COMMISSION STAFF WORKING DOCUMENT Accompanying the document 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 programme for cooperation in the field of customs for 2021-2027
Date: 2026-01-29
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU programme, customs, customs cooperation, customs formalities, customs inspection, customs union, exchange of information, information system, project evaluation, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.1.2026  SWD(2026) 20 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document 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 programme for cooperation in the field of customs for 2021-2027  {COM(2026) 40 final}  
 
 
Table of contents 

1. 

INTRODUCTION .................................................................................................................. 4 

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

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

2.2.   Point(s) of comparison ..................................................................................................... 10 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ........ 15 

4.  EVALUATION FINDINGS................................................................................................. 23 

4.1.   To what extent was the intervention successful and why? ............................................... 23 

4.2.   How did the EU intervention make a difference and to whom? ...................................... 48 

4.3.   Is the intervention still relevant? ...................................................................................... 49 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? .................................. 52 

5.1.   Conclusions ...................................................................................................................... 52 

5.2.   Lessons learned ................................................................................................................ 56 

ANNEX I:   PROCEDURAL INFORMATION ........................................................................... 59 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................... 62 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 
TO THE EVALUATION QUESTIONS (BY CRITERION) .............................................. 71 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ............................................................ 81 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT .............................. 83 

1 

 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AI 

ART 

AWP 

CBAM 

CCEI 

CCI 

CELBET 

CEPOL 

CLEP 

CRMS2 

DG BUDG 

DG TAXUD 

ECCG 

EES 

ETCIT 

Artificial Intelligence 

Activity Reporting Tool 

Annual Work Programme  

Carbon Border Adjustment Mechanism 

Customs Control Equipment Instrument 

Centralised Clearance for Import 

Customs Eastern and South-Eastern Land Border 
Expert Team 

European Union Agency for Law Enforcement 
Training 

Common Learning and Events Programme 

Customs Risk Management System 

Directorate-General for Budget 

Directorate-General for Taxation and Customs Union 

Electronic Customs Coordination Group 

European Electronic Systems 

Expert Team on Customs IT 

EU CSW-CERTEX  

EU Customs Single Window Certificate Exchange 

EU SWE-C 

EU Single Window Environment for Customs 

GUM 

ICG 

ICS2 

IOSS 

IT 

Guarantee Management 

Import of Cultural Goods 

Import Control System 2 

Import One Stop Shop 

Information Technology 

2 

 
 
LMS 

LTI 

Learning Management System 

Learning Tools Interoperability 

MASP-C 

Multi-Annual Strategic Plan for Customs 

MEF 

MFF 

NCTS 

NIS 

PICS 

PoUS 

Monitoring and Evaluation Framework 

Multiannual Financial Framework 

New Computerised Transit System 

National Import Systems 

Programme Information and Collaboration Space 

Proof of Union Status 

TRACES 

Trade Control and Expert System 

UCC 

WCO 

Union Customs Code 

World Customs Organization 

3 

 
1. 

INTRODUCTION 

Regulation (EU) 2021/444 of the European Parliament and of the Council established the 
European  Union  Customs  Programme  2021-2027  (‘the  (Customs)  programme’)  as  a 
successor to the Customs 2020 Programme, providing a framework for cooperation in the 
customs  field  across  Europe.  With  a  budget  of  EUR 950  million  for  2021  to  2027,  the 
programme supports national customs administrations in working together as one to: (i) 
protect the EU’s financial interests; (ii) ensure security and safety within the EU; and (iii) 
facilitate legitimate trade while combatting illegal activities. This interim evaluation has 
been undertaken roughly at the programme’s mid-point, in accordance with Article 14(2) 
of Regulation (EU) 2021/444, and provides evidence-based insights into the programme’s 
implementation and performance to date as well as lessons learned. 

Purpose and scope of the evaluation 

This  interim  evaluation  aims  to  assess  whether  the  Customs  programme  is  on  track  to 
achieve its intended results, including the extent to which it is (i) supporting the preparation 
and uniform implementation of customs legislation and policy, (ii) enhancing cooperation 
among  customs  authorities  and  with  partner  competent  authorities;  (iii)  improving 
administrative capacity building and operational performance of customs authorities; and 
(iv)  promoting  innovation  in  the  area  of  customs  policy.  In  line  with  the  EU’s  Better 
Regulation  guidelines,  the  assessment  is  structured  around  the  five  key  evaluation 
criteria, namely effectiveness, efficiency, coherence, EU added value and relevance. 
In  other  words,  the  evaluation  examines  how  effectively  the  Customs  programme  is 
meeting its objectives and delivering expected outcomes, how efficiently it uses financial 
and human resources to do so, how coherent it is with other policies and its own internal 
logic, what value it adds by being delivered at EU level, and how relevant the programme 
remains  in  light  of  current  and  future  needs.  By  evaluating  these  aspects,  the  interim 
evaluation addresses whether the programme’s initial expectations are being fulfilled and 
identifies any areas for improvement at mid-term. 

The  scope  of  the  evaluation  covers  all  activities  implemented  within  the  Customs 
programme  between  January  2021  and  December  2024,  including  IT  capacity-building 
measures, joint actions, training initiatives, and knowledge-sharing efforts funded by the 
programme. Within this framework, a number of customs IT systems, also referred to as 
European Electronic Systems (EES), are an explicit focus of this interim evaluation as they 
account  overall  for  more  than  90%  of  the  programme  funding  and  have  been  less 
extensively  covered  in  evaluations  of  the  programme’s  predecessors  due  to  data 
availability constraints. The present interim evaluation examines the extent to which the 
funding  provided  by  the  programme  has  contributed  to  its  intended  objectives  of 
supporting  the  customs  authorities  working  together  and  acting  as  one  to  protect  the 
financial and economic interests of the Union and its Member States, ensuring security and 
safety  within  the  Union,  and  to  protect  the  Union  from  unfair  and  illegal  trade,  and 
facilitating legitimate business activity. 

4 

 
 
Methodology of the evaluation 

This  interim  evaluation  is  based  on  a  combination  of  qualitative  and  quantitative  data, 
including stakeholder consultations, survey results, monitoring indicators, case studies and 
desk research. The general public was also able to provide feedback via a call for evidence1. 
The interim evaluation is based primarily on an external support study carried out over a 
12-month period by a consortium led by Economisti Associati2. In order to devise a suitable 
approach to the evaluation, some critical elements had to be accounted for at the outset of 
the exercise, including: (i) the gradual evolution of the programme, whereby its key types 
of activities have remained broadly stable while developing and improving over time; (ii) 
the budgetary split, whereby the vast majority of programme resources are devoted to EES 
in  the  field  of  customs;  (iii)  the  fact  that  collaborative  activities  and  human  capacity-
building  actions  have  already  been  extensively  evaluated;  (iv)  the  difficulties  faced  by 
previous  evaluations,  particularly  in  measuring  the  costs  and  benefits  of  the  EES,  and 
dealing with ‘consultation fatigue’ among core stakeholders; and (v) the recent launch of 
the Monitoring and Evaluation Framework (MEF), which provides a more solid base of 
monitoring  data  than  was  available  for  past  evaluations.  This  led  to  a  methodological 
approach centred on case studies to focus the analysis on the systems and enablers 
most material to spending and performance in this programming period. Of the five 
case studies investigated in depth as part of this interim evaluation, four focus on specific 
EES,  including  the EU’s new  Import Control System (ICS2), the system developed for 
Proof of Union Status (PoUS), the new EU Centralised Clearance for Import (EU CCI), 
and the digitalisation of new controls on the Import of Cultural Goods (ICG), while the 
fifth non-EES case study was on the Learning Management System (LMS). The selection 
of the case studies  aimed to  ensure coverage of  different  points  of the customs process 
(pre-arrival risk, status determination, import clearance, non-UCC enforcement) and the 
enabling  capacity-building  layer.  They  also  vary  in  maturity,  expenditure  intensity  and 
system  architecture3.  The  mix  was  expected  to  yield  complementary  insights  into  the 
benefits  and  shortcomings  of  the  Customs  programme,  thereby  addressing  previous 
evidence gaps as concerns the cost-effectiveness of the supported EES. 

