perceived  as  inconsistent,  as  Member  States 
were not required to score all identified risk factors and not all authorities appeared to grasp the 
correct way to conduct the risk scoring, which led to variations in how risks were assessed across 
different  jurisdictions.  Additionally,  accurate  inventory  reporting  has  proven  challenging  for 
some  authorities,  with  Member  States  citing  difficulties  in  maintaining  precise  records  of 
existing equipment, which in turn complicates planning for future investments. 

Extent to which the CCEI responds to the latest technological developments in customs control 
equipment 

One of the objectives of the CCEI is to support the modernisation of customs control equipment 
by ensuring that Member States have access to state-of-the-art tools for border management and 
enforcement.  In  addition  to  addressing  equipment  shortages  and  ensuring  equivalent  levels  of 
customs control across the EU, the programme was also intended to foster innovation in customs 
control equipment and – related to that but not an explicit objective in itself  – promote greater 
standardisation  of  technologies  used  by  Member  States.  The  ability  to  incorporate  emerging 
technologies  and  align  procurement  with  evolving  international  best  practices  is  therefore  an 
important  aspect  of  the  programme’s  relevance.  This  section  examines  the  extent  to  which  the 
CCEI has supported technological advancements, facilitated the uptake of innovative solutions, 
and encouraged standardisation in customs control equipment across the EU. 

Stakeholder feedback suggests that many CCEI-funded projects during the first call have focused 
on replacing  ageing equipment and improving detection technologies more broadly rather than 
piloting  or  integrating  innovative  solutions.  This  approach  by  national  authorities  aligned  well 
with the focus of the first call under the CCEI, which highlighted maintaining and upgrading of 
equipment  as  core  targets.  It  further  was  in  line  with  Member  States’  priorities,  as  they  have 
generally  valued  reliability  and  immediate  operational  needs  over  experimental  or  state-of-the-
art equipment. During the first call, the programme still encouraged investment in cutting-edge 
technologies  (as  visible  both  in  the  first  MAWP  and  call  for  application),  but  without  a 
structured  incentive  or  pressure  to  prioritise  them  in  a  more  bottom-up  approach  to  the 
programme. Even though the bidding is designed as a competitive process, the fact that the first 
call  was  not  oversubscribed  lead  to  a  non-competitive  setting,  in  which  customs  authorities 
largely received what they applied for and leverage for steering was limited. As a result, it was 
largely  left  to  individual  customs  administrations  to  decide  whether  to  incorporate  innovative 
elements into their projects. 

Some  stakeholders,  including  industry  representatives  and  certain  Member  States,  have 
suggested  that  eligibility  criteria  should  be  broadened  to  better  accommodate  emerging 
technologies  such  as  AI-powered  detection  systems  and  drone  surveillance.  Germany,  for 
example,  recommended  that  the  Commission  periodically  review  the  eligibility  criteria  to 
incorporate  advancements in  customs control equipment.  Industry representatives further noted 
that companies producing innovative equipment often struggle to get their solutions included in 
the  eligible  equipment  list  or  noticed  by  customs  authorities,  with  some  proposing  a  process 
similar to the US model, where pre-procurement funding is available for developing and testing 
emerging technologies. 

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The  evaluation  identified  a  limited  number  of  CCEI-funded  projects  that  incorporated 
particularly innovative elements during the first round of projects. The  Dutch case study offers 
one  example  where  the  grant  was  used  to  introduce  advanced  scanning  and  detection 
technologies  at  major  cargo  and  passenger  entry  points,  including  the  Port  of  Rotterdam  and 
Schiphol  Airport.  The  project  aimed  to  integrate  equipment  into  a  cohesive  detection  network, 
leveraging  AI  and  algorithmic  analysis  to  enhance  customs  controls.  However,  despite  these 
ambitions,  officials  noted  that  full  implementation  of  the  envisioned  data  integration  and  AI-
driven detection had not yet materialised at the time of preparing the case study. More generally, 
Commission  staff  serving  as  application  evaluators  for  CCEI  acknowledged  that  while  some 
proposals demonstrated a strong focus on innovation, others placed little emphasis on it and still 
managed to secure funding. The fact that safety and security were the only mandatory priorities 
also in the second call for applications, combined with a (de facto) non-competitive application 
process, has contributed to innovation being a lower-rated aspect of project evaluations overall. 

Another challenge concerns the alignment between the CCEI programming cycle and the pace of 
technological  advancement.  Customs  authorities  and  industry  stakeholders  highlighted  that 
procurement cycles under the CCEI are relatively slow, which may delay the uptake of emerging 
technologies. The lack of dedicated funding for pilot projects or pre-procurement testing further 
limits  the  programme’s  capacity  to  harness  technological  advancement.  In  interviews,  a  few 
Member State officials suggested that future CCEI calls should include mechanisms for funding 
the development and piloting of new technologies, rather than focusing solely on procurement. 

Interoperability also emerged as areas where the CCEI’s relevance has been limited, as well as 
for  standardisation.  While  the  programme  aims  to  promote  harmonisation  across  the  EU, 
customs  authorities  and  industry  representatives  reported  ongoing  challenges  related  to  data 
integration  and  standardisation  of  equipment.  Industry  stakeholders  noted  that  the  absence  of 
EU-wide  technical  standards  for  customs  control  equipment  leads  to  inefficiencies,  as 
manufacturers must adapt their products to varying national specifications. This increases costs 
and complicates future equipment  upgrades and maintenance.  In  Ireland, for example, customs 
authorities  highlighted  the  lack  of  integration  between  different  national  customs  systems, 
emphasising  that  data  protection  concerns  sometimes  prevent  effective  information-sharing 
between  Member  States.  Similarly,  one  official  pointed  out  that  while  the  CCEI  encourages 
interoperability, data-sharing initiatives were suspended due to  concerns about equipment from 
certain non-EU providers being used in some countries, reflecting broader geopolitical tensions 
in procurement decisions. 

Despite  these  shortcomings,  most  Member  States  acknowledge  that  the  CCEI  has  played  an 
important  role  in  ensuring  access  to  modern  customs  control  tools.  The  questionnaire  results 
indicate that 52% of national authorities strongly agreed, and another 39% tended to agree, that 
the  CCEI  encourages  the  purchase  of  innovative  equipment.  However,  qualitative  feedback 
suggests  that  this  is  not  necessarily  due  to  the  programme  actively  prioritising  technological 
advancement,  but  rather  because  it  provides  much-needed  funding  for  equipment  upgrades. 
Some Member States emphasised that the CCEI could further enhance its impact by expanding 
support beyond equipment procurement to include digital solutions, software development, and 
AI-driven risk analysis tools. 

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Figure  24:  Please  express  your  level  of  agreement  with  the  following  assumptions  on  the 
deployment of CCEI funding 

Source: Questionnaire responses from national customs administrations. 

Summary response 

The CCEI has demonstrated a notable degree of flexibility in adapting to evolving geopolitical 
and policy contexts, particularly in response to crises such as the war in Ukraine. The ability of 
Member  States  to  amend  ongoing  projects  and  reallocate  funding  has  been  widely  praised, 
allowing  customs  authorities  to  shift  equipment  deployments  in  response  to  trade  flow 
disruptions and evolving enforcement priorities. The incorporation of emerging policy priorities, 
such  as  drug  trafficking  and  organised  crime,  into  the  second  MAWP  further  illustrates  the 
programme’s  responsiveness  to  external  developments.  However,  while  CCEI  has  proven 
adaptable in reallocating resources and adjusting funding priorities, some limitations persist. One 
key concern is the lack of explicit guidance on security-related procurement issues, with Member 
States facing challenges in navigating concerns over equipment sourcing, particularly from non-
EU providers.  

In  contrast,  the  CCEI’s  alignment  with  technological  advancements  in  customs  control 
equipment  presents  a  more  mixed  picture.  While  the  programme  has  facilitated  the 
modernisation  of  customs  enforcement  by  funding  essential  equipment  upgrades,  its  role  in 
fostering  innovation  has  been  relatively  limited.  Member  States  have  generally  prioritised  the 
replacement  of  ageing  equipment  over  the  adoption  of  emerging  technologies  during  the  first 
call, and the lack of competition during the application process has meant that innovation has not 
been a decisive factor in project evaluations. Nonetheless, some projects, such as visible in the 
Dutch case study, have integrated advanced scanning and AI-driven detection tools. Stakeholders 
have  suggested  that  the  programme  could  do  more  to  facilitate  the  uptake  of  emerging 
technologies by broadening eligibility criteria and providing dedicated funding for pilot projects 
and research-driven innovation. 

Furthermore, interoperability and standardisation remain areas where steering has been limited. 
While the CCEI aims to promote greater harmonisation in customs control equipment, variations 
in national procurement practices and a lack of common technical standards have reportedly led 
to  inefficiencies  and  increased  costs  for  manufacturers.  Some  Member  States  have  also  raised 
concerns about data integration challenges, with geopolitical considerations further complicating 
cross-border  information-sharing  initiatives.  Despite  these  challenges,  customs  authorities 
generally  acknowledge  that  the  CCEI  has  played  a  crucial  role  in  ensuring  access  to  modern 
enforcement tools.  

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Coherence 

Table 17: Evaluation matrix for Coherence 

Evaluation questions 

Judgment criteria 

Indicators 

Data sources 

11. To what extent are the various 
elements of CCEI coherent with 
one another and maximising the 
generation of synergies? 

Extent to which CCEI is 
comprised of a coherent 
and mutually supportive 
mix of activities  

Extent to which 
synergies within CCEI 
are materialising in 
practice 

12. To what extent is CCEI 
coherent with relevant Customs 
Union and wider EU policies, 
programmes, funds and 
instruments, and maximising 
synergies in practice? 

Extent to which CCEI is 
coherent with EU 
customs policy and wider 
policy priorities  

Extent to which CCEI is 
coherent with other EU 
programmes, funds and 
instruments 

Extent to which 
synergies between CCEI 
and other initiatives are 
materialising in practice 
Extent to which 
equipment purchased is 
shared with and supports 
the work of other border 
authorities  

Soundness of the CCEI intervention logic 
Stakeholder views on the balance between 
different CCEI components and activities  
Evidence / examples of any inconsistencies 
/ gaps between parts of CCEI 

Evidence / examples of synergies between 
CCEI grants and supporting activities 
Evidence / examples of synergies between 
CCEI grants (including complementarities 
described in applications and evidence of 
this in practice, both within and between 
countries) 
Evidence / examples of any issues, e.g. 
wrong balance between purchases of new 
equipment and maintenance  

Level of alignment between CCEI 
documentation and relevant EU policies 
and strategies  
Stakeholder views on whether CCEI and 
relevant EU policies and strategies are 
complementary and mutually reinforcing¨ 
Evidence of / examples of any 
inconsistencies / gaps between CCEI and 
relevant EU policies and strategies 

Level of alignment between CCEI 
documentation and relevant EU 
programmes, funds and initiatives  
Stakeholder feedback on whether CCEI 
complements and avoids duplication with 
relevant EU programmes, funds and 
initiatives  
Evidence of / examples of any 
inconsistencies / gaps between CCEI and 
relevant EU programmes, funds and 
instruments  

Evidence / examples of synergies / 
duplication / issues between CCEI grants 
and other policies and strategies  
Evidence / examples of synergies / 
duplication / issues between CCEI grants 
and funding / projects from other 
programmes, funds and instruments  
Evidence / examples of synergies / 
duplication / issues between CCEI grants 
and the work of other border authorities 

•  Document review 

• 

Stakeholder 
interviews  

•  MS questionnaire 
responses  

•  CCEI monitoring 

data 

• 

Stakeholder 
interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies  

•  Document review 

• 

Stakeholder 
interviews with EU 
officials 

•  Document review 

• 

Stakeholder 
interviews with EU 
officials 

•  CCEI monitoring 

data 

• 

Stakeholder 
interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies  

EQ  11.  To  what  extent  are  the  various  elements  of  CCEI  coherent  with  one  another  and 
maximising the generation of synergies? 

This  evaluation  question  addresses  the  internal  coherence  of  the  Instrument  and  assesses  the 
extent  to  which  its  activities  and  component  parts  fit  together.  The  CCEI’s  Regulation  and 
intervention  logic  sets  out  a  relatively  simple  delivery  model  based  predominantly  on  direct 

107 

 
financial  support  through  grant  funding.  While  the  Instrument’s  main  activity  provides  grants 
“for the purchase, maintenance and upgrade of customs control equipment”, to  respond to  this 
question the evaluation looks at the extent to which this is supported by non-financial activities 
making use particularly of Commission documentation and interview feedback. It also examines 
whether synergies between CCEI grants and other aspects of the programme have materialised, 
focusing particularly on the issue of joint procurement. 

Extent to which CCEI is comprised of a coherent and mutually supportive mix of activities 

The question of whether the CCEI is internally coherent is made somewhat more straightforward 
by  the  fact  that  the  CCEI  does  not  carry  out  a  large  “mix  of  activities”.  While  assessing  the 
extent to which the Instrument’s objectives are internally coherent with the style of programme 
delivery is an important line of inquiry, this is covered under the relevance EQs above. 

The Instrument is focused mostly on providing direct co-financing. Article 6 of the Regulation 
stipulates  that  direct  financing  is  available  for  six  eligible  “purposes”:  a)  non-intrusive 
inspection;  (b)  indication  of  hidden  objects  on  humans;  (c)  radiation  detection  and  nuclide 
identification; (d) analysis of samples in laboratories; (e) sampling and field analysis of samples; 
(f) handheld search. While the value of these purposes and the eligibility of types of equipment is 
explored under the Relevance EQs, there is no evidence to suggest that these “purposes” are not 
complementary or collectively do not fully cover the needs of Member States. Furthermore, the 
other major distinction in the type of activities is the appropriateness of the mix of funding for 
BCPs and customs laboratories. While the spending is divided into 80% for BCPs and 20% for 
Labs, there is no evidence of any discontent with this split, nor any very positive feedback on it. 
However, as outlined in EQ 3, both the demand (in terms of applications) and spend was higher 
for BCPs than the original allocation, prompting the questions of whether this division should be 
increased further for funding for BCPs. 

The Commission also supports the Member States with central guidance on procurement in the 
form of call documents and support through the aforementioned support officers. In this respect, 
the majority of MS share a positive view on how the CCEI is being managed, with  a majority 
believing  the  guidance  provided  by  DG  TAXUD  for  CCEI  participation  is  sufficiently  clear 
(52% strongly agree, 39% tend to agree). However, Member States also highlighted the need for 
more clarity in procurement guidelines from DG TAXUD regarding permissible equipment and 
suppliers, including the prohibition of certain countries or companies. They indicated that more 
explicit  guidelines  from  the  Commission  in  these  areas  could  have  reduced  ambiguity  and 
ultimately  improved  the  efficiency  of  the  procurement  process  as  certain  suppliers  could  have 
been ruled out from the start of the process and been unable to appeal tender decisions.  

A final activity which supports the delivery of the Instrument is the “meeting of experts”, namely 
the  CCEI  Coordination  Group  (CCEI  CG).  The  feedback  on  this  activity  was  generally  if  not 
universally positive, with some suggestions for ways it could be improved. When asked whether 
the  CCEI  CG  is  an  effective  forum  for  collaboration,  only  29%  of  Member  State  respondents 
“strongly”  agreed,  while  the  majority  (55%)  “tended”  to  agree,  and  the  remainder  (16%)  were 
either neutral or disagreed. The case studies also indicated that the CCEI CG is generally seen as 
a positive platform for collaboration, but there were suggestions for enhancing its effectiveness 
by  expanding  its  scope  and  establishing  more  specialised  working  groups  to  address  specific 
challenges  and  opportunities  in  procurement  and  deployment  such  as  specific  categories  of 
equipment (e.g. fixed scanners), innovation and AI, which could provide learning opportunities.  

Extent to which synergies within CCEI are materialising in practice  

One of the few “internal” synergies between aspects of CCEI which is  explicitly mentioned in 
the Regulation is to facilitate joint procurement of CCE amongst Member States. Although the 
legislation does not provide a large amount of explanation or guidance on how to achieve this, 

108 

 
Article  6.6  states  that  “the  Commission  shall  also  encourage  the  joint  procurement  and  joint 
testing of customs control equipment by two or more member states”. However, thus far, while 
the CCEI has not supported any joint procurement of CCE, the CCEI CG produced a deliverable 
(no.  5)  on  procurement  which  explored  new  procurement  methods  and  encouraged  joint 
procurement with a focus on safety, sustainability and centralised structure. 

The  questionnaire  found  that  the  economic  benefits,  such  as  economies  of  scale  of  joint 
procurement,  were  widely  recognised,  with  Member  States  noting  its  value  particularly  for 
standardised equipment such as handheld scanners. However, the questionnaire also highlighted 
several significant barriers to joint procurement, primarily stemming from differences in national 
legislation  and  procurement  procedures.  In  the  case  studies,  other  Member  States  expressed 
scepticism  regarding  highly  specialised  or  location-specific  equipment,  which  may  be  less 
suitable for joint procurement due to varying national needs and schedules.  

Furthermore,  some  Member  States  even  suggested  that,  compounded  by  a  wider  climate  of 
inflation, CCEI might have had a distortionary effect on the supply of CCE given the increase in 
demand  which  the  Instrument  contributed  to.  Several  Member  States  argued  that  the  small 
number  of  CCE  manufacturers  faced  strain  on  their  supply  chains  from  increased  demand, 
leading  to  longer  production  lead  times  and  further  delays  in  the  procurement  process  and 
perhaps  contributing  to  price  inflation.  This  further  underlines  the  potential  value  of  joint 
procurement  and  how  competition  among  Member  States  for  similar  types  of  equipment  can 
create  challenges  in  the  procurement  process,  particularly  when  the  number  of  suppliers  is 
limited and when specific security or technical requirements need to be met. 

To increase the feasibility of this important synergy, many Member States emphasised the need 
for  a  harmonised  legal  framework  and  standardised  processes  at  the  EU  level  to  address  these 
discrepancies. A Member State cited a examples like the EU’s COVID-19 vaccine procurement 
as  a  successful  model  of  centralised  coordination,  with  suggestions  that  the  Commission  or 
dedicated CCEI staff could manage joint procurement processes. A pilot project demonstrating 
feasibility and benefits was also proposed by another Member State as a  starting point to build 
confidence and align efforts.  

In addition to joint procurement, there also has been a lack of progress with standardisation and 
data sharing between Member States, though this is analysed in EQ 1. 

Summary response  

The  Customs  Control  Equipment  Instrument  demonstrates  internal  coherence  and  potential  for 
synergies  under  a  delivery  model  that  is  primarily  focused  on  direct  financial  support  through 
grants for customs control equipment. While the CCEI's activities are not as varied as other EU 
programmes,  its  direct  co-financing  approach  covers  six  eligible  purposes,  which  are 
complementary  and  align  with  Member  States'  needs.  Furthermore,  the  fact  that  demand  and 
expenditure between Labs and BCPs has been marginally different to originally envisaged in the 
2021-2022  MAWP  (which  foresaw  an  80/20%  split  of  the  funding  between  BCPs  and  Labs), 
indicates that this aspect  is  complementary and coherent  though  a larger  share for BCPs could 
increase  the  internal  coherence  of  the  Instrument.  The  support  from  DG  TAXUD,  including 
technical  and  administrative  assistance,  is  highly  valued  by  Member  States,  despite  some 
administrative  burdens.  However,  there  is  a  need  for  clearer  procurement  guidelines  from  the 
Commission  regarding  permissible  equipment  and  suppliers.  The  CCEI  Coordination  Group 
serves  as  a  collaborative  platform,  though  there  is  room  to  enhance  its  effectiveness  through 
specialised  working  groups.  Regarding  synergies,  joint  procurement  is  recognised  for  its 
economic benefits, but barriers such as differing national legislation and the limited number of 
suppliers hinder its full realisation. Some Member States suggest a harmonised legal framework 
and  standardised  processes  at  the  EU  level  to  facilitate  joint  procurement,  drawing  parallels  to 

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successful  models  like  the  EU's  COVID-19  vaccine  procurement.  Ultimately,  the  CCEI’s 
joint  procurement, 
principal  activities  are  very  coherent  but  potential  synergies  for 
standardisation and data sharing have not been exploited thus far. 

EQ 12. To what extent is CCEI coherent with relevant Customs Union and wider EU policies, 
programmes, funds and instruments, and maximising synergies in practice? 

In  contrast  with  the  internal  coherence  of  the  Instrument,  which  is  straightforward  to  evaluate 
due  to  the  relative  simplicity  of  the  delivery  model,  Commission  documentation  consistently 
emphasises  the  CCEI’s  external  coherence  and  the  importance  of  the  interconnectedness  with 
other policies and programmes in Customs and beyond.  

As stated in the CCEI’s 2023-24 MAWP, “the CCEI programme will continue feeding into the 
wider Commission agenda and will create synergies with other Union programmes, such as the 
EU Anti-Fraud Programme, the Border Management and Visa Instrument (BMVI), the Internal 
Security  Fund  (ISF),  the  Recovery  and  Resilience  Facility  (RRF),  Horizon  Europe,  and  the 
Technical  Support  Instrument (TSI). Complementarities with  these programmes are very much 
encouraged  and  will  ensure  the  Union  added  value  of  the  CCEI”.  This  EQ  will  analyse  these 
complementarities firstly with the Customs Programme followed by numerous other policies and 
programmes. The EQ will first look at the theoretical complementarities which the Commission 
is trying to achieve before, using figure below, highlighting Member States' awareness of these 
linkages, before examining evidence of concrete practical overlaps or synergies. 

Figure 25: Responses  to the questionnaire Q3.6: "The CCEI aims to  complement  a number of 
other sources of EU funding, several of which are listed below.  Can you indicate whether you / 
colleagues working with the CCEI are aware of these initiatives?” 

Source: Questionnaire responses from national customs administrations. 

Extent to which CCEI is coherent with EU customs policy and wider policy priorities 

Wider  EU  customs  policy  is  covered  extensively  in  the  relevance  EQ  which  finds  that  the 
Instrument is relevant to the broader objectives of customs policy, thus implying a high level of 
coherence  with  them.  Instead,  the  analysis  below  covers  the  coherence  with  the  Customs 
Programme.  The  Customs  Programme  is  an  EU  funding  programme  which,  inter  alia,  aims  to 
foster  cooperation  amongst  Member  State  Customs  Authorities.  As  the  2023  Annual  Progress 
Report  explains,  the  CCEI  has  a  “specific  focus”  of  funding  the  purchase  of  equipment  while 

110 

 
 
“complementing and supporting actions” such as training and knowledge exchange activities are 
supported by the Customs Programme.  

This distinction has helped to clearly demarcate the types of activities which should be carried 
out  under  each  Instrument,  reducing  the  possibility  of  overlap.  This  is  reinforced  by  the 
Regulation which stipulates that “an action that has received a contribution under the Instrument 
may  also  receive  a  contribution  from  the  Customs  programme  or  from  another  Union 
programme, provided that the contributions do not cover the same costs”. In practice, almost all 
of the Member State questionnaire respondents (97%) were aware of the Customs Programme, 
suggesting that this complementarity and the respective functions of the two policies are clear to 
nearly all of the Member States.  

Furthermore, several responses highlighted specific synergies between the CCEI and aspects of 
the Customs Programme, such as trainings, meetings, and expertise sharing bodies like CLET, 
CLEN, and CELBET.  

•  There  is  evidence  of  some  synergies  with  the  Customs  Laboratories  Expert  Team 
(CLET).  The  CCEI  complements  this  by  enhancing  operational  cooperation  and 
analytical  capabilities  within  the  customs  laboratories  across  the  European  Union.  By 
funding  new  equipment,  the  CCEI  bolsters  CLET's  ability  to  support  the  EU's  customs 
laboratories,  thus  harmonising  the  Union's  customs  control  functions.  Synergies  with 
CLET  through  experience  and  knowledge  exchange  was  mentioned  several  times  by 
Member States in the questionnaire.  

•  Similarly, the Customs Laboratories European Network (CLEN) was established in 1999 
to  promote  coordination,  knowledge  sharing,  and  resource  optimization  amongst 
Customs  Labs  aligning  it  closely  with  CCEI's  objectives.  Furthermore,  Commission 
documentation  describes  collaboration  between  the  CCEI  Coordination  Group  and  the 
CLEN, which through practical workshops and bilateral study visits, have facilitated the 
sharing of best practices and expertise. These efforts, also mentioned in the questionnaire, 
collectively  enhance  the  EU's  customs  capabilities,  particularly  in  employing  advanced 
techniques. 