1 See https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14231-Interim-Evaluation-of-

the-CUSTOMS-2021-2027-programme_en. 

2 Study supporting the interim evaluation of the Customs programme (2021-2027) – final report. 
3 See Annex II for further details. 

5 

 
 
 
 
 
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Description of the intervention and its objectives 

Problems the Customs programme was intended to solve 

The  Customs  programme  2021-2027  was  conceived  to  tackle  a  set  of  persistent  and 
emerging pressures on the EU customs union that were set out in detail in the programme’s 
impact assessment report4. Rising trade volumes, new security threats  and transnational 
crime,  rapid  digitalisation  and  new  business  models  (notably  e-commerce),  as  well  as 
constrained financial and human resources have all increased the pressure to improve the 
performance of the customs union and expand the scope of the tasks to be performed by 
customs  administrations.  This  has  led  to  the  functioning  of  the  customs  union  being 
hampered by the twin problems of insufficient uniformity and efficiency. The drivers of 
these  two  interconnected  problems  were  identified  as  the  uneven  capacity  of  customs 
administrations,  inconsistencies  in  interpreting  and  implementing  EU  legislation, 
including Union Customs Code (UCC)5 rules, and obstacles to cooperation between 
customs authorities and other stakeholders. 

Firstly, there is a foundational need to tackle the twin problems facing the customs union 
by completing the digital transformation mandated by the UCC and steered through 
the UCC work programme, and which provides that all exchanges of information between 
customs  authorities  and  between  economic  operators  and  customs  authorities  are  to  be 
made  electronic.  Delivering  this  in  practice  relies  on  a  portfolio  of  17  core  electronic 
systems  (14 trans-European  systems  developed  centrally with  Member States  and  three 
strictly national systems), complemented by other customs IT components. Progressively 
replacing legacy and paper processes with interoperable EU-wide systems, such as ICS2 
and EU CCI, is essential to make the customs union function ‘as one’ and more efficiently. 
Given  these  systems’  complexity  and  their  24/7  operational  requirements,  they  need 
substantial,  predictable  funding  from  2021  to  2027,  with  the  impact  assessment  report 
estimating  that  EUR 855.5 million  is  needed  just  to  run  existing  systems  and  complete 
those already required by law. 

Secondly, there is a closely-linked need to strengthen EU-wide risk management and 
supply-chain security. The original Import Control System (ICS), introduced after 9/11, 
had structural  weaknesses. This prompted the move to  ICS2, which enabled  richer pre-
loading and pre-arrival data to be collected, as well as earlier, more consistent targeting 
across all modes. This  shift  from  fragmented, nationally driven profiling  to  a common, 
data-rich approach was considered necessary to address both security and trade facilitation 
imperatives at scale. 

4 SWD(2018) 321. 
5  Regulation  (EU)  No 952/2013  of  the  European  Parliament  and  of  the  Council  laying  down  the  Union 

Customs Code. 

6 

 
 
Thirdly, there is a need to cope with expanding customs responsibilities amid resource 
constraints. Customs administrations now enforce more than 60 non-customs legal acts at 
the  border  (health,  environment,  product  compliance,  dual-use  items,  etc.),  while 
processing  hundreds  of  millions  of  declarations  each  year.  These  tasks  increasingly 
demand a framework for collaboration, interoperable data, cross-agency connectivity and 
skilled  staff.  The  customs  administrations  themselves  have  emphasised  the  need  for 
reinforced EU risk management, cooperation with partner authorities and support to carry 
out these broadened tasks despite reduced budgets and staffing. 

Inputs into the Customs programme 

To  tackle  these  needs,  the  programme  provides  the  following  key  inputs:  financial 
resources amounting to EUR 950 million and human resources both at EU and national 
level;  and  two  key  planning  tools,  including  the  Multi-Annual  Strategic  Plan  for 
Customs (MASP-C) and the multiannual work programmes. 

The  budget  for  the  programme  is  EUR 950  million  over  the  current  seven-year 
Multiannual Financial Framework (MFF). 

Table 1: Customs programme budget 2021 - 2027 (EUR million) 

2021 

2022 

2023 

2024 

2025 

2026 

2027  Total 

Financial allocation  125.5  130.5  125.1  135.7  138.4  141.2  144.3  940.8 

Source: DG BUDG6 

The human resource inputs are those of DG TAXUD (one of the smaller Directorates-
General of the Commission with 450 officials across both tax and customs) and the staff 
of the Member States’ customs authorities (ministries and border officials, including well 
over 100 000 front-line customs officers alone). 

The Commission is assisted by a programme committee made up of representatives of the 
Member States. The committee is consulted on the multiannual work programmes for the 
programme and on the Customs Control Equipment Instrument (CCEI), a new instrument 
under the current MFF’s Integrated Border Management Fund. The Customs programme 
complements  the  CCEI  through  collaborative  actions  that:  (i)  support  the  purchase  of 
equipment (e.g. sharing the latest technological developments, standards, security aspects 
and potential joint procurement); and (ii) make optimal use of the purchased equipment 
(e.g. sharing know-how and good practices, training on various aspects, etc.). 

Key planning inputs supporting the activities are the multiannual work programmes and 
the MASP-C. 

6 See: https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-

performance-statements/customs-performance_en. 

7 

 
 
 
 
The MASP-C is a project management tool that has been revised three times since the first 
stand-alone  MASP-C  was  adopted  in  2019.  It  is  an  operational  tool  that  sets  out  what 
customs IT systems must be built or upgraded, by whom and by when (including those 
needed  for  the  implementation  of  the  UCC),  and  it  draws  on  the  advice  of  two  expert 
groups,  namely  the  Customs  Policy  Group  and  the  Electronic  Customs  Coordination 
Group.  The  Trade  Contact  Group,  which  represents  stakeholders  other  than  national 
authorities, is also consulted. The MASP-C closely tracks progress in implementing the 
systems needed for the UCC. 

Activities and intended outputs of the Customs programme 

The programme’s inputs support a range of activities, including: (i) the development and 
maintenance of the EES (i.e. the IT systems that enable seamless and secure information 
exchange to take place between Member States), which represents the programme’s first 
building  block;  and  (ii)  training  and  human  competency  building  (such  as  seminars, 
workshops and project groups for customs officials). 

The  lion’s  share  of  the  budget  (~95%)  goes  to  IT  capacity-building  activities,  i.e. 
developing, operating (including carrying out any necessary maintenance and upgrades) 
and performing quality checks on the common components of the EES. Priority is given 
to  electronic  systems  that  are  necessary  for  implementing  the  customs  union  and  for 
customs  authorities  to  carry  out  their  tasks.  The  overall  output  of  the  funding  for  IT 
capacity-building  under  the  programme  is  designed  to  produce  a  seamless  and  secure 
electronic  environment  for  digital  exchange  and  storage  across  customs  authorities  and 
with economic operators, as well as sound risk management. 

Collaboration and human competency activities represent the second building block of 
the  Customs  programme.  Collaboration  is  designed  to  strengthen  national  customs 
administrations’  operational  capability  and  performance.  The  activities  include  project-
based  collaboration,  training  activities,  programme  groups,  seminars  and  workshops, 
working  visits  etc.,  as  well  as  expert  teams.  Expert  teams  were  introduced  under  the 
Customs 2020 programme (2014-2020). They are led by a Member State and include a 
variable number of participating Member States that have an interest in the subject, with 
the objective being to pool expertise to perform tasks in specific domains or to carry out 
operational activities. Training is conducted through the Customs and Tax EU Learning 
Portal, known as the LMS. The LMS promotes training courses and webinars that customs 
programme officials have designed and organised. E-learning courses are developed by the 
EU training team with the involvement of customs experts (either in-house experts in DG 
TAXUD or customs officials in the participating countries) for the content creation. An 
external contractor does the technical design and development. The Common Learning and 
Events Programme (CLEP) consists of training  courses run by national administrations, 
generally in person rather than online. They are announced and organised via the portal. 
Participants are registered, selected and validated via the portal. 