•  Finally, according to the responses to the questionnaire which also asked respondents to 
provide  concrete  examples  of  synergies,  the  CCEI  is  also  aligned  closely  with  the 
Customs  Eastern  and  South-Eastern  Land  Border  Expert  Team  (CELBET)  through 
consistent  collaboration  and  shared  objectives.  Per  the  interview  with  a  CELBET 
representative,  the  body  reportedly  maintains  regular  discussions  with  the  CCEI  CG, 
ensuring that topics related to CCEI remain a permanent agenda item in their meetings, 
fostering ongoing alignment and shared priorities. This synergy is further strengthened by 
CELBET's  effective  network  among  Member  State  experts,  which  facilitates  seamless 
communication  and  support,  especially  during  the  CCEI  funding  application  process. 
Additionally,  CELBET  contributes  to  the  CCEI  procurement  process  by  providing  a 
comprehensive  library  of  model  technical  specifications.  CELBET's  activities,  such  as 
BCP  diagnostics,  procurement,  training,  and  exchanges  of  images,  complement  CCEI's 
objectives,  especially  in  strategic  border  crossing  points  impacted  by  geopolitical 
tensions,  like the Ukraine crisis.  This  coordination supports the EU’s policy priority on 
mitigating  international  conflicts,  as  outlined  in  the  2023-2024  CCEI  MAWP,  and 
enhances the implementation of sanctions and humanitarian aid processes. 

Extent to which CCEI is coherent with other EU programmes, funds and instruments 

In  addition  to  the  Customs  Programme,  the  Commission  aims  to  achieve  complementarities 
between the CCEI and several other key EU programmes, funds and instruments.  

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The  Border  Management  and  Visa  Instrument  (BMVI),  together  with  the  CCEI,  makes  up  the 
two  strands  of  the  Integrated  Border  Management  Fund  (IBMF).  Much  like  the  Customs 
Programme, both of these financial instruments operate at the external borders but their scope is 
different, with BMVI focusing on the control of persons crossing the external borders as well the 
wider concept of European Integrated Border management. The legal basis of both the CCEI and 
BMVI  allow  for  financing  equipment  –  under  certain  circumstances  –  for  the  purposes  of  the 
other  policy  domain.  However,  with  only  45%  of  respondents  (typically  national  CCEI 
coordinators) to the Member State questionnaire indicating an awareness of the BMVI, the level 
of  complementarity  and  synergies  are  still  developing.  Despite  both  funding  instruments  being 
the  two  components  of  the  same  fund,  there  are  no  overlaps  as  the  different  objectives  and 
implementation  approaches  naturally  reduce  the  potential  of  collaboration  between  the  two 
programmes.  This  is  primarily  due  to  the  differences  between  control  of  goods  (CCEI)  and  of 
persons (BMVI).  

Another programme which demonstrated high awareness levels in the evaluation questionnaire is 
the European Port Alliance, with  94% of respondents  indicating awareness.  This  initiative was 
set up to combat drug trafficking and organised crime and is named specifically in the MAWP as 
an initiative which CCEI can contribute to in addition to other strategies such as the EU Strategy 
to tackle Organised Crime 2021-2025, the EU Agenda and Action Plan on Drugs 2021-2025, the 
2020-2025 EU Action Plan against firearms trafficking, the EU Action Plan against trafficking in 
cultural goods.  In addition to the high level of awareness of the EPA amongst Member States, 
there is evidence of synergies with the priorities of the EPA (drugs and drug precursors) being 
explicitly integrated into both the 2023-2024 CCEI MAWP and the objectives of the second call. 
Furthermore, Member States indicated that they had visited major European ports and been able 
to exchange best practices through the Programme.  

Furthermore,  the  CCEI  and  the  EU  Anti-Fraud  Programme  overseen  by  OLAF  demonstrate  a 
clear  complementarity,  effectively  addressing  distinct  yet  interconnected  objectives  within  the 
EU's broader security and customs framework. With 84% of respondents indicating awareness, 
some MS also indicated complementarities as they can receive funding for elements that are not 
covered by CCEI but complement the equipment procured under CCEI (e.g. videorecorder, IT-
equipment,  or  vehicles).  Before  the  establishment  of  the  CCEI  as  a  standalone  instrument, 
OLAF's  programme  was  instrumental  in  supporting  beneficiaries  seeking  funding  for  border 
equipment.  According  to  interviews  with  OLAF  staff,  with  CCEI's  inception,  many  funding 
requests  transitioned  to  this  new  instrument,  allowing  the  Anti-Fraud  programme  to  reallocate 
resources  to  support  other  beneficiaries  (e.g.  other  law  enforcement  agencies.  This  shift 
highlights  the distinct target  groups  of the two programmes:  CCEI  focuses on customs  control 
needs, while the Anti-Fraud Programme broadens its support to include various law enforcement 
sectors.  

The CCEI  also  has the  potential for synergies  with other major EU funding  programmes, with 
55%  of  MS  indicating  awareness  of  the  Technical  Support  Instrument  (TSI)  and  48%  for  the 
Recovery  and  Resilience  Facility  (RRF).  As  set  out  in  the  MAWP,  the  CCEI  is  aligned  with 
these  two  programmes  in  the  sense  that  CCE  can  complement  broader  RRF  and  TSI  projects 
aimed  at  improving  customs  administrations.  Based  on  the  2023-24  MAWP,  there  is 
complementarity in the areas of enhancing cybersecurity, interoperability, and interconnectivity 
among  Member  States  with  the  equipment  financed  through  the  CCEI  contributing  to  the 
objectives  of  these  programmes.  There  is  significant  potential  for  synergies  with  these 
programmes  as  they  can  fund  aspects  of  customs  control,  most  notably  infrastructure 
improvements,  that  stakeholders  have  repeatedly  reported  that  they  would  like  to  be  eligible 
under CCEI. One questionnaire response noted the potential use of funds allocated through RRF 
for  the  infrastructure  necessary  to  install  and  operate  equipment  purchased  through  CCEI. 

112 

 
this  potential, 

Despite 
infrastructure 
improvements have been seemingly limited with few examples highlighted in the questionnaire 
and  the  interviews  suggesting  that these  alternative  funding  sources  could  benefit  from  greater 
awareness. 

to  complement  CCEI  funding  with 

investments 

The CCEI and Horizon Europe, the EU’s research and innovation framework programme, have 
demonstrated a number of synergies in customs-related innovation. To prevent funding overlaps, 
DG  TAXUD,  alongside  DG  HOME  and  DG  RTD,  oversees  this  collaboration  by  reviewing 
Horizon  work  programmes  and  encouraging  Member  States  to  link  CCEI  projects  with  EU-
funded  research.  Horizon  Europe  funds  innovative  projects  that  align  with  CCEI's  objectives, 
facilitating  the  integration  of  new  technologies  into  customs  operations  across  the  EU.  This 
includes  projects  like  the  Pan-European  Network  of  Customs  Practitioners  (PEN-CP)  and  the 
Parcel  and  Letter  Security  for  Postal  and  Express  Courier  Flows  (PARSEC),  which  aim  to 
enhance  security  and  operational  capabilities  in  customs  and  foster  innovation  in  EU  customs 
and border management, among many others. 

Despite  an  awareness  of  just  29%  amongst  Member  States,  the  CCEI  also  demonstrates 
synergies with the Connecting Europe Facility (CEF), particularly through invitations to submit 
proposals for projects aimed at enhancing safe and secure mobility. In 2023, a EUR 100 million 
call was launched to develop infrastructure at strategic border crossing points (BCPs), areas that 
are ineligible for CCEI funding. This complements previous efforts in 2022, where CEF funding 
supported  infrastructure  improvements  for  the  Solidarity  Lanes  with  Ukraine.  These  initiatives 
exemplify  a  collaborative  framework  where  the  CEF  enhances  BCP  infrastructure  while  the 
CCEI  provides  additional  security  equipment,  collectively  boosting  capacity  and  efficiency  at 
strategic locations.  

Finally, the interviews indicated that, while there is no direct coordination, the CCEI is aligned 
with  the  World  Customs  Organisation,  particularly  the  integration  of  non-intrusive  inspection 
standards. 

Extent  to  which  synergies  between  CCEI  and  other  initiatives  are  materialising  in  practice. 
Extent  to  which  equipment  purchased  is  shared  with  and  supports  the  work  of  other  border 
authorities. 

While  there  is  little  overlap  between  the  CCEI  and  other  EU  initiatives,  there  is  also  limited 
evidence  of  meaningful  synergies  and  multiplier  effects.  From  the  questionnaire,  it  should  be 
noted  that  a  number  of  respondents  pointed  out  that  they  would  not  be  aware  of  synergies  or 
overlaps  because  the  listed  EU  initiatives  are  generally  handled  by  other  officials  in  their 
national  authorities.  The  Estonian  official  stressed  that  the  exploitation  of  synergies  could 
potentially be improved by working on clearer communication channels, a wider sharing of best 
practices,  or  streamlining  efforts  in  terms  of  timelines,  objectives,  and  criteria  across  the 
different  initiatives.  Finally,  there  is  also  a  coordination  mechanism  established  between  the 
CCEI, OLAF, and DG  HOME which plays a crucial role in  minimising overlaps and ensuring 
that the synergies between these programmes are leveraged. This coordination helps maintain a 
strategic focus on shared objectives, such as enhancing the EU's integrated border management 
capabilities. 

The  overall  efficacy  of  the  CCEI’s  synergies  with  other  programmes  like  the  Border 
Management  and  Visa  Instrument  (BMVI)  is  still  developing.  Enhancing  these  synergies  will 
require  more  streamlined  data  collection  methods,  improved  coordination  among  DGs,  and 
potentially integrating some CCEI activities into broader customs initiatives under the proposed 
EU  Customs  Reform,  which  aims  to  centralise  and  optimise  customs  operations  across  the 
Union.  With  increased  awareness  of  the  BMVI  amongst  CCEI  coordinators  as  well  as 

113 

 
collaboration through joint activities, synergies and progress towards achieving the objectives of 
both programmes is more likely. 

Finally,  one  of  the  key  elements  of  the  CCEI  Regulation  Recital  26  for  the  evaluation  was  to 
explore  the  extent  to  which  the  CCE  is  shared  with  other  border  authorities  both  within  and 
between  Member  States.  The  responses  to  the  questionnaire  about  the  sharing  of  equipment 
financed under the Customs Control Equipment Instrument (CCEI) with other border authorities 
highlight several key points.  

Firstly, many Member States have not yet shared equipment financed under the CCEI with other 
border authorities. This is often due to the specific nature of the equipment, which is tailored for 
customs  use  and  requires  trained  personnel  for  operation.  The  equipment,  such  as  X-ray 
machines  and  other  detection  tools,  is  often  just  used  by  customs  administrations  as  these 
specialised items are limited in their usefulness elsewhere outside the customs mandate.  

However, there are examples where cooperation does occur. In Spain, for instance, baggage X-
ray machines are operated by the Guardia Civil in  customs areas, demonstrating some level  of 
inter-agency  collaboration  while  Romania  conducted  joint  risk  analyses  with  other  authorities 
under a government ordinance. Some Member States have agreements in place that allow other 
state  authorities  like  police  or  consumer  protection  agencies  to  benefit  from  the  equipment 
through  mutual  agreements.  While  sharing  between  Member  States  seems  to  be  almost  non-
existent, the questionnaire found that, upon request of DG TAXUD, and within the framework of 
Cyprus Maritime Corridor, the  Italian Authorities  lent Cyprus a scanning  equipment  from  July 
2024 to March 2025. However, legal and practical barriers also play a significant role in limiting 
equipment sharing. In Greece, for example, a separate legal agreement would be required for co-
sharing  between  Member  States,  which  can  be  a  lengthy  process  highlighting  the  need  for 
streamlined legal frameworks to facilitate inter-agency collaboration.  

In summary, while there is potential for the shared use of equipment, it is often limited by the 
equipment's  specialised  nature  and  the  operational  requirements  of  customs  authorities. 
Nonetheless,  the  examples  of  cooperation  and  openness  to  future  collaborations  suggest 
pathways  to  enhance  inter-agency  synergy  and  maximise  the  utility  of  customs  control 
equipment. 