8 

 
 
There are also support activities, including innovation activities, which are defined in the 
Programme  Regulation  as  being,  in  particular,  proof-of-concepts,  pilot  projects, 
prototyping  initiatives,  smart  data  mining  and  collaboration  among  systems,  jointly 
developed communication actions and studies. 

Expected results and impacts of the Customs programme 

By building on these outputs, the programme is expected to achieve several result-level 
outcomes that are aligned with its four specific objectives. 

the preparation and uniform implementation of customs legislation and policy; 

The programme’s specific objectives / expected results are intended to support: 
• 
•  customs cooperation; 
•  administrative and IT capacity building, including human competency and training, as 

well as the development and operation of the EES; 
innovation in the area of customs policy. 

• 

If these specific results materialise as planned, they will contribute directly to helping the 
customs union and the customs authorities to work together and act as one to achieve the 
general objectives / expected impacts of the programme, which are to: 
•  protect the financial and economic interests of the EU and its Member States; 
•  ensure the security and safety of the public in the EU; 
•  protect  the  EU  from  unfair  and  illegal  trade,  while  supporting  legitimate  business 

activity. 

Figure 1: Intervention logic for the Customs programme 

Source: MEF for the Customs Programme (2021-2027), SWD(2023) 24 final 

9 

 
 
 
 
2.2. Point(s) of comparison 

The Customs programme has undergone seven iterations, with EU funding for customs 
cooperation dating back to 1991. Over time, the programme has evolved gradually, with a 
focus on deepening cooperation rather than introducing radical changes. As a result, the 
impact  of  EU  funding  can  take  years  to  materialise,  making  it  difficult  to  distinguish 
between the outcomes of different funding periods. 

Despite the evolving challenges, the core objectives of the 2021-2027 programme remain 
similar  to  those  of  its  predecessors.  By  identifying  areas  of  strength,  value  and 
improvement  through  an  assessment  of  five  key  criteria,  successive  evaluations  have 
aimed to improve understanding of the programme’s performance. These evaluations have 
informed  evidence-based  adjustments  to  the  programme,  including  its  activities  and 
monitoring  systems.  However,  the  programme’s  impact  is  often  intertwined  with  the 
broader  regulatory  and policy environment,  making it challenging  to  isolate its specific 
contributions. 

Given  these  complexities,  a  direct  comparison  between  programming  periods  is  not 
straightforward. Nevertheless, a useful approach is to compare the current period (2021-
2027)  with  its  predecessor,  the  Customs  2020  programme7.  The  interim  evaluation 
addresses the following three key questions to identify appropriate points of comparison: 

1.  What was the state of affairs prior to the 2021-2027 programme? 

2.  What developments were anticipated? 

3.  What are the key comparative elements that can be used to evaluate the programme’s 

progress? 

The situation before the Customs programme 2021-2027 

At  the  close  of  the  Customs  2020  programme  (2014-2020),  the  EU  customs  union 
operated  on  a  largely  harmonised  legal  basis,  the  UCC,  but  still  relied  on  the 
programme  to  deliver  the  trans-European  IT  backbone  and  the  cooperation 
structures needed for uniform application in practice. The Customs 2020 programme 
had  a  committed  budget  of  EUR  531.7  million,  of  which  approximately  87%  financed 
European  Information  Systems,  11%  joint  actions  (including  expert  teams)  and  2% 
training activities. The final evaluation underlined that Customs 2020 programme had been 
indispensable to implementing the UCC IT work programme (17 projects), with nine UCC 
IT projects released during 2014-2020 and the remainder planned for the subsequent period 
of 2021-2027. Operationally, joint actions (project groups, working visits, monitoring) and 
the introduction of expert teams deepened practical cooperation and knowledge sharing 

7  Regulation  (EU)  No 1294/2013  of  the  European  Parliament  and  of  the  Council  establishing  an  action 
programme for customs in the European Union for the period 2014-2020 (Customs 2020) and repealing 
Decision No 624/2007/EC. 

10 

 
 
 
 
across  customs  administrations.  Countries  without  specific  expertise  or  training 
programmes benefited particularly from these activities. The Customs 2020 programme 
thus made it more cost-effective to implement customs law uniformly. 

Overall,  the  final  evaluation8  found  that  Customs  2020  programme  was  broadly 
effective  and  efficient  in  achieving  its  core  objectives  of  modernising  the  customs 
union and fostering cooperation between customs administrations. The evaluation also 
confirmed  that  the  Customs  2020  programme  was  coherent  with  other  EU  policies, 
although  there  was  scope  for  it  to  complement  border  and  security  funds  to  a  greater 
degree.  As  a  point  of  continuity,  the  Customs  2020  programme,  like  its  predecessor, 
provided  strong  EU  added  value  through  economies  of  scale  in  IT  and  uniform 
implementation (instead of 27 national developments being implemented in parallel). The 
Customs 2020 programme was also considered to match administrations’ needs and proved 
adaptable  to  unforeseen  developments  (i.e.  the  COVID-19  pandemic  and  Brexit), 
confirming its continued relevance at the close of the period. 

Expected developments under the Customs programme 2021-2027 

The  impact  assessment  for  the  Customs  2021-2027  programme9  set  out  the  expected 
trajectory  for  the  successor  programme  to  Customs  2020  programme.  It  put  forward  a 
programme of EUR 950 million that was designed primarily to complete the UCC digital 
transformation to make customs fully electronic and interoperable by the end of 2025. The 
impact assessment stressed that EUR 855.5 million would be needed between 2021 and 
2027 just to run existing systems and develop/deploy those already mandated by adopted 
legislation. Most notably, the introduction of ICS2 to address earlier security gaps is a 
major development that dominates the programme’s workload and cost profile. 

It was understood that the current programme would have to address not only the delivery 
of the UCC core requirements, but also the rise of e-commerce (in particular, low-value 
and  small  parcel  consignments),  which  had  created  significant  issues  for  customs 
under the Customs 2020 programme. Existing risk management systems were struggling 
to cope with the sheer volume and speed of digital trade flows. Furthermore, the quality of 
information for small shipments, (specifically descriptions of goods) was often poor, which 
hindered  effective  targeting  and  enforcement.  The  expansion  of  non-financial  control 
obligations during the previous programme, which was often linked to sectoral legislation 
(product safety, environmental standards, public health and intellectual property rights), 
placed  considerable  demands  on  customs  authorities.  Under  the  Customs  2020 
programme,  work  on  the  EU  Single  Window  Environment  for  Customs  (EU  SWE-C) 
began but was expected to (and has) continued under the successor programme. The EU 
SWE-C  underwent  a  major  upgrade  in  2025  with  the  interconnection  of  different  non-
customs domains, of which one (ICG) is a DG TAXUD system. 

8 SWD(2022) 363 final. 
9 SWD(2018) 321 final. 

11 

 
 
 
Alongside  IT,  the  impact  assessment  anticipated  scaling  administrative  capacity-
building and cooperation mechanisms (including expert teams) to address differences 
in  capacity,  expand  cross-agency  connectivity  (customs  cooperation  with  partner 
competent  authorities),  and  mainstream 
(data  analytics,  AI, 
interoperability).  The  impact  assessment  noted  the  programme’s  EU  added  value  in 
economies of scale and interoperability by design, highlighting evidence that every euro 
invested at EU level in common IT systems saves Member States around EUR 5 at national 
level through avoided duplication and faster harmonisation. 

innovation 

In parallel, the impact assessment flagged a more centralised operational delivery based on 
the creation of an EU customs agency as a possible longer-term development. The Customs 
programme 2021-2027 was explicitly described as a transitional programme focused on 
completing  UCC  systems,  thereby  laying  the  groundwork  for  a  bigger  structural  shift 
towards deeper customs integration. 