Summary response  

The CCEI is coherent and complimentary with both the Customs Programme and several others 
highlighted above. Stakeholders are aware of the Customs Programme and, in several instances, 
have enjoyed the synergies between the two programmes through trainings, meeting and sharing 
of best practices. There is also considerable potential for synergies with other programmes such 
as the TSI and RRF which could  provide funding for key needs (such  as infrastructure and  IT 
systems) which stakeholders would like to be included in the CCEI. However, there is a distinct 
paucity of actual examples of these synergies notwithstanding the Anti-Fraud Programme which 
has funded equipment which is not eligible under CCEI but very useful to Member States.  

into 

the  design  of 

the  CCEI,  emphasising 

The  need  for  external  coherence  with  various  EU  policies,  programmes,  and  funds  was 
considered  and  built 
importance  of 
interconnectedness.  The  CCEI  aligns  with  other  EU  programmes  such  as  the  EU  Anti-Fraud 
Programme,  the  Border  Management  and  Visa  Instrument  (BMVI),  and  others,  aiming  to 
complement  these  through  synergies  and  reduce  overlaps.  The  CCEI's  focus  on  funding 
equipment  is  distinct  from  the  Customs  Programme,  which  handles  training  and  knowledge 
exchange,  ensuring  clear  demarcation  and  preventing  overlap.  Member  States  have  noted 
synergies with initiatives like the Customs Laboratories Expert Team (CLET) and the Customs 
Laboratories  European  Network  (CLEN),  enhancing  operational  cooperation  and  analytical 
capabilities.  

the 

114 

 
The  CCEI  aligns  with  several  EU  programmes,  though  awareness  and  implementation  of 
synergies  vary.  The  CCEI,  along  with  the  Border  Management  and  Visa  Instrument  (BMVI), 
forms  part  of  the  Integrated  Border  Management  Fund,  allowing  potential  resource  sharing, 
although  awareness  and  synergy  levels  are  currently  low.  High  awareness  exists  for  the 
European Port Alliance, which aligns with CCEI’s objectives against organised crime. The CCEI 
complements  the  EU  Anti-Fraud  Programme,  with  distinct  target  groups,  enhancing  resource 
allocation  across  border  and  law  enforcement  needs.  The  insight  that  equipment  that  was  not 
eligible to be funded under the CCEI but nonetheless very complimentary to the list of CCE was 
an example of a synergy that could potentially be replicated. Despite synergy potential with the 
Technical  Support  Instrument  and  Recovery  and  Resilience  Facility  for  infrastructure 
improvements,  current  integration  is  limited.  The  CCEI  and  Horizon  Europe  collaborate  on 
customs  innovations,  while  the  Connecting  Europe  Facility  complements  infrastructure  at 
strategic border points. Coordination with the World Customs Organisation further supports non-
intrusive  inspection  standards.  Enhanced  communication  and  harmonised  processes  across 
initiatives could improve synergy exploitation.  

Equipment  sharing  with  other  border  authorities  within  and  between  Member  States  is  limited 
due  to  the  specialised  nature  of  the  equipment  and  legal  barriers.  However,  instances  of 
cooperation, such as Spain's use of baggage X-ray machines by the Guardia Civil and Cyprus's 
temporary  borrowing  of  scanning  equipment,  indicate  potential  for  enhanced  inter-agency 
collaboration.  Streamlined  legal  frameworks  and  improved  coordination  could  foster  greater 
synergy and maximise the benefits of customs control equipment. 

115 

 
 
 
EU Added Value 

Table 18: Evaluation matrix for EU added value 

Evaluation questions 

Judgment criteria 

Indicators 

Data sources 

13. What has been the EU 
added value of the CCEI 
compared to what could be 
achieved by the MS at 
national level?  

Extent to which CCEI 
funding has been 
additional and leveraged 
national funding (rather 
than replacing national 
funding), cost savings 
and/or economies of 
scale generated 

Summary of key findings from relevance, 
effectiveness and efficiency 
Role of CCEI in helping the MS to achieve 
value for money in the purchase of customs 
control equipment 
Evidence / examples of the state of play 
compared to a situation if no CCEI funding 
had been available  

•  Answers to other 

evaluation questions 

• 

Stakeholder interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies 

Extent to which the CCEI 
has created opportunities 
for customs authorities to 
act as one, e.g., through 
increased collaboration, 
data sharing and 
interoperable and mobile 
equipment 

Extent to which the CCEI 
has enabled the MS to 
address mutual 
challenges, e.g., joint 
procurement, co-sharing, 
testing, innovation 

Extent to which the CCEI 
led to unexpected effects 
(positive or negative) 

14. How could the CCEI be 
better exploited to add value 
in the context of the EU 
Customs Reform? 

Extent to which CCEI 
has untapped potential 

Summary of key findings from relevance, 
effectiveness and efficiency 
Role of CCEI in fostering collaboration 
and data sharing 
Evidence / examples of the state of play 
compared to a situation if no CCEI funding 
had been available 

•  Answers to other 

evaluation questions 

• 

Stakeholder interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies 

Summary of key findings from relevance, 
effectiveness and efficiency 
Role of CCEI in addressing mutual 
challenges 
Evidence / examples of the state of play 
compared to a situation if no CCEI funding 
had been available 

•  Answers to other 

evaluation questions 

• 

Stakeholder interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies 

Evidence / examples of unexpected 
benefits (e.g. safety and health benefits for 
users of the purchased equipment, greener 
equipment)  
Evidence / examples of any unintended 
negative consequences, such as substation 
effects of equipment that would have been 
purchased anyway 

Steps taken / planned towards facilitating 
joint procurement 
Possible interactions / synergies between 
CCEI and a future EU Customs Agency 
and / or Data Hub 

•  Answers to other 

evaluation questions 

• 

Stakeholder interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies 

•  Answers to other 

evaluation questions 

• 

Stakeholder interviews 

•  MS questionnaire 
responses  

• 

In-depth case studies 

EQ 13. What has been the EU added value of the CCEI compared to what could be achieved by 
the MS at national level? 

This question hinges on the ‘additionality’ of the CCEI, meaning the extent to which it not only 
is  addressing  real  needs  and  making  progress  towards  its  objectives  (assessed  under  relevance 
and  effectiveness,  respectively),  but  also  catalysing  achievements  that  would  not  have  been 
possible  through  other  means.  The  assessment  focuses  on  the  additionality  of  the  equipment 
purchased, cost savings, taking advantage of opportunities for customs authorities to act as one, 
enabling of customs authorities to address mutual challenges, and any unexpected effects. Aside 
from  synthesising  the  relevant  elements  from  other  evaluation  questions,  the  various  data 
collection tools also contained dedicated questions on additionality; the in-depth case studies are 
particularly  important  in  this  respect,  since  these  allowed  for  exploration  of  what  would  have 
happened in specific situations without CCEI funding.  

116 

 
Extent to which CCEI funding has been additional and leveraged national funding (rather than 
replacing national funding)  

As noted in EQ 1, the two CCEI calls to date have led to the allocation of over EUR 550 million 
of  EU  funding,  which  has  already  been  or  is  expected  to  be  used  for  the  purchase  of  customs 
control  equipment.  However,  to  be  truly  ‘additional’,  the  EU  funding  needs  to  be  used  for 
purchases that would not  have been possible from  national  budgets  or other sources. Since the 
evaluation  lacked  access  to  data  on  national  budgets  or  decision-making  processes,  the 
assessment is based largely on the grant documentation and input from stakeholders.  

In  the  first  instance,  an  imbalance  in  the  financial  resources  available  for  customs  control 
equipment  was  a  frequently  raised  issue  during  the  evaluation.  For  example,  nearly  80%  of 
customs authorities responding to the questionnaire cited this as a ‘very’ (48%) or ‘quite’ (29%) 
important  issue.  This  concern  was  echoed  in  the  open  replies,  with  several  Member  States 
identifying financial imbalances as a critical problem, since ‘the Customs Union is only as strong 
as  its  weakest  link’.  Many  interviewees  from  customs  authorities,  European  institutions  and 
international  organisations  expressed  a  similar  view.  The  implication  is  that  many  customs 
authorities  would  not  have  been  able  to  mobilise  the  resources  needed  for  adequate  customs 
control equipment without outside funding.  

That  said,  it  also  bears  mentioning  that,  in  their  applications  under  the  first  and  second  calls, 
customs administrations were not required to demonstrate a need for financial support as such. 
Rather,  funding  could  be  awarded  as  long  as  the  equipment  itself  was  needed,  regardless  of 
whether customs authorities had the means to purchase the equipment anyway.  

From  this  it  follows  that  levels  of  additionality  would  be  expected  to  differ  depending  on  the 
circumstances and needs of individual  customs authorities. This  indeed appears to  be the  case, 
with  the  Member  States  falling  broadly  into  two  groups.  The  first  group  is  comprised  of 
countries for which CCEI funding clearly enabled (or is in the process of enabling) purchases of 
customs  control  equipment  that  would  not  have  been  possible  from  other  sources.  The 
questionnaire  results  suggest  that  most  Member  States  fit  this  description.  Almost  two  thirds 
(61%) of respondents reported that, without the CCEI, their customs authorities would not have 
been able to purchase the requested equipment. Only 9% were of the opposing view, while the 
remaining 29% were either neutral, unsure, or didn’t respond. High levels of additionality were 
also evident in six of the ten case studies of specific grants,  namely Belgium, Croatia, Estonia, 
Finland, Poland and Romania. 

Among the grants demonstrating high levels of additionality, a unifying theme was of significant 
equipment needs combined with lacking resources at national level. All but one of the case study 
grants  in  this  category  possess  important  land  borders  with  third  countries,  while  the  other 
(Belgium)  is  the  site  of  one  of  the  EU’s  largest  container  ports.  Four  of  the  grants  were  also 
among the largest from the first call in terms of monetary value; the other two were for Estonia 
and  Croatia,  both  small  Member  States.  Customs  authorities  in  all  six  of  these  countries 
emphasised urgent needs, e.g., due to continued reliance on equipment that was obsolete and / or 
had  exceeded  its  expected  lifecycle.  It  is  also  telling  that  these  six  grants  were  all  subject  to 
delays.  While  negative  from  an  implementation  perspective,  this  seems  correlated  with  high 
levels of additionality (albeit indirectly and perhaps counterintuitively), because Member States 
that  dared  to  go  outside  their  comfort  zones  with  ambitious  funding  requests  frequently 
experienced difficulties to put these plans into action. Still, despite timescales that were longer 
than expected, the case studies provide compelling evidence that these grants will ultimately lead 
to the purchase and deployment of equipment that would not have materialised otherwise. 

117 

 
 
In  contrast,  the  other  four  of  the  case  studies  –  Austria,  Italy,  the  Netherlands  and  Spain  – 
covered equipment needs that national officials admitted would have been met regardless of the 
CCEI.  The  specific  circumstances  differed  to  a  degree;  for  example,  in  some  cases  the  CCEI 
funding  was  simply  used  to  help  implement  equipment  modernisation  plans  that  had  already 
been  approved  and  launched.  In  other  cases,  the  availability  of  EU  funding  allowed  customs 
authorities  to  speed  up  /  bring  forward  equipment  purchases  that  might  have  been  spread  out 
over a few years. Given the importance of maintaining a high  level  of control at  all times, the 
role of the CCEI in allowing these Member States to deploy needed equipment more quickly is 
also a form of additionality that should not be underestimated. In this respect, it is worth pointing 
out that only one of the four grants in this group was delayed.  

Of course, the picture is not fully black and white. For example, customs authorities from several 
Member  States  explained  that,  even  if  they  would  have  been  able  to  purchase  the  requested 
equipment without EU co-funding, the CCEI served to elevate customs control equipment on the 
political  agenda,  incentivising  customs  to  strive  for  more  ambition  and  ‘protecting’  against 
budget  cuts.  On the other hand, as discussed in  EQs 1 and 9, not  all purchases enabled by the 
CCEI have addressed the most urgent needs and priorities of the Customs Union. In such cases, 
the  equipment  may  have  been  ’additional’  without  achieving  the  maximum  added  value  that 
could have been achieved with the funding. 

Extent to which the CCEI has generated cost savings and / or economies of scale 

In  principle,  the  CCEI  could  also  generate  EU  added  value  by  saving  money  for  the  Member 
States.  Several  pathways  to  these  savings  could  be  foreseen.  At  a  basic  level,  the  CCEI 
Coordination  Group  aims  to  serve  as  a  forum  for  pooling  knowledge  on  customs  control 
equipment  and  on  procurement,  which  could  help  the  Member  States  to  develop  tender 
specifications  and  run  procurement  processes  more  efficiently.  Increased  standardisation,  if 
achieved, could also reduce the costs charged by suppliers, while joint procurement would aim, 
inter alia, to give purchasers more bargaining power and drive down costs.  