It  is  also  worth  noting  that  a  new  complementary  financial  instrument  providing 
financing for customs control equipment was expected under the 2021-2027 financial 
framework. Its aim was to address persistent control capacity gaps and uneven availability 
of customs control equipment, but it required a new funding instrument. 

Comparison  between  the  Customs  2020  programme  and  the  Customs  programme 
2021-2027 

Compared with the 2020 Customs programme (Decision No 1382/2013/EU), the Customs 
programme  for  the  period  2021-2027,  established  by  Regulation  (EU)  2021/444,  has  a 
familiar  structure  and  supports  similar  activities,  even  if  some  of  the  terminology  has 
changed10. 

Similarly,  the  objectives  are  not  new  either.  However,  the  framing  of  the  objectives  is 
different  under  the  Customs  programme  2021-2027.  Article  3  of  the  Programme 
Regulation refers explicitly to customs authorities acting as one and facilitating legitimate 
trade  as  part  of  the  general  objectives.  Innovation  in  customs  policy  was  added  to  the 
specific  objectives,  while  a  more  nuanced  reference  to  supporting  the  uniform 
implementation  of  policy  was  introduced.  The  Customs programme  2021-2027  is  also 
more explicit than its predecessor about integrating the programme goals with generally 
applicable EU objectives11. 

The  2021-2027  programme  has  a  significantly  higher  budget  than  its  predecessor 
(almost double). This increase is due mainly to the fact that while the Customs 2020 

10 For example, IT systems were referred to as ‘EIS’ but are now ‘EES’. The term ‘joint actions’ is no longer 

used under the Customs programme 2021-2027. 

11 For instance, recital 3 of Regulation (EU) 2021/444 states that the programme should contribute to the 
digital and green economy, while Article 3(b) includes the objective to support environmental and health 
protection. This represents a broader strategic scope than Regulation (EU) No 1294/2013, which focused 
more narrowly on customs cooperation and IT support. 

12 

 
 
 
the  Customs  programme  2021-2027 

programme supported collaborative development and preparatory work for the UCC 
final 
systems, 
operationalisation  and 
long-term  maintenance  of  the  EU  customs  system 
architecture. This includes the ambitious and complex implementation of the new ICS2, 
which is the single biggest reason why the budget has increased. 

focuses  more  on 

the 

13 

 
Table 2: Overview of key aspects 

Aspect 

Customs 2020 (2014-2020) 

Customs 2021-2027 

Legal Basis 

Regulation (EU) No 1294/2013 

Regulation (EU) 2021/444 

Objectives 

of 

general 

objective 

the 
‘The 
Programme  shall  be  to  support  the 
functioning  and  modernisation  of  the 
customs union in order to strengthen the 
internal market by means of cooperation 
between  participating  countries,  their 
customs authorities and their officials. 

The  specific  objectives  shall  be  to 
support customs authorities in protecting 
the  financial  and  economic  interests  of 
the  Union  and  of  the  Member  States, 
including the fight against fraud and the 
protection of intellectual property rights, 
to increase safety and security, to protect 
citizens and the environment, to improve 
the  administrative  capacity  of 
the 
customs authorities and to strengthen the 
European 
of 
competitiveness 
businesses.’ (Article 5)  

and 

the 
‘The  general  objective  of 
Programme is to support the customs 
union 
authorities 
customs 
working together and acting as one to 
protect  the  financial  and  economic 
interests  of 
its 
Member  States,  to  ensure  security 
and  safety  within  the  Union  and  to 
protect  the  Union  from  unfair  and 
illegal 
facilitating 
legitimate business activity. 

the  Union  and 

trade,  while 

The  specific  objectives  of 
Programme are to support: 

the 

• the preparation and uniform 
implementation of customs 
legislation and policy; 

• customs cooperation; 

• administrative and IT capacity 
building, including human 
competency and training, as well 
as the development and operation 
of European electronic systems; 

• innovation in the area of customs 

policy.’ 

(Article 3) 

Note  that  the  stronger  focus  on 
innovation 
specific 
objective), is completely new. 

(the 

last 

Budget 

~EUR 522 million 

~EUR 950 million 

Policy 
context 

Pre-Brexit,  less  focus  on  e-commerce 
and  digitalisation,  adoption  of  Union 
Customs  Code  (2013)  for  application 
from 2016 onwards 

Post-Brexit,  post-COVID,  explicit 
references to green/digital priorities, 
ongoing  work 
to  develop  and 
implement the Customs Action Plan 
and  to  make  progress  on  possible 
customs 
e-
commerce and take forward plans for 
centralisation. 

reform 

tackle 

to 

Delivery  

Annual work programme  

Multiannual work programmes 

Source: External support study. 

14 

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

Current state of play 

Since  its  launch,  the  Customs  programme  has  concentrated  spending  on  the 
European  Electronic  Systems  for  customs  (EES).  From  2021  to  2024,  total 
commitments amounted to EUR 512.53 million, of which about EUR 486.93 million 
(~95%) was for the EES, underscoring its pivotal role in the programme’s objectives. 
The budget for collaborative activities, including expert teams, was markedly lower, with 
a  total  of  approximately  EUR 7.25 million  (~1.4%)  over  the  same  period.  It  declined 
sharply in 2022 and fell to zero in 2023, which was due to the fact that – as from 2021 – 
grants have been multiannual (covering on average 2-3 years). Subsequently, the budget 
for  collaborative  activities  increased  modestly  in  2024.  However,  these  data  cover 
committed expenditure, and actual expenditure may not occur in the year the commitment 
was  made.  Other  service  contracts  received  a  more  consistent  allocation  of  around 
EUR 18.15 million in total (~3.5%). Meanwhile, the budget for external experts is minimal 
at only EUR 0.20 million (~0.04%). Overall, the data reflect the programme’s design and 
legal  basis,  prioritising  EU-level  IT  capacity  investments  to  develop  and  operate  the 
customs  digital  landscape,  while  keeping  a  smaller,  targeted  envelope  for  collaborative 
actions and supporting services each year. 

Figure 2: Customs programme budget per type of funding 

2024

2023

2022

2021

European Electronic Systems
Collaboration activities (incl.
expert teams)

External experts
Other service contracts

 -

 50.000.000

 100.000.000

 150.000.000

2021
116.533.046

2022
125.321.558

2023
113.352.772

2024
131.717.597,38

5.600.000

200.000
2.884.091

749.998

900.000,00

4.372.444

7.800.531

3.096.402,62

European Electronic Systems

Collaboration activities (incl. expert teams)

External experts

Other service contracts

Source: Customs Programme Annual Progress Reports for 2021-2024 

15 

 
 
European Electronic Systems (EES) 

Developing  and  operating  the  EES  is  a  core  focus  of  the  Customs  programme.  The 
programme supports more than 60 interconnected digital customs systems that facilitate 
import/export processes and information exchange across the EU. The systems vary widely 
in  their  remit,  from  systems  which  provide  the  crucial  communication  infrastructure  or 
disseminate information for compliance with customs rules to systems that provide for the 
completion of customs processes or,  enable exchanges between customs and non-customs 
authorities to facilitate trade (as in the case of the EU SWE-C, which was implemented 
during  this  programming  period).  Broadly  speaking,  they  can  be  broken  down  into  the 
following different categories, based on their purpose. 

•  Data  dissemination  systems  that  disseminate  requisite  information  for  customs 
purposes, such as the Combined Nomenclature System, which provides a standardised 
classification of goods that is disseminated to traders and customs authorities to ensure 
consistent tariff application and statistical reporting across the EU. 

•  Systems  for  gathering  information/analysis,  such  as  the  EU’s  Counterfeiting  and 
Piracy System, which is used to track and analyse information related to counterfeit 
and piracy activities. 

•  Systems  interfacing  directly  with  traders,  including  the  Import  Control  System  - 
Shared  Trader  Interface,  which  is  a  trader-facing  component  of  ICS2.  This  tool 
provides the single access point for traders to enter their data in ICS2. 

•  Systems for managing transactions, such as the Automated Export System a Europe-
wide system that supports the smooth export of goods out of the EU. It enables export 
and exit formalities to be digitalised and modernised, as required by the UCC. Another 
example is the EU CCI, which helps the customs authorities of several Member States 
that are acting as one customs authority (with joint responsibility for risk management, 
controls,  clearance  of  goods  and  collection  of  duties  and  taxes)  to  manage  import 
transactions. ICS2 is another system that has been set up to help Member State customs 
authorities manage data sharing and collaborate on risk management. 

•  Other / miscellaneous systems, covering an array of systems that do not fall into the 
above categories. One example is the Programme Information and Collaboration Space 
(PICS),  which  provides  an  online  collaboration  platform  for  tax  and  customs 
professionals working in national administrations across Europe. 

The  output  indicators  for  the  EES,  as  specified  in  the  Monitoring  and  Evaluation 
Framework (MEF, are on a broadly positive trajectory. 

In  terms  of  development  (output  indicator  1.1),  there  were  6  IT  projects  in  the 
initiating phase in 2021, 4 in 2022, 6 in 2023 and 2 in 2024. As regards projects in the 
execution phase, there were 22 IT projects at this stage in 2021, 16 in 2022, 22 in 2023 and 
17  in  2024.  From  2022  to  2024,  all  project  costs  were  in  line  with  planned  budgets, 

16 

 
 
achieving  a  100%  match.  As  required  by  the  MASP-C,  the  proportion  of  projects  with 
‘green’ status went from 69% in 2022 to 100% in 2023 and remained high at 92% in 2024. 

With respect to delivery of the common components of the EES (output indicator 1.2), 
the Customs programme delivered key releases to production in both 2023 and 2024. 
In 2023, the CBAM transitional IT system was released as required by Regulation (EU) 
2023/956, while in 2024, PoUS (phase 1), ICS2 (release 3, step 1), the central component 
of  the  GUM  System  and  CCI  (phase  1)  were  released.  For  both  new  and  upgraded 
components  in  2023  and  2024,  100%  timeliness  (share  delivered  per  MASP-C)  was 
achieved,  while  the  UCC  completion  rate  progressed  from  87%  (2022)  to  91.45% 
(2023) and 93.84% (2024). Nine UCC projects are fully operational and five more have 
completed common-component development and have been deployed at national level. 

One  of  the  key  measures  of  the  reliability  of  the  EES  (output  indicator  1.3)  is  the 
availability of the EES (indicator 1.3.3, which measures customs systems critical for the 
functioning  of  the  internal  market).  The  average  availability  has  remained  steady  at 
99.85%  in  2021,  99.80%  in  2022,  99.86%  in  2023  and  99.49%  in  2024.  In  2024,  the 
availability decreased by almost 0.4 percentage points and fell below the aggregate target 
of  99.65%.  The  2024  annual  progress  report  explains  that  in  2024,  the  significantly 
increased data volume due to UCC-related system deployment (including the ICS2, the 
Central  Electronic  System  of  Payment  Information  and  e-commerce  data  in  the 
Surveillance  system)  posed  a  challenge  to  the  availability  of  the  central  common 
communication  network,  but  that this challenge  was  successfully overcome. The  figure 
below presents the detailed availability for key systems. 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 3: Availability of the EES from 2021 to 2024 

AES/ECS

99,48%

99,62%

99,51%

99,67%

CERTEX

99,96%

99,93%

99,98%

99,63%

CRS

100,00%

100,00%

100,00%

99,80%

CRS3

100,00%

99,95%

100,00%

99,34%

CS/RD2

100,00%

99,90%

99,90%

99,24%

EBTI

100,00%

99,89%

97,97%

99,62%

EOS+EORI+REX+CDS

99,96%

99,98%

99,99%

99,41%

ICS2

99,52%

99,70%

99,70%

99,15%

ICS2 CR_STI

100,00%

99,51%

98,99%

98,30%

ICS2 MON

100,00%

99,95%

99,98%

99,51%

INF-SP

100,00%

99,99%

99,95%

99,18%

INF-STP

100,00%

99,88%

99,95%

99,53%

NTCS

99,48%

98,97%

99,98%

99,65%

QUOTA

99,95%

99,92%

99,61%

100,00%

TARIC 3

99,99%

100,00%

99,98%

99,89%

TARIC Transmission

99,80%

99,91%

100,00%

99,73%

UUMDS

99,92%

99,88%

99,98%

99,71%

PoUS

100,00%

100,00%

100,00%

99,21%

2021

2022

2023

2024

Source: Customs programme Annual Progress Reports for 2021-2024 

When assessing the reliability of IT support services (output indicator 1.4), the annual 
progress reports show that user satisfaction with the services provided (measured on a 0-5 
scale) increased by 0.02 points from 4.16 in 2022 to 4.18 in 2023 and decreased by 0.07 
points in 2024 to 4.09. The target value is 4, meaning this indicator is on track. 

In addition to the MEF output indicators, the following are also several key examples of 
the most significant ways in which the IT capacity-building activities have supported and 
helped to achieve the EU’s customs legislation and policy priorities. 

•  Support to e-commerce: the programme contributed to the project group addressing 
the import and  export formalities  of low-value  consignments,  and to the  High-level 
Seminar on E-commerce organised under the Slovenian Presidency. 

18 

 
 
 
•  Addressing the challenges created as a consequence of Russia’s aggression against 
Ukraine: the signing of the EU-Ukraine agreement in September 2022 made it possible 
for Ukraine to be fully integrated  as a beneficiary of the Customs programme. This 
enabled Ukraine to be connected to crucial EU IT customs systems to facilitate trade 
flows  and  consolidate  its  pre-accession  strategy  (i.e.  gaining  access  to  the  common 
secure  customs  network,  which  is  necessary  for  Ukraine  to  apply  the  New 
Computerised  Transit  System  (NCTS)).  In  2023,  the  programme  helped  develop 
Ukraine’s customs decision system at national level, as part of its integration into the 
EU. In 2024, the programme provided a platform for establishing customs control and 
risk assessment guidance to underpin a common EU-wide approach to implementing 
the common risk criteria for export/exit and managing circumvention risks. In addition, 
Ukraine implemented  NCTS  phase 5  (in April  2024), as  well  as electronic  customs 
systems for customs clearance and controls, guarantees and risk management. 

•  Customs risk management: in 2022, work under the programme continued to support 
the  design  and  development  of  the  ICS2  system  and  the  deployment  of  the  new 
CRMS2, which led to major improvements in the sharing of risk information and in 
communication  between  Member  States’  experts  dealing  with  risks  and  risk 
management. Discussions with DG TAXUD confirmed that CRMS2 had contributed 
significantly  to  crisis  management,  both  in  terms  of  sanctions  and  risks  related  to 
human health, through facilitating connections and targeted exchanges of information 
between Member States. 