In  practice,  the  first  of  these  pathways  seems  to  have  been  materialised.  Asked  in  the 
questionnaire  about  whether  the  CCEI  Coordination  Group  is  an  effective  forum  for 
collaboration,  the  vast  majority  either  ‘strongly’  (29%)  or  ‘tended  to’  (55%)  agreed.  In  the 
interviews, several customs authorities further explained that the expertise, advice and templates 
/ sample material shared in the Coordination Group  served to reduce costs at national level for 
the drafting of tender specifications, management of procurement processes, and dealing with of 
suppliers.  This  was  especially  appreciated  by  smaller  Member  States,  which  lack  in-house 
capacity.  Aside  from  saving  time  in  the  first  instance,  this  also  meant  decreased  chances  of 
unsuccessful procurements and litigation. In addition, the more targeted approach of the second 
call  for  proposals,  which  included  specific  recommendations  to  Member  States  and  increased 
guidance in areas like security specifications, was seen as a further step forward. However, the 
scale  of  these  types  of  savings  has  been  limited  because  they  have  not  affected  in  any 
fundamental ways the processes for procuring and deploying customs control equipment, which 
are where most costs are incurred.  

Turning to the savings that could potentially result from either standardisation of equipment or 
joint  procurement,  these  remain  largely  unrealised.  Regarding  standardisation,  although  many 
questionnaire respondents (55%) agree that this is occurring through the CCEI, no interviewees 
felt that it was helping to obtain lower prices. For its part, joint procurement is permitted in the 
CCEI Regulation  and has been a topic of discussion in the Coordination Group and of a study 
procured by DG TAXUD, and many officials responding to the questionnaire and taking part in 
interviews  have  mooted  its  future  promise,  especially  for  less  tailored  types  of  equipment  like 
handheld  scanners.  The  potential  benefits  from  central  purchasing  by  the  Commission,  if 

118 

 
facilitated by the proposed EU Customs Reform, also attract considerable enthusiasm. However, 
these benefits remain theoretical in the absence of any concrete attempts to actively promote or 
enable joint procurement at this stage.  

Extent to which the CCEI has created opportunities for customs authorities to act as one 

In light of the EU’s common external border, a key part of the mission of EU customs is for the 
27  customs  authorities  to  increasingly  act  as  if  they  were  one.  The  CCEI  specific  objective 
envisages  progress  towards  this  mission  through  enabling  purchases  of  customs  control 
equipment,  which  in  turn  aim  to  reduce  disparities  between  Member  States  and  contribute  to 
achieving a unform level of control.  

As  discussed  under  EQ  1,  the  CCEI  has  been  progressing  towards  its  objectives  relatively 
effectively,  albeit  slowly,  due  mainly  to  problems  and  delays  experienced  with  national 
procurement processes. Still, this was attributed to external factors rather than design flaws in the 
CCEI. Encouraging early results were noted, alongside beneficiaries’ confidence that the CCEI 
will  make  a  significant  contribution  over  time  to  its  objective  of  achieving  adequate  and 
equivalent  results  of  customs  controls.  This  is  a  positive  finding,  though,  as  discussed  under 
additionality, it could be questioned whether CCEI funding is always used to maximum effect, 
while most impacts are still yet to emerge.  

In theory, the CCEI  could  also  foster other opportunities for customs authorities to  act  as one, 
such as through increasing cooperation between customs authorities, standardisation of customs 
control  equipment,  and  sharing  of  data  and  actual  equipment.  On  the  first  of  these,  the  CCEI 
Coordination  Group  has  become  a  key  forum  for  exchange  on  matters  concerning  customs 
control  equipment,  as  noted  above  (though  other  fora  such  as  CELBET  and  CLEN  also  play 
important roles in this respect). Almost half of questionnaire respondents (49%) also agreed that 
the  CCEI  had  led  to  more  practical  cooperation  between  customs  authorities.  As  mentioned 
above, nearly two thirds (55%) also felt that the CCEI had led to increased standardisation of the 
equipment.  

However, when it comes to operational collaboration, examples of impact are extremely limited. 
Just  26%  of  questionnaire  respondents  agreed  that  the  CCEI  had  led  to  more  data-sharing,  of 
which only 10% ‘strongly’. Despite the role of EU co-funding and a general enthusiasm to work 
more together, the bottom line is that decisions on the equipment to be purchased and its use are 
made overwhelmingly in the national arena. This is in line with the implementation modality of 
the CCEI, which relies on the Member States to procure the equipment, and policy on customs 
controls  more  broadly.  In  this  regard,  interviewed  officials  expressed  little  awareness  for  how 
data  or  equipment  could  be  shared  or  the  legal  and  practical  protocols  for  doing  so. 
Cybersecurity  concerns  and  closed  IT  environments  were  also  mentioned  as  obstacles,  as  was 
(by fewer customs administrations) the ineligibility for CCEI funding of IT infrastructure, which 
in principle could be used to build and maintain connections for sharing data between countries. 
More positively, as discussed in EQ 14 below, questionnaire respondents and interviewees also 
pointed out that ongoing policy developments could help bring a more European character to the 
environment for customs control equipment, namely if the proposed EU Customs Reform leads 
to the establishment of an EU Customs Agency and EU Data Hub.  

Extent to which the CCEI has enabled the Member States to address mutual challenges 

As noted in the previous two judgement criteria, the Member States have generally been using 
the  CCEI  to  purchase  equipment  that  is  genuinely  needed.  The  CCEI  has  also  been  making 
progress  towards  its  specific  objective,  the  pace  of  which  is  expected  to  increase  over  time  as 
more and more equipment is purchased and deployed. Since the challenges faced by individual 
Member States are by definition also challenges facing the Customs Union, the CCEI can be said 
to be adding value in this regard. 

119 

 
However, it should also be emphasised that the CCEI’s relatively bottom-up, open approach has 
given  the  Member  States  significant  discretion  to  decide  on  which  equipment  priorities  to 
pursue.  This  was  particularly  true  of  the  first  call  for  proposals,  which  focused  on  countries’ 
short-term priorities; the second call targeted specific policy priorities, while the Member States 
also  had  to  take  into  account  individual  recommendations  from  DG  TAXUD  in  their  grant 
applications. Still, both calls were open to all Member States (vast majorities of which chose to 
participate  in  each  case)  rather  than,  say,  priority  countries  or  BCPs.  Moreover,  even  for  the 
second  call,  the  priorities  were  sufficiently  broad  such  that  most  types  of  eligible  equipment 
could  reasonably  be  justified.  In  contrast,  the  CCEI  expressly  did  not  dictate  in  a  top-down 
manner  which  equipment  should  be  purchased  and  where  it  should  be  deployed.  Moreover,  as 
explained  in  the  first  judgement  criterion,  the  additionality  of  the  funding  varied,  with  some 
purchases  being  truly  dependent  on  the  EU  funding  and  others  that  would  have  taken  place 
anyway.  

Leading  from  this,  it  is  difficult  to  determine  the  appropriate  amount  of  steering  and 
prescriptiveness.  On  the  one  hand,  a  more  centralised,  top-down  approach  could  in  principle 
result in a more efficient allocation of resources and better addressed the challenges facing the 
Union  as  a  whole.  On  the  other  hand,  the  national  competence  for  customs  controls  limits  the 
amount  of  steering  that  would  be  politically  and  legally  feasible,  and  providing  all  Member 
States with the opportunity to take part helps ensure wide support for the instrument. Since DG 
TAXUD lacks comprehensive and accurate data on existing equipment deployments and needs, 
it would also be difficult to take all decisions at EU level. A balance probably needs to be struck, 
and  the  second  call  looks  like  a  step  in  the  right  direction,  even  if  somewhat  more 
prescriptiveness would probably be desirable, as argued in EQ 1.  

Aside from setting priorities for the equipment to be purchased, there are other areas where the 
CCEI  could  have  gone  further  to  help  the  Member  States  address  common  challenges.  A 
particular  concern  has  been  procurement.  Combined  with  cybersecurity  risks,  questionnaire 
respondents  and  interviewees  repeatedly  singled  this  out  as  a  problematic  area  which,  due  to 
limited capacity and expertise, frequently led to delays, litigation, cancellations and relaunched 
procurements,  etc.  More  guidance  and  potentially  requirements  in  this  area  would  have  been 
appreciated  and  increased  the  added  value  of  the  instrument.  In  the  area  of  innovation,  aside 
from  encouraging  and  allowing  the  purchase  of  innovative  equipment,  the  CCEI’s  role  in 
spurring  progress  seems  to  have  been  limited.  A  similar  situation  has  prevailed  for  joint 
procurement,  which,  as  mentioned  above,  has  been  discussed  extensively  in  the  CCEI 
Coordination Group and been the subject of a dedicated study, but not yet been attempted within 
the frame of the programme.  

Extent to which the CCEI led to unexpected effects (positive or negative) 

The CCEI is a relatively straightforward intervention in that it has one main activity, which is the 
provision of financial support for the Member States to purchase, maintain and upgrade customs 
control  equipment.  This  simple  structure  limits  the  scope  for  unexpected  effects,  very  few  of 
which were identified in the evaluation, either positive or negative. 

Of those that could be found, the main ones were negative and relate to the relative flexibility of 
the instrument. As noted above under additionality, Member States need to justify the need for 
the requested equipment, but not for the funding as such. In some cases, this has led to the ‘mere’ 
displacement  of  national  funding,  which  is  obviously  not  the  intention  of  the  CCEI.  Similarly, 
once a grant has been awarded and signed, Member States are able to request significant changes 
to the equipment to be purchased without adjusting the monetary amount of a grant. While it is 
important  for  customs  authorities  to  be  able  to  adapt  plans  to  shifting  circumstances,  customs 
authorities may face an incentive to retain the secured funding, which in some cases appears to 

120 

 
lead  to  outcomes  unrelated  to  the  original  funding  application.  For  example,  one  case  study 
involved a large grant that was originally intended for the purchase of equipment for several land 
borders  with  Russia  that,  though  formerly  busy,  were  subsequently  closed  due  to  the  war  in 
Ukraine. Rather than revising the grant amount downwards, the funds were redeployed to other 
BCPs in the same country, where the needs may not have been as great. These examples add to 
the  point  above  in  implying  that  the  instrument  would  be  better  served  in  shifting  the  balance 
between flexibility and prescriptiveness / control towards the latter, at least to a degree. 

Summary response 

It was assessed to what extent the CCEI has added value beyond what the Member States could 
achieve on their own. The first and perhaps most fundamental judgement criteria is additionality, 
meaning whether the funding leveraged rather than replaced national  funding. Given that grant 
applications needed to demonstrate a need for the equipment rather than for the funding as such, 
and  that  the  availability  of  resources  differs  by  country,  it  would  be  expected  that  levels  of 
additionality would also vary. This turned out to hold in practice: the questionnaire results and 
case  studies  showed  that  most  customs  authorities  would  not  have  been  able  to  make  the 
purchases of the funded equipment without the CCEI, with especially high additionality among 
countries facing significant needs combined with a lack of resources. However, there were also 
examples  where  customs  authorities  would  have  gone  ahead  anyway,  either  on  the  same 
schedule or with a longer time frame. Such examples were relatively rare and still helped elevate 
customs  control  equipment  on  the  political  agenda,  leading  to  higher  levels  of  ambition  and 
reducing risks of future budget cuts. 

The ability of the CCEI to generate cost savings and / or economies of scale was also examined. 
The CCEI Coordination Group has enabled such savings to a certain extent, by pooling expertise 
in  a  way  that  helps  national  customs  authorities  –  especially  those  with  limited  capacity  –  to 
reduce  costs  for  drafting  tender  specifications,  managing  procurement  processes  and  dealing 
with  suppliers.  However,  the  greater  savings  that  could  be  hoped  for  from  standardising 
equipment or joint procurement remain to be realised.  

To some extent  the CCEI has created opportunities  for customs authorities to  act  as one, most 
notably  through  the  progress  made  towards  its  specific  objective  of  enabling  purchases  of 
customs  control  equipment,  which  in  turn  reduces  disparities  between  Member  States  and 
increases the uniformity of controls. The CCEI is also fostering increased cooperation between 
customs  authorities  and 
increased  standardisation  of  equipment.  However,  operational 
collaboration  still  appeared  limited,  particularly  regarding  the  sharing  of  data  or  actual 
equipment. 

Regarding the CCEI’s role in helping the Member States to address mutual challenges, progress 
towards its specific objective also implies added value in this area, since the challenges faced by 
the Member States also affect the Customs Union. However, it was also found that the CCEI’s 
bottom-up approach, has the disadvantage of not necessarily steering funding to the equipment 
and locations where the Customs Union (rather than individual Member States) is in most need. 
The CCEI could  also potentially have provided more guidance in the field of procurement, for 
which  many  customs  authorities  faced  problems  that  led  to  delays  and  extra  costs.  Joint 
procurement and innovation are also areas of untapped potential.  

Finally, regarding unexpected effects, the relatively simple structure of the CCEI has served to 
limit the scope of these. The only notable exceptions relate to the flexibility of the instrument. In 
some  cases  this  has  allowed  the  funding  of  projects  that  are  not  additional  but  rather  replaced 
national  resources,  as  noted  above.  In  addition,  the  ability  to  revise  the  equipment  to  be 
purchased during the lifetime of a grant, without changing the amount, may in some cases have 
led to purchases where needs were not sufficiently great. 

121 

 
EQ 14. How could the CCEI be better exploited to add value in the context of the EU Customs 
Reform? 

Unlike the other evaluation questions, which have looked backward to assess the CCEI during its 
first years of operation, this last question is about the future. More specifically, it considers how 
the  CCEI  could  be  better  exploited  to  add  value  in  light  of  the  EU  Customs  Reform,  an 
ambitious  proposed  initiative  that  aims  to  further  harmonise  customs  practice  in  the  EU  and 
make it more risk-based and data-driven. The question is necessarily hypothetical in nature, since 
the reform was still under negotiation as of  May 2025, and its provisions are not  scheduled to 
apply  until  after  the  current  programming  period.38  Nonetheless,  it  is  useful  to  reflect  ways  in 
which the CCEI could potentially add more value once the envisaged changes are in place.  

As  a  starting  point,  it  is  worth  recalling  some  of  the  CCEI’s  main  shortcomings  and  areas  of 
limited progress to date. These include a lack of targeting, insufficient procurement guidance and 
limited use of the programme to foster standardisation, innovation, data sharing and operational 
collaboration.  On  top  of  this,  joint  procurement,  though  seen  as  a  potential  avenue  for  further 
progress in all of these areas as well as a way to improve customs authorities’ bargaining power 
and increase efficiency, is still in its infancy. 

Of the wide range of legislative and procedural novelties envisaged in the EU Customs Reform, 
a review of the legislation and accompanying legislation, as well as feedback from stakeholders, 
suggests  that  three  of  these  in  particular  could  be  harnessed  to  address  the  CCEI’s  existing 
problems. These are briefly described below, in terms of the nature of the changes compared to 
the current situation, and the potential implications for the CCEI (or a successor instrument) in 
the future:  

•  Harmonisation of customs risk management: under the current Union Customs Code risk 
management  and  controls  are  largely  the  responsibility  of  national  customs  authorities, 
especially for non-financial risks, based on the national risk frameworks and risk engines 
used to target controls. The Customs Reform will change this by introducing provisions 
by which all Member States will  have access  to  real-time data and will be able to  pool 
information to respond more quickly, consistently and effectively to risks and introducing 
a  new  strengthened  risk  management  framework,  which  will  be  based  on  a  common 
prioritisation  of  risks  for  the  whole  EU,  a  mechanism  for  increased  operational 
cooperation.  

o  In  practice,  more  consistency  will  be  needed  in  the  arena  of  customs  control 
equipment, regarding e.g., increased standardisation, the sharing and / or pooling 
of  data,  and  interoperability  and  coordination  between  customs  authorities 
conducting  controls.  To  facilitate  this,  the  CCEI  could  require  authorities 
applying  for  grants  to  purchase  interoperable  equipment  based  on  common 
standards, and to put in place protocols for sharing the images and other relevant 
data produced using the equipment, and for interpreting those images (potentially 
assisted  by  AI).  Such  requirements  could  also  act  as  an  additional  incentive  for 
Member States to take steps towards joint requirements.  

•  Establishment  of  an  EU  Customs  Data  Hub:  the  impact  assessment  for  the  Customs 
Reform  determined  that  traders  currently  need  to  submit  customs  data  to  up  to  111 

38 More specifically, per Article 265 of the proposed legislation, the timeframe for application will see key elements 
–  particularly  the  EU  Customs  Authority  and  EU  Customs  Data  Hub  –  take  effect  on  1  January  2028,  while 
others will progressively be rolled out until 2038. 

122 

 
 
different  IT  systems  and  to  deal  with  the  authorities  in  all  Member  States  where  they 
have operations. While interoperability between certain systems allows some of the data 
involved to be shared, this is seldom the case for the risk data used to target controls and 
images and other information produced using customs control equipment. Cybersecurity 
concerns and national rules and processes pose additional barriers. The introduction of an 
EU  Customs  Data  hub  will  act  as  an  enabler  for  the  harmonised  risk  management 
described above, as well as making it easier for customs authorities to share information 
securely and thereby coordinate and mutually benefit from each other’s controls.  

o  The  Data  Hub  should  increase  the  potential  added  value  of  more  uniform 
approaches to customs control equipment, which would in turn also make it more 
worthwhile  for  the  CCEI  to  prioritise  the  purchase  of  standardised  and 
interoperable  equipment.  Increased  possibilities  for  the  pooling  and  sharing  by 
means  of  the  data  hub  and  coordinated  use  of  data  could  also  spur  innovation 
through the CCEI.  

•  Establishment  of an EU  Customs Authority:  despite the nature of customs policy as  an 
exclusive  EU  competence,  and  the  increased  harmonisation  of  rules  and  processes,  for 
the  most  part  national  customs  authorities  have 
for 
implementation.  The  EU  Customs  Authority  will  change  this  by,  for  the  first  time, 
assigning certain customs operational tasks to a central body. Concretely, these tasks will 
include using the data from the EU Customs Data Hub to conduct EU-level risk analysis 
and make control recommendations to national authorities, and coordinating operations in 
the  event  of  a  crisis.  Potentially,  it  will  also  take  responsibility  for  developing  and 
maintaining  the  EU  Customs  Data  Hub  and  executing  programmes  such  as  future 
iterations of the CCEI.  

responsibility 

retained 

o  The EU Customs Authority is likely to open the door to a myriad of possibilities 
for  the  CCEI.  As  a  centre  of  expertise  on  many  relevant  matters  (including 
technological  developments  and  capabilities,  cybersecurity  and  procurement 
practices),  the  authority  can  ensure  the  use  of  such  knowledge  to  inform  CCEI 
planning,  and  development  of  requirements,  guidance,  templates  etc.  Inter  alia, 
this  could  include  taking  action  to  introduce  standardised  testing  protocols, 
enabling more effective comparisons of equipment.39 Operational staff would be 
able to play a coordinating role vis-à-vis national customs authorities, increasing 
the  chance  that  opportunities  for  sharing  data  and  collaboration  are  grasped.  It 
would also be the central location for enabling the use of shared images, and for 
producing a reference library for both training and interpretation purposes, which 
would in turn help refine algorithms for risk analysis purposes. And finally, were 
the  decision  taking  to  further  streamline  the  procurement  of  customs  control 
equipment, encourage joint procurement or even carry out purchases centrally, the 
EU Customs Authority would be the natural actor to lead these initiatives.  

39 This would be in line with the first recommendation of a recent study carried out for DG TAXUD on customs 
detection technologies: European Commission (2024), Customs control detection technologies: state-of-the-art, 
emerging  customs  control  equipment  and  its  testing,  study  prepared  for  the  European  Commission  by  NTT 
Data.  

123 

 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

The table below summarises the costs and benefits that can be linked to the CCEI, as identified in the evaluation. The early stage of implementation of 
the CCEI made it impossible to comprehensively assess the benefits. Very few projects from the first call have been completed, and the grant agreements 
from  the  second  call  just  started  at  the  end  of  2024  and  the  beginning  of  2025.  In  view  of  this,  the  interim  evaluation  focused  on  assessing  the 
implementation of the CCEI, and documenting early outputs and emerging results to the greatest extent possible, but was not in a position to provide a 
systematic quantitative analysis of wider benefits at this stage. 

As regards the costs, it should be noted that the table does not include the cost of the  instrument itself for the EU budget  (EUR 1,006 million for the 
period 2021-2027). Direct compliance costs (in particular administrative costs for Member States linked to application, grant management and reporting 
processes) were assessed by collecting data on the time spent on different relevant activities via the questionnaire for national customs administrations. 
Interviews were used to follow up, fill gaps and help clarify the interpretation of this data. The data was processed using the EU Standard Cost Model, 
and the cost estimated by multiplying the time required with the average labour cost per hour (including pro-rated overheads). Details are provided in 
Annex 3, as part of the response to EQ 6 (under efficiency).  

124 

 
 
 
 
 
 
 
 
 
 
 
 
Table 19: Overview of costs and benefits identified in the evaluation 

Types of impacts 

Citizens / consumers 

Businesses 

Administrations 

Quantitative 

Comments 

Quantitative 

Comments 

Quantitative 

Comments 

Direct 
compliance 
costs 

Enforcement 
costs 

Indirect costs 

Direct benefits 

Indirect 
benefits 

- 

- 

- 

- 

- 

s
t
s
o
C

s
t
i
f
e
n
e
B

None 

None 

None 

None 

Potentially a wide range of 
economic, environmental and 
social (safety, health) benefits 
from more effective customs 
controls. Customs are involved in 
delivering numerous regulatory 
policies in addition to broader 
safety, security and revenue 
collection tasks. 

- 

- 

- 

- 

- 

None 

None 

None 

None 

Potentially trade 
facilitation benefits 
and from more 
efficient customs 
controls 

Approx. EUR 
610,000 p.a. 

Cumulative cost of the staff time spent 
by the customs administrations of all 27 
EU MS to apply for and implement 
CCEI grants, and take part in CCEI 
management 

- 

- 

- 

- 

None 

None 

More and better CCE available at 
customs administrations (improved 
capacity) contributing to more effective 
and efficient customs controls 

Protection of the financial and economic 
interests of the EU and its MS, ensuring 
security and safety within the Union and 
protecting the Union from illegal trade 
via better detection capabilities 

125 

 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

The synopsis report presents a comprehensive summary of all consultation activities undertaken 
as  part  of  this  evaluation.  It  provides  a  detailed  account  of  the  outcomes  from  all  consultation 
activities  and  seeks  to  inform  stakeholders  about  how  their  input  has  been  integrated  into  the 
evaluation process.  

The  approach  to  stakeholder  consultations  was  three-pronged,  consisting  of  (i)  a  written 
consultation of customs authorities first, complemented by (ii) in-depth interviews and ultimately 
by (iii) a stakeholder workshop with customs administrations to validate the preliminary findings 
and conclusions. These  consultation  activities were carried out  as part of the supporting  study. 
The evaluation was preceded by a call for evidence between June and July 2024. This took place 
via the EU’s Have Your Say Portal and fed into the preparation of the work for the tendering of 
the evaluation’s support study and the work itself.  

Methodology 

Questionnaire 

The questionnaire was designed to collect feedback and evidence from customs administrations. 
A  questionnaire  was  preferred  to  a  survey  under  the  logic  that  it  would  elicit  responses  on  a 
Member State basis and enable respondents to combine input from different officials.  

In order to maximise the usefulness of the questionnaire, several design features were included to 
minimise the burden on respondents while collecting comparable and useful data. In summary, 
these include:  

•  A mix of objective, fact-based information and more subjective input (e.g. on processes 
that have worked  well and less well),  and closed (multiple-choice) and open (free text) 
questions.  Such  an  approach  helped  keep  the  questionnaire  relatively  brief,  which  is 
important given that responses to the questionnaire were needed before proceeding to the 
interviews with a sample of customs authorities;  

•  The use of a Microsoft Word format rather than an online form. While less sophisticated 
than other consultation tools, this avoided the risk that any respondents will be unfamiliar 
with the format, and also facilitates sharing among the different officials who may need 
to collaborate on the questionnaire within customs authorities; 

•  An  emphasis  on  user-friendliness,  with  clear  instructions  for  respondents,  simple 
formatting (e.g. with colour-coding to distinguish question text, multiple-choice and free-
text parts of the document), the inclusion of a glossary to explain the terms used, and pre-
populating of certain questions to the extent possible based on the CCEI monitoring and 
grant data; 

•  An intuitive structure that corresponds to the experiences of customs officials rather than 

evaluation logic; 

•  Support to provide clarification, respond to any questions, talk through the questionnaire 
with any customs officials needing assistance, or even complete the questionnaire orally 
if any administrations lack the time to provide written input. 