Collaborative actions (including expert teams) 

Alongside  developing  and  maintaining  the  EES,  the  Customs  programme  supported 
extensive collaborative actions to help administrations apply EU law uniformly and turn 
new IT and policy changes into day-to-day practice. The collaborative actions include a 
wide variety of activities that fall into the following main categories: 

•  project-based structured collaboration, which includes: 

-  project groups, typically consisting of representatives from a limited number of 
countries,  working  together for a specified period to  achieve a defined objective 
with clear outputs/results (such as coordination or benchmarking); 

-  expert  teams,  which  are  structured,  long-running  forms  of  (either  temporary  or 
permanent)  cooperation  that  pool  expertise  from  national  customs  authorities  to 
carry  out  tasks  in  specific  domains  or  to  perform  operational  activities,  and  that 
(unlike  project  groups)  are  funded  via  dedicated  multiannual  grants  under  the 
Customs programme in recognition of the more intense effort required; 

•  meetings and other ad hoc events, such as seminars, workshops and working visits; 

19 

 
 
• 

training activities  hosted within  collaboration strands, specifically  CLEP and  IT 
training sessions  embedded in  programme groups, seminars and workshops  to  align 
skills with the guidance being developed; 

•  programme groups used for ongoing policy preparation and harmonisation (e.g. the 

Electronic Customs Coordination Group). 

The number of collaborative actions organised (output indicator 2.1.1-2) ramped up 
from a transition baseline in 2021 to a steady hybrid rhythm. In 2021, most of the joint-
action activity was part of the old Customs 2020 framework, while the new programme 
had three general collaborative actions that were active in December. As a result, 2021 is 
not directly comparable with later years of the implementation period. However, from 2022 
onwards, collaboration stabilised. In 2022, there were 63 collaborative actions, including 
324 meetings (95 physical, 222 online, 7 hybrid) and 5 959 participants across all Member 
States  and  participating  countries.  In  2023,  there  were  77  actions,  280  meetings  (128 
physical, 137 online, 15 hybrid) and 5 646 participants. In 2024, there were 85 actions, 307 
meetings  (156  physical,  133  online,  18  hybrid)  with  5 868  participants.  Improvements 
made to PICS supported this ‘mixed’ environment, which combines in-person and virtual 
formats. 

The  actions  covered  mainly  best  practices  and  guidelines,  followed  by  customs 
cooperation, which is illustrated by the figure below on output indicator 2.1, sub-indicator 
1, with one collaborative action contributing to multiple areas. 

Figure 4: Number of collaborative actions organised by topic (including expert teams), 
2022-2024 

56

52

45

50

43

31

19

17

18

Best practices
and guidelines

Customs
cooperation

Union law
andpolicy
application and
implementation

3

5

3

Human
competency
building

1

1

2

Innovation

7

7

8

6

4

2

IT capacity
building

Programme
management

Source: Customs programme Annual Progress Reports for  2022-2024  

2022

2023

2024

Beyond  volumes,  the  outputs  from  collaborative  actions  (output  indicator  2.1.3) 
increased sharply over the course of evaluation period. Action managers reported 724 
working practices, guidelines and recommendations in 2022, 1 801 in 2023 and 3 040 in 
2024. These figures reflect a broad interpretation whereby each individual practice within 
a document (and orally exchanged recommendations) counts as an output, and they cannot 
be easily split into ‘Union law’ and ‘other topics’, given the technical breadth. Satisfaction 

20 

 
 
 
with activities (output indicator 2.1.4) remained high across the period, scoring 83.9% 
in 2022, 84.1% in 2023 and 83.7% in 2024, which is well above the MEF’s 70% target. 
Participants most often cited relevance to their daily work, good organisation and useful 
outputs as reasons for their high level of satisfaction. 

Expert teams, which were first introduced under Customs 2020, are led by a Member State 
and include a variable number of participating Member States that have an interest in the 
subject. As of July 2024, there were four live expert teams: 

• 

• 

• 

• 

the expert team on new approaches to developing and operating customs IT systems 
(ETCIT  III),  which  is  the  fourth  phase  of  the  first  expert  team  to  be  set  up  under 
Customs 2020; 

the  expert  team  for  pooling  expertise  to  resolve  complex  cases  of  divergent  tariff 
classification (BTI II); 

the  expert  team  for  pooling  and  sharing  specific  analytical  expertise  of  Customs 
Laboratories at Union level (CLET III); 

the Customs Eastern and South-Eastern Land Border Expert Team (CELBET 3), which 
was  replaced  with  the  European  Union  Customs  Alliance  for  Borders  Expert  Team 
(EUCABET) in 2025. 

Capacity building 

The Customs programme’s capacity-building strand is delivered mainly through the 
Customs  and  Tax  EU  Learning  Portal,  known  as  the  LMS.  There  are  two  formal 
training formats, i.e. IT training workshops and CLEP, which serve distinct purposes. IT 
training workshops are short, technical sessions, often virtual or hybrid, that focus on the 
operation and security of the EES and networks (e.g. ICS2). They equip officials to work 
with newly released functionalities and central services. CLEP are face-to-face, hands-on 
operational courses hosted by Member States, covering practical border-control techniques 
such as car/truck searches, x-ray scanner use, radiation detection and sniffer-dog work. In 
2023, 448 participants attended IT workshops and 13 CLEP events were organised under 
the programme, while in 2024, there were 247 IT training attendances and 16 CLEP events. 
The LMS itself has continued to gain users. There were over 6 000 active and registered 
users in 2024, and co-sharing arrangements with the World Customs Organization (WCO) 
have broadened access and avoided duplication of available learning material. 

EU learning modules have been used to a greater degree by participating countries 
(output indicator 2.2.1)  as new systems have been rolled out. In 2023, 718 modules 
were used – up from 496 modules in 2022 – as new courses were introduced. The figure 
edged up further to 776 modules in 2024, with the smaller increment linked to a change of 
content  contractor  that  year.  In  2023,  courses  accompanying  ICS2  and  Single  Window 
building  blocks  were  added,  while  in  2024,  new  content  covered,  among  others,  ICS2 
(road/rail/maritime and inland waterways), TARIC consultation, GUM and PoUS modules 
for officials and economic operators. Data on participation totals (output indicator 2.2.2) 

21 

 
 
reflect both direct completions and national redistributions of downloaded courses. After 
a  methodological  reset  in  2022  (counting  only  EU  portal  data  plus  CLEP/IT  workshop 
attendance  from  the  Activity  Reporting  Tool),  472 770  professionals  (20 746  customs 
officials;  452 006  others)  were  trained  under  the  programme  that  year.  In  2023,  the 
registered number of professionals trained was 279 338 (248 527 customs officials; 30 811 
others) and in 2024, the number increased to 547 490 (525 540 customs officials; 21 950 
others). 

Quality scores for e-learning (output indicator 2.2.3) remained above target (75%) 
throughout the evaluation period. The score was 75.3% in 2022, 80.1% in 2023, and 
76.6%  in  202412.  The  2023  peak  coincided  with  highly  rated  courses  linked  to  new 
obligations (e.g. CBAM transitional registry), while the slight dip in 2024 reflects ageing 
UCC-law  content.  Sub-scores  for  content,  methodology  and  technology  consistently 
ranged between the mid-70s and the low-80s. 

Figure 5: Quality of e-learning courses by aspect 

Content

Methodology

Technology

77,5%
79,1%

76,8%

75,8%

79,8%

73,9%

77,5%

80,2%

76,6%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

Source: Customs programme Annual Progress Reports for 2022-2024  

2024

2023

2022

12 Participants rate relevance and whether the course met their expectations. 

22 

 
 
 
 
 
 
 
 
4.  EVALUATION FINDINGS 

This chapter assesses the impact of the Customs programme 2021-2027 against the 
criteria of effectiveness, efficiency, coherence, EU added value and relevance. The 
assessment is guided by 13 specific evaluation questions (see Annex III for the 
evaluation matrix and answers to the evaluation questions), which in turn are presented 
under three headings. 