The questionnaire included an introduction, as well as sections on the rationale for the CCEI and 
the needs of MS; on participation and results so far; experiences with and views on programme 

126 

 
 
management;  possible  future  developments;  and  a  concluding  section  for  Member  States  to 
provide additional remarks.  

Member  States  received  the  questionnaire  as  an  MS  Word  document.  The  questionnaire  was 
distributed to national CCEI contact points between 6 and 7 November 2024, with a submission 
deadline of 4 December 2024. MS were asked to confirm receipt and their intent to respond. A 
follow-up  was  sent  on  15  November  to  authorities  that  had  not  confirmed.  Personalised 
reminders were sent on 5 December to those who had not submitted their responses or requested 
extensions.  By  9  January  2025,  all  MS  submitted  at  least  one  response,  with  a  total  of  31 
completed questionnaires  received  from  27 MS  (a few MS  chose to  submit  separate responses 
reflecting the views of the officials responsible for BCPs and laboratories).  

Interview Programme 

The  interview  programme  targeted  several  key  groups  in  the  CCE  ‘ecosystem’  including 
representatives  of  (i)  national  customs  authorities,  (ii)  European  Commission  and  other  EU 
institutions  officials,  (iii)  relevant  expert  groups  (e.g.  CELBET)  and  (iv)  the  security  and 
customs  control  industry.  Targeting  these  four  key  stakeholder  groups  allowed  the  research  to 
gather  a  wide  range  of  perspectives,  close  gaps  or  expand  on  key  elements,  and  discuss  key 
issues in greater depth, and with more nuance and openness, than was possible in the responses 
to the written questionnaire.  

In  terms  of  the  sequencing  of  the  interviews,  first  five  familiarisation  interviews  with 
representatives  of  various  DG  TAXUD  units  were  conducted  during  the  supporting  study’s 
inception  phase  to  collect  initial  feedback  and  insight  on  the  instrument’s  genesis,  its  policy 
context, programme management, the data model, and other relevant aspects.  

This was followed by the interview programme ‘proper’, which was conducted in two ‘waves’. 
Wave  1,  which  was  launched  in  November  2024,  included  interviews  that  were  carried  out  to 
inform  the  case  studies  on  ten  selected  CCEI  projects;  this  entailed  consulting  representatives 
(usually  several)  of  the  implementing  national  customs  administrations,  as  well  as  the  DG 
TAXUD project officers who were responsible for each of the projects. In addition, wave 1 also 
targeted  relevant  Commission  services  (such  as  OLAF  and  the  JRC),  the  World  Customs 
Organization,  expert  groups  (e.g.  CELBET)  and  representatives  of  the  customs  control 
equipment industry.  

Wave 2 (launched in January 2025) primarily targeted national customs authorities that were not 
interviewed as part of the case studies, in order to gather additional input from them and, where 
appropriate, follow up, clarify and expand on their questionnaire responses. In total, interviews 
were conducted with representatives of 14 Member States.  

In total 49 interviews were conducted. The table below provides a breakdown of the interview 
programme  outlining  interviews  conducted  per  stakeholder  group.  It  should  be  noted  that,  in 
many cases, interviews involved more than one interviewee; in particular, almost all interviews 
carried  out  to  inform  the  case  studies  were  attended  by  two  or  more  representatives  of  the 
national customs administrations in question. 

Table 20: Overview of the interview programme 

Main groups  

National customs authorities 

Relevant expert groups 

European Commission and other EU Institutions 

Number of Interviews 

 27* 

 2 

 13 

127 

 
Customs control equipment industry 

Total  

 7 

 49 

* As part of the case studies, more than one interview was carried out with a few national customs authorities. In many other 
cases,  two  or  more  officials  took  part  in  the  same  interview.  The  numbers  above  relate  to  the  number  of  separate  interviews 
conducted,  not  the  number  of  participants  (which  would  be  significantly  higher).  All  in  all,  interviews  were  carried  out  with 
representatives of the customs authorities of 24 Member States. 

Workshop 

The  online  workshop,  which  took  place  on  26  February  2025,  was  an  opportunity  for 
representatives of national customs authorities to review, validate, and, where needed, refine the 
preliminary  and  emerging  results  of  the  evaluation.  This  “validation”  workshop  took  place 
during  the  last  phase  of  the  supporting  study,  after  the  data  collection  activities  and  the  initial 
analysis of the data had been completed. The online workshop was arranged and hosted by the 
study team on MS Teams. The agenda included:  

▪  The presentation of the key preliminary findings  

▪  Discussion of the findings in breakout groups  

▪  Plenary  discussion  (including  a  summary  of  the  main  points  from  each  breakout  group 

and a discussion of the future of the CCEI)  

▪  Wrap-up and next steps  

In total, 40 representatives of the national customs administrations of 19 Member States attended 
the workshop (in addition to representatives from DG TAXUD and the study team).   

Results 

Questionnaire 

This section provides a high-level summary of the results per theme.  

Organisation of CCEI within Customs Authorities  

In the introductory section on the internal organisation of customs authorities, the questionnaire 
delved  into  the  rationale  behind  the  CCEI  and  how  the  priorities  of  the  programme  align  with 
those of national authorities.  

The  responses  to  the  first  question  of  this  section  shows  that  the  pre-identified  issues  and 
challenges  are generally of high importance to customs authorities within the EU. While all of 
the  proposed  issues  and  challenges  were  considered  at  least  quite  important  by  a  majority  of 
respondents,  the  greatest  importance  was  attributed  to  the  imbalances  that  exist  between  MS 
when it comes to the controls exercised at the Union’s external borders (45% considered it very 
important  and 39% somehow important).  Highly  important,  in  the  eyes of customs  authorities, 
are  also  the  imbalances  in  financial  resources  surrounding  CCE  (45%),  imbalances  in  the 
administrative  capacity  dealing  with  processes  around  CCE  (42%),  and  imbalances  in  the 
availability  of  CCE  (35%).  Of  slightly  less  importance  appears  to  be  the  insufficient 
standardisation and/or interoperability of CCE, although  still 32% said  it was a very important 
issue.   

Rationale of the CCEI  

The findings from the questionnaire on the rationale of the CCEI reveal several key insights into 
the perspectives of customs authorities within the EU. The pre-identified issues, particularly the 
imbalances  in  controls  at  the  Union’s  external  borders,  financial  resources,  administrative 
capacity,  and  availability  of  customs  control  equipment,  are  seen  as  highly  important  by  the 
majority  of  respondents.  While  most  authorities  agree  on  the  alignment  of  CCEI's  eligibility 

128 

 
criteria  with  their  equipment  needs,  some  express  concerns  about  the  criteria's  breadth, 
particularly  regarding  infrastructure,  software,  and  maintenance  needs  not  being  adequately 
funded.  Moreover,  the  alignment  of  priorities  between  the  EU  and  national  levels  shows  that 
general  safety  equipment  are  well-aligned,  though  innovation  and  green  targets  are  less 
prioritised. Despite a positive view on CCEI's policy priorities, some authorities noted challenges 
in the administrative burden of data collection and the need for more user-friendly budget sheets. 
Additionally,  there  is  a  call  for  regular  updates  to  the  list  of  eligible  equipment  to  incorporate 
emerging challenges and innovative technologies, as well as for support in the infrastructure and 
maintenance  of  CCEI-funded  equipment.  Overall,  while  there  is  significant  alignment  between 
national priorities and the CCEI, certain areas for improvement and adaptation remain crucial for 
future iterations. 

Participation and results to date  

The  questionnaire  results  regarding  the  participation  in  and  outcomes  of  the  CCEI  programme 
reveal  several  insights.  While  grants  awarded  in  the  initial  call  have  progressed  slower  than 
expected,  largely  due  to  procurement  issues  and  national  political  factors,  the  role  of  DG 
TAXUD  is  not  cited  as  a  cause.  Some  Member  States  highlighted  timing  and  procedural 
challenges as reasons for non-participation in early calls. Satisfaction with TAXUD's support is 
generally high, yet obtaining national co-funding and ensuring adequate human resources remain 
significant  hurdles.  Although  the  equipment  funding  aligns  well  with  CCEI  priorities, 
procurement processes at the national level face challenges, especially concerning the exclusion 
of  certain  third-country  providers.  The  programme's  emphasis  on  secure  and  environmentally 
friendly  equipment  is  well-received,  though  more  EU-level  guidance  on  data  protection  and 
cyber  security  is  sought.  Awareness  of  other  EU  funding  initiatives  varies,  with  potential 
synergies  and  complementarities  identified,  particularly  with  the  Customs  Programme  and 
European Ports Alliance. Early feedback suggests the equipment improves customs performance, 
though sharing with other border authorities is limited due to legal and operational constraints. 
External factors like economic uncertainty and security concerns impact the programme's utility 
in  some  regions.  The  CCEI's  value  lies  in  enabling  equipment  upgrades  that  surpass  national 
funding  capabilities,  though  reliance  on  CCEI  funding  sometimes  limits  broader  procurement 
due  to  reduced  national  budget  allocations.  Collaborative  opportunities  within  the  CCEI  are 
positively noted by countries such as Germany and Estonia. 

Management of the CCEI  

The management of the CCEI requires varying amounts of staff resources across Member States 
(MS),  with  managing  active  grants  and  preparing  grant  applications  being  the  most  time-
consuming tasks, requiring on average 60 and 40 staff days annually, respectively. While most 
MS  find  the  resource  demands  manageable,  the  preparation  of  grant  applications  is  noted  as 
particularly  resource-intensive  by  19%  of  respondents,  primarily  due  to  the  burdensome  data 
collection  and  reporting  processes.  Opinions  on  the  management  of  the  CCEI  are  generally 
positive, with  the guidance from DG TAXUD  and the effectiveness  of the CCEI Coordination 
Group  being  well-received.  However,  there  are  calls  for  improvements  in  the  clarity  and 
usefulness  of  Annual  Progress  Reports  and  the  appropriateness  of  monitoring  indicators.  To 
enhance  the  management  and  implementation  of  the  CCEI,  MS  suggest  simplifying  processes 
and reducing administrative burdens, such as minimising the need for extensive statistical data in 
applications.  There  is  also  interest  in  centralising  equipment  procurement  to  improve 
coordination  and  efficiency,  as  well  as  providing  unified  instructions  and  sharing  technical 
specifications to streamline actions on the EU Tender Portal. 

Interviews 

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While  the  most  important  findings  from  the  interview  programme  have  fed  into  the  evidence 
base for the evaluation questions, the thematic headline findings from the interviews for each of 
the different main types of stakeholders are broken down below. 

National customs administrations 

Impact and Benefits of CCEI  

•  Equipment  procurement  and  funding.  CCEI  has  been  pivotal  in  providing  necessary 
funding for customs  equipment,  enabling Member States to  undertake procurement that 
would have been challenging solely through national budgets. This has been particularly 
crucial for countries facing budget cuts due to geopolitical factors. 

•  Enhancement  of  customs  control:  The  programme  has  significantly  enhanced  the 
accuracy  and  efficiency  of  customs  controls.  For  instance,  one  Member  State’s 
acquisition  of  fixed  scanners  allowed  for  better  resource  allocation  and  improved 
detection  accuracy,  while  another's  use  of  substance  detectors  expedited  control 
procedures by reducing reliance on laboratory analyses.  

Challenges and Areas for Improvement  

•  Data  collection  and  reporting.  Member  States  reported  that  the  data  collection  and 
reporting requirements under CCEI were often cumbersome and time-consuming. These 
processes  involved  duplicating  existing  information  and  required  significant  manual 
effort,  diverting  resources  from  core  operational  tasks.  Simplifying  these  requirements 
could  enhance  efficiency  and  allow  customs  authorities  to  focus  on  their  primary 
responsibilities. 

•  Procurement  and  implementation  delays.  Many  countries  faced  challenges  due  to 
complex  procurement  procedures,  rising  equipment  costs,  and  lengthy  tendering 
processes.  

•  Joint procurement challenges. Scepticism about the feasibility of joint procurement was 
expressed by several Member States due to differing national legislation, administrative 
procedures, and security requirements. These differences are seen as significant obstacles 
to successful collaboration. 

Strategic and Operational Considerations  

•  National  vs. EU needs. There is  a recognised need to  balance meeting specific national 
requirements with aligning broader EU goals. Member States emphasised the importance 
of flexibility in eligibility criteria to accommodate diverse national priorities and ensure 
that  EU-wide  objectives  are  met.  Others  pointed  to  the  challenge  of  standardising 
equipment across countries with different needs and operational realities.  

•  Security and geopolitical concerns. Geopolitical tensions, particularly with China and the 
war in Ukraine, have significantly influenced procurement strategies and priorities. These 
factors  have  necessitated  stricter  security  measures  and  a  reassessment  of  equipment 
suppliers.  Some  Member  States  highlighted  the  impact  of  these  tensions  on  their 
procurement decisions, necessitating enhanced security protocols. 

Recommendations and future outlook  

•  Simplification and streamlining: Streamlining data collection and reporting processes is a 
key  recommendation,  with  proposals  for  automated  systems  to  alleviate  administrative 
burdens  and  improve  efficiency.  Denmark  and  Germany  suggested  that  reducing 
redundancy  in  data  requirements  could  free  up  resources  for  more  strategic  activities 
within customs administration. 

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•  Enhancing  knowledge  sharing:  There  is  a  call  for  more  informal  knowledge-sharing 
platforms,  such  as  workshops  and  peer-to-peer  sessions,  to  facilitate  best  practice 
exchanges  and  enhance  collaboration  among  Member  States.  Sweden  and  Ireland 
emphasised  the  value  of  these  exchanges  in  improving  customs  practices  and  fostering 
innovation 

•  Expanding  eligibility  criteria:  Suggestions  include  expanding  CCEI's  scope  to  include 
emerging technologies like AI-powered systems and drones, as well as infrastructure and 
maintenance  costs.  This  would  allow  Member  States  to  better  meet  evolving  customs 
control needs and enhance operational capabilities.  

•  Fostering standardisation and harmonisation: The importance of standardising equipment 
across  the  EU  to  enhance  interoperability  and  ensure  cohesive  customs  operations  is 
emphasized. Some Member States suggested that the Commission play a more active role 
in assessing and coordinating equipment needs to achieve greater standardisation across 
Member States.  

Equipment manufacturers  

More Transparency on Procurement Plans: 

Manufacturers  consistently  highlighted  the  need  for  clearer  information  regarding  upcoming 
CCEI  funding  rounds  and  procurement  plans.  There  is  a  strong  desire  for  better  visibility  into 
which  countries  are  planning  to  procure  equipment  and  the  specific  timelines  for  these 
procurements. Additionally, manufacturers are requesting more detailed breakdowns of funding 
allocations,  not  merely  by  unit  numbers  but  also  by  equipment  type  and  monetary  value.  This 
enhanced  transparency  would  enable  suppliers  to  better  prepare  and  align  their  production 
capabilities with the anticipated demand. 

Greater Standardisation of Requirements: 

Several  manufacturers  noted  the  inefficiencies  and  increased  costs  resulting  from  varying 
specifications  for  similar  equipment  across  different  countries.  To  address  this,  there  is  a 
suggestion  for  the  Commission  to  provide  more  standardised  guidelines  or  a  comprehensive 
"catalogue"  of  approved  equipment  configurations,  which  would  streamline  the  procurement 
process.  Furthermore,  some  manufacturers  propose  the  development  of  common  EU-wide 
standards  for  equipment  performance  and  cybersecurity,  facilitating  a  more  cohesive  and 
efficient procurement environment. 

Increased Engagement Between Commission and Industry: 

Manufacturers are advocating for more direct communication channels with the Commission and 
customs authorities. Suggestions for achieving this  include the organisation of regular industry 
briefings and brokerage events to showcase new technologies. Additionally, there is a call for a 
dedicated point of contact for equipment suppliers, which would facilitate more opportunities for 
manufacturers  to  provide  input  on  technical  specifications  and  future  needs.  Such  engagement 
would foster a collaborative environment and ensure that industry perspectives are considered in 
decision-making processes. 

Mechanisms to Support Innovative Technologies: 

Many companies, particularly those with newer or more innovative products, face challenges in 
getting  their  equipment  recognised  and  eligible  for  procurement  by  customs  authorities.  To 
support innovation, proposals include creating an "other" category for emerging technologies or 
utilising pre-procurement funds to help new technologies achieve licensing and approval. Some 
manufacturers suggest adopting a process similar to the US system, where funding is allocated to 

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develop  solutions  for  specific  challenges,  thereby  encouraging  and  supporting  technological 
advancements. 

Consideration of European Suppliers / Content: 

Concerns have been raised by multiple manufacturers about competition from non-EU suppliers, 
particularly  those  from  China,  who  often  compete  primarily  on  price.  There  is  a  desire  for 
procurement criteria to place greater emphasis on factors such as security, quality, and European 
content, rather than focusing predominantly on price. To support EU strategic autonomy in this 
sector, some manufacturers suggest implementing incentives or preferences for European-based 
manufacturers. 

Improved Clarity on Regulations and Processes: 

Manufacturers have noted difficulties in navigating the different regulations across EU member 
states, especially concerning more sensitive technologies. There is a request for clearer guidance 
on  topics  such  as  licensing  requirements,  cybersecurity  standards,  and  the  process  for  getting 
new technologies approved for CCEI funding. Some suggest that the Commission could play a 
pivotal role in harmonising these requirements across the EU, reducing complexity and ensuring 
consistency. 

Feedback and Continuous Improvement Mechanisms: 

Several  manufacturers  have  recommended  the  implementation  of  systems  that  allow  customs 
authorities to  provide feedback on  equipment  performance. Such feedback could  inform  future 
procurement decisions and assist manufacturers in improving their products. Additionally, there 
is  interest  in  understanding  how  the  CCEI  programme  itself  might  evolve  in  future  phases, 
particularly  in  terms  of  software  and  integration  capabilities.  This  reflects  a  broader  industry 
desire  for  a  more  coordinated,  transparent,  and  innovation-friendly  approach  to  the  CCEI 
programme, while also balancing the needs and autonomy of individual member states. 

Other stakeholders  

CELBET 

CELBET  is  a  specialised  EU  initiative  dedicated  to  enhancing  customs  operations  and  border 
management  across  the  EU's  external  land  borders.  As  it  transitions  into  the  EU  Customs 
Alliance  for  Borders,  its  scope  will  broaden  to  encompass  additional  areas  of  focus.  CELBET 
plays a pivotal role in its interaction with the Customs Control Equipment Initiative (CCEI) by 
maintaining  regular  discussions  and  fostering  a  network  among  Member  State  experts.  This 
ensures  seamless  communication  and  support  throughout  the  procurement  process.  Among  the 
challenges  faced  are  the  differentiation  between  infrastructure  and  equipment,  particularly 
concerning  high-energy  scanners,  and  cybersecurity  concerns  related  to  procurement  laws. 
Suggestions  for  improvement  include  moving  from  a  Border  Crossing  Point  (BCP)-focused 
approach to an equipment-based approach for proposal submissions and potentially establishing 
an EU-level institute for joint procurement to standardise equipment across Member States. 

JRC 

The JRC has acknowledged that while the programme effectively supplies detection equipment, 
it  has  not  fully  realised  its  innovation  goals.  The  framework  does  support  innovation,  yet 
proposals  often  lack  emphasis  on  this  criterion.  The  JRC  advocates  for  stricter  adherence  to 
evaluation criteria to encourage innovation. Challenges in the evaluation process include a mix 
of  political  considerations,  which  can  undermine  technical  evaluations,  and  a  recommendation 
for  improving  the  integrity  of  this  process  by  relying  exclusively  on  external  evaluators. 
Although  they  noted  some  complementarity  with  national  initiatives,  there  was  no  significant 

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overlap  with  other  EU  initiatives.  They  also  suggested  that  the  programme  could  improve  by 
enforcing its focus on innovation more rigorously. 

OLAF 

OLAF's  involvement  with  the  CCEI  includes  ensuring  alignment  with  other  programmes  and 
preventing  financial  overlaps.  The  CCEI  complements  OLAF's  focus  on  law  enforcement 
agencies  by  addressing  border-related  needs.  The  programme's  design  is  robust,  with  specific 
delegated  acts  providing  clarity  on  indicators  and  monitoring  systems.  The  budget  of  EUR  1 
billion is  deemed appropriate, given the high  costs  associated with  equipment. Suggestions for 
improvement  include  enhancing  the  evaluation  of  laboratory-related  proposals  and  introducing 
security notices to prevent procurement from sensitive third countries. 

WCO 

While  the  WCO’s  work  is  not  directly  tied  to  the  CCEI,  the  interviewee  indicated  that  the 
standards developed by the WCO are expected to apply to equipment purchased by all countries, 
including  EU  MS.  They  also  stated  EU  experts  and  MS  collaborate  to  ensure  alignment  with 
these standards. Furthermore, while the WCO is not actively monitoring the implementation of 
the CCEI, discussions within the organisation suggest that the Instrument is proceeding well and 
in line with the objectives of the WCO. 

Workshop 

The feedback obtained during the workshop was used to validate and, where appropriate, revise 
and  refine  the  draft  conclusions  and  recommendations.  The  discussion  with  stakeholders  was 
structured around four main themes and corresponding questions (see below). The main findings 
from the workshop (and specifically the breakout groups) are summarised below:  

Delays in implementation: Why are so many projects progressing so slowly? 

The  discussion  of  the  first  group  focused  on  how  smaller  grants,  which  can  be  awarded  more 
frequently  and  adapted  more  easily  than  larger  ones,  could  help  reduce  the  complexity  of 
amendments (and subsequently) delays. Others from the group highlighted the fact that different 
administrations  often  share  jurisdiction  over  the  land  itself  on  which  BCPs  sit  which  can 
complicate processes such as permitting of equipment. Others indicated that they have to comply 
with  mandatory  national  procurement  legislation  that  slow  down  the  process.  Meanwhile,  the 
second  group  discussed  the  impact  of  (cyber)security  concerns  in  procurement  with  regards  to 
uncertainty  around  certain  suppliers  in  an  already  concentrated  supplier  market.  Interrelatedly, 
the  group  also  noted  the  delivery  delays  which  were  mostly  attributed  to  stock  issues  and 
increased  demand  which  were,  at  times,  exacerbated  by  national  procedural  issues  (like  those 
discussed in Group 1). Finally, the third group shared the view that the CCEI may have increased 
demand for some equipment, leading to delays in delivery of CCE.  

Data model: How could the data (available CCE per BCP, traffic, risks, performance indicators) 
be collected and used more effectively and efficiently? 

The first group argued that while providing inventory data was not challenging, defining traffic 
statistics  and performance indicators was problematic with  concerns raised about  the workload 
involved  in  compiling  statistics.  There  was  a  lack  of  clarity  on  setting  seizure  targets  due  to 
unpredictable  traffic  flows  at  BCPs.  Furthermore,  price  variations  for  some  equipment  were 
significant  from  the  signing  of  the  grant  agreements,  leading  to  mismatches  in  the  required 
equipment and the level  of funding. Furthermore, the second group agreed that the data model 
was  seen  as  cumbersome  and  repetitive  with  participants  questioning  the  necessity  of  some 
elements  and  highlighting  the  need  for  simplification.  While  participants  acknowledged  the 

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importance  of  data  collection  at  the  EU  level,  they  suggested  national  data  collection  systems 
could also be effective without the model. 

Added value: How could the impact and added value of the CCEI be further enhanced? 

The first workshop group remarked on how broadening the eligibility criteria to include related- 
infrastructure  and  software  would  add  more  value  for  Member  States,  with  the  latter  also 
emerging from the second group’s discussion. However, group two also highlighted that, if the 
CCEI  were  to  open  the  list  of  eligible  equipment  to  pieces  such  as  drones,  this  would  likely 
require adapted legal bases and expertise in many Member States.  

Alternatives  to  the  CCEI:  Post-2027,  could  the  (very  relevant)  CCEI  objectives  be  better 
achieved by other means? 

Rather  than  alternatives  to  CCEI,  both  Groups  two  and  three  highlighted  their  desire  for 
increased  joint  procurement  in  the  future,  although  doubts  remained  on  how  to  approach  the 
immediate  next  steps  on  how  achieve  this.  Price  advantages  through  bulk  purchases  and 
standardisation were particularly underlined. 

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