1. To what extent was the intervention successful and why? (effectiveness, efficiency and 
coherence). 

2. How did the EU intervention make a difference? (EU added value). 

3. Is the intervention still relevant as it stands? (relevance). 

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

Effectiveness 

The effectiveness assessment is organised around the programme’s main delivery pillars, 
including the EES), collaborative and human competency activities, and innovation, which 
is treated as a cross-cutting driver that operates through pilots and proofs-of-concept and 
is embedded in the other two pillars. Overall, this interim evaluation assesses how these 
aspects  contribute  to  the  programme’s  general  and  specific  objectives  (a  description  of 
these is provided in Section 2.1 ‘Description of the intervention and its objectives’). 

Effectiveness of the EES 

The  evaluation  confirms  that  the  IT  capacity-building  activities  of  the  Customs 
programme  provide  stakeholders  with  clear  benefits.  Some  of  the  benefits  are  still 
emerging  and  will  take  more  time  to  materialise  fully,  given  the  different  stages  of 
deployment  and  implementation  of  the  systems,  as  well  as  the  delays  and  challenges 
reported.  Findings  from  the  case  studies  confirm  that  the  systems  in  place  are  solid 
foundations, which are already contributing (in the case of ICS2 and PoUS) or are expected 
to  contribute (in the case of  ICG and EU  CCI)  to the achievement of the programme’s 
intended results. EU CCI has already helped Member States to develop their NIS, thereby 
fostering shared knowledge, harmonisation and standardisation at EU level. Thus, there is 
no need for each Member State to create their own specifications for upgrading their NIS 
and  reducing  costs  and  inefficiencies.  However,  the  full  benefits  of  EU  CCI  will 
materialise once the system becomes fully operational. 

Individual  digital  systems  or  clusters  of  systems  are  helping  to  varying  degrees  to 
support  the  Customs  programme’s  four  specific  objectives.  As  indicated  above,  the 
four  systems  examined  in  the  case  studies  contribute  to  one  or  more  of  the  specific 

23 

 
 
 
objectives.  In  the  first  years  of  programme  implementation,  support  for  the  coherent 
implementation of EU law and policy (specific objective 1) and for cooperation (specific 
objective 2) have been more effective and visible than support  for IT capacity building 
(specific objective 3) and innovation (specific objective 4). 

While  most  of  the  digital  systems  assessed  contribute  to  supporting  the  programme 
objectives individually, the ICG (which contributes to specific objectives 2 and 3) is an 
example of a cluster. The ICG has been integrated from the go-live date of 28 June 2025 
with EU CSW-CERTEX (EU Customs Single Window Certificate Exchange System)13. 
EU CSW-CERTEX ensures interoperability between customs and non-customs domains. 
In this case, this means ensuring that the import licences (i.e. a form of certificate) issued 
by  competent  authorities  (generally  a  ministry  of  culture)  are  recognised  as  such  by 
customs authorities. The ICG has been developed as a module of DG SANTE’s TRACES 
system and it is the first DG TAXUD system to use EU CSW-CERTEX. 

Evidence from the first years of implementing the programme confirms that the EES 
help to implement Union law and policy coherently (specific objective 1). In fact, as 
documented in the UCC progress reports, and confirmed in the case studies conducted, the 
digital systems financed by the programme have been fundamental for implementing the 
UCC legal provisions. This is also reflected in the trajectory of the MEF’s corresponding 
results  indicator  1.2.  Feedback  from  national  customs  authorities  surveyed  by  the 
programme  management  has  steadily  improved  during  the  first  three  years  it  was 
measured, with the figures for 2023 and 2024 exceeding the 70% target set14. This indicator 
reflects positive perceptions of the contribution made by the new common components of 
the EES to implementing Union law and policy coherently. 

The annual progress reports for 2021-2024 and consultations with DG TAXUD provide 
several  examples  of  how  the  most  important  contributions  and  achievements  of  the  IT 
capacity-building  activities  have  supported  the  EU’s  customs  legislation  and  policy 
priorities. These activities include: (i) programme support to launch the VAT e-commerce 
package; (ii) the full integration of Ukraine as a beneficiary of the EU Customs Common 
Transit Convention, enabling Ukraine to be connected to the NCTS; (iii) the preparation, 
as part of Ukraine’s pre-accession strategy, of future connections to crucial EU IT customs 
systems to facilitate trade flows; (iv) support to design and develop the ICS2 system; and 
(v)  the  deployment  of  CRMS2.  CRMS2  significantly  improved  the  sharing  of  risk 
information and communication between Member States’ experts dealing with risks and 
risk management. 

13  EU  CSW-CERTEX  is  designed  to  improve  digital  cooperation  and  coordination  between  customs 
authorities and partner competent authorities for better integrated, faster and simpler paperless processes 
for goods clearance and better enforcement of and compliance with Union non-customs formalities, see 
recital 9 of Regulation (EU) 2022/2039. 

14 Corresponds to national authorities’ approval rating from “fully disagree”/0% to “fully agree”/100% with 
the statement that “the new common components of the EES facilitate coherent implementation of Union 
law and policy”. 

24 

 
 
As the only EES selected for a case study that was expected to contribute to the specific 
objective  of  coherent  implementation  of  Union  law  and  policy,  ICS2  was  explicitly 
designed  to  fulfil  the  obligations  set  out  in  the  UCC  and  related  regulations  (see  box 
below). 

Box 1: Contribution of ICS2 to specific objective 1 (coherent implementation of Union law 
and policy) 

The new system (unlike its predecessor) is a better (if not watertight) guarantee of the 
uniform  implementation  of  the  UCC.  The  shared  trader  interface  with  common 
specifications, and a centrally managed common repository for exchanging information, 
are  marked  improvements  compared  with  ICS1,  which  was  completely  decentralised 
(and therefore not fully harmonised). However, while many traders consider that the EU 
has gone in the right direction with the central components, they feel that it has not gone 
far enough to fully realise the benefits of harmonisation. There is seemingly a tension 
between what is desirable for trade and what is politically feasible at Member State level, 
given the need to retain sovereignty over risk analysis and entry systems. 

While  there  is  also  evidence  that  the  EES  support  cooperation  between  national 
customs  administrations  (specific  objective  2),  work  is  still  ongoing  at  EU  and 
Member  State  level  to  further  harmonise  and  centralise  processes  through 
completing  the  UCC  and  the  proposed  customs  reform15.  The  result  from  the 
programme management’s surveys of national customs authorities for the results indicator 
2.2.1, which captures positive perceptions of the contribution of new common components 
of the EES to facilitating operational cooperation between national authorities, shows that 
levels of agreement rose from 62% in 2022 to 72% in 2023, and slightly declined to 71% 
in 2024. However, the values were still below the 75% annual target. Other relevant MEF 
result indicators measuring cooperation, such as the number of consultations and system-
to-system messages exchanged, are on track to achieve or exceed the targets set for the 
whole programming period. 

Findings from the survey of national customs authorities confirmed widespread consensus 
among respondents that the EES significantly benefited communication between countries. 
This was especially the case for communication between the EU Member States, with 23 
out  of  24  respondents  who  provided  an  assessment  believing  that  administrative 
cooperation and the exchange of information between Member States would be affected to 
a  high  extent  or  more  if  the  Customs  programme  no  longer  supported  the  common 
components  of  the  EES.  This  was  also  true  for  the  communication  between  the  EU 
Member States and potential candidate countries (23 out of 25 respondents) and between 
the EU and non-EU countries (16 out of 21 respondents). 

15 The EU Customs Reform put forward a series of proposals on 17 May 2023 for the most ambitious and 
comprehensive reform of the EU Customs Union since its establishment in 1968. For more details, see 
https://taxation-customs.ec.europa.eu/customs-4/eu-customs-reform_en. 

25 

 
 
 
 
Findings from the IT case studies suggest that while all four systems assessed in depth are 
intended  to  improve  cooperation  between  national  administrations,  the  extent  to  which 
collaboration has materialised in practice varies and can take some time to consolidate. 

Box  2:  Contribution  of  the  selected  EES  to  specific  objective  2  (cooperation  between 
national customs administrations) 

ICS2 is intended to increase opportunities for closer cooperation on risk analysis within 
Member  States  and  between  customs  and  other  governmental  agencies.  Customs 
authorities indicated that this cooperation is nascent and is also challenged by the fact 
that some Member States are not willing to share highly sensitive data on risks. This is 
in line with the fact that the Safety and Security Analytics (SSA) element is ongoing. 
Nevertheless,  the  authorities  expect significant benefits  from  developing  the SSA for 
more effective and efficient risk analysis. 
Customs and competent authorities cooperated closely via a project group to develop 
the ICG. One of its key functionalities is an administrative cooperation module that will 
enable  these  competent  authorities  to  exchange  information,  either  bilaterally  or 
multilaterally, in the context of an import licence application process. 
By improving the uniformity of the procedures across the EU, the PoUS system helps to 
set up a more consistent, harmonised and simplified process related to customs clearance 
for Union goods, thereby improving cooperation between customs authorities. Another 
advantage of PoUS is that a central system solution eliminates the risk of using false 
paper-based  T2L  documents  in  the  destination  country,  as  data  is  simultaneously 
accessible  in  the  country  of  departure  and  to  the  customs  authorities  of  the  Member 
States  of  submission.  More  visible  benefits  are  expected  when  the  system-to-system 
solution  is  released  and  the  transitional  measures  currently  used  by  large  traders  in 
several Member States are discontinued. 
The EU CCI system is intended to contribute directly to fostering collaboration among 
customs  authorities,  enabling  the  supervising  customs  offices  and  the  presentation 
customs  offices  to  act  as  a  unified  entity  with  joint  responsibility  for  the  risk 
management, controls and clearance of goods imported into the EU. 
The  system  will  provide  a  uniform  framework  and  a  standardised  procedure  for 
centralised  clearance,  which  is  expected  to  promote  a  more  integrated  approach  to 
customs management within the EU. In terms of the system’s early achievements, the 
EU CCI common specifications helped Member States to make progress in developing 
and/or upgrading their national import systems, which is a purely national matter that 
further harmonises the import customs process and the VAT rules at EU level.  

During the first years of the programme, the new common components of the EES 
contributed  increasingly  to  IT  capacity  building  (specific  objective  3).  These 
contributions include: (i) improving national customs authorities’ perceptions under results 
indicator 3.2.1, which measures the contribution of new common components of the EES 
to improving the operational performance of national authorities (although values are still 
below the target); (ii) increasing the number of applications by system (results indicator 
3.1.2); and (iii) providing positive examples of progress in the development, deployment, 
and achievements of EES (as reported in the annual progress reports). The purpose of all 
four digital systems reviewed in the case studies is to support IT capacity building. As with 
the previous objective, the extent to which effective support for IT capacity building has 

26 

 
 
occurred varies, given that each system is in a different stage of development and operation 
(see box below for further details on the contribution of each EES assessed through the 
case studies). 

Box 3: Contribution of selected EES to specific objective 3 (IT capacity building) 

their 

to  focus 

Most  Member  State  authorities  agree  that  –  given  the  technical  specifications,  the 
competing demands and priorities facing Member States (not to mention the fact that 
they invested in developing ICS1 not that long ago) – without the programme funding, 
ICS2  would  not  have  been  achieved  on  schedule  in  its  current  form  and  with  the 
noteworthy  benefits  it  provides.  In  addition,  the  fact  that  certain  components  were 
centralised  enabled  customs  authorities 
limited  resources  on 
complementary aspects. The exploration of the counterfactual confirmed that national 
IT  infrastructure  often  lacks  the  capacity  to  meet  technical  requirements,  making 
Member States heavily reliant on external providers. 
The ICG is  a new European information system that will digitise from the outset the 
requirements  of  a  new  import  process  under  Regulation  2019/880  on  the  import  of 
cultural goods, illustrating how centralised development is appropriate in this scenario. 
The PoUS system contributes to enhancing IT capacity building at national level. It was 
introduced in response to a clear legal requirement to move away from the issuing and 
presentation  of  paper-based  or  commercial  documents  to  prove  the  Union  status  of 
goods, which differed across Member States, to an electronic and harmonised process 
that would be implemented uniformly in all national customs administrations across the 
Member States. The benefits for national customs authorities include: (i) the consistent 
management  of  proofs  across  the  EU  (through  standardised  processes);  (ii)  a  lower 
administrative burden (as a result of lodging electronic requests); (iii) better traceability 
and  transparency  of  data;  (iv)  lower  risk  and  costs  of  undetected  fraud;  (iv)  better 
management  of  the  Union  status  of  goods  and  stronger  focus  on  non-compliant 
behaviour (through the online availability of information on registered proofs); and (v) 
simplification to one single point of access for retrieving electronic proofs (through the 
availability of a central repository). 
The  EU  CCI  common  specifications  helped  Member  States  to  make  progress  in 
developing and/or upgrading their national import systems, which is a purely national 
matter.  The  widespread  use  of  the  EU  CCI  common  specifications  reflects  their 
significant  value to  Member States in  developing  their national  import systems  more 
efficiently.  The  most  valued  features  included  a  standardised  framework  promoting 
consistency  and  compliance  among  Member  States,  smoother  integration  with  both 
national systems and the EU customs environment and clear, comprehensive guidelines 
for implementing processes and defining system requirements. 

The extent to which individual digital systems or clusters of systems have contributed 
to  innovation  (specific  objective  4)  is  less  evident.  National  customs  authorities’ 
perceptions of how new common components of the EES have contributed to innovation 
in the area of customs (reflected in results indicator 4.1) have remained unchanged over 

27 

 
 
the years, with the annual values being 10 percentage points below the 70% target16. The 
fact  that  innovation  –  both  as  a  specific  objective  and  as  an  eligible  action  type  –  was 
introduced for the first time in the current programme may partly explain the low numbers. 
The annual progress reports did not provide any concrete examples of ways in which the 
new  common  components  of  the  EES  had  contributed  to  this  specific  objective,  even 
though the last two reports’ narrative was more positive about achievements in this area. 

Findings from the case studies suggest that, of the four IT systems assessed, ICS2 is the 
only  one that most explicitly aims to  contribute to the specific objective  of innovation. 
Several of the Member States consulted highlighted the benefits that the automation of risk 
analysis processes provides through digitising data. ICS2 facilitates the use of advanced 
algorithms and automation technologies to analyse entry summary declaration data. 

The  EU  CCI  introduces  a  groundbreaking  innovation  by  seamlessly  integrating  with 
national import systems for the first time, establishing a unified and sophisticated customs 
framework that aligns national practices with EU-wide objectives. The EU CCI system is 
set  to  improve  the  efficiency,  harmonisation  and  coordination  of  import  customs 
operations  across  the  EU,  showcasing  significant  advancements  in  building  a  more 
interconnected  and  efficient  customs  infrastructure.  Enabling  customs  authorities  in 
different Member States to operate collectively as a single entity for the clearance of goods 
under  the  CCI  framework  is  another  of  the  EU  CCI  system’s  pivotal  innovations.  The 
customs authorities share collective responsibility for risk management, complying with 
both  fiscal  and  non-fiscal  regulatory  requirements,  implementing  more  harmonised  and 
efficient controls, as well as calculating and collecting duties and other charges. 

The ICG has been ‘future-proofed’ by being set up flexibly enough for AI to be used in 
future to identify fakes or cultural goods with a manifestly understated value. This is an 
innovation that is likely to be implemented when a common export system is introduced 
later  this  decade.  Officials  are  closely  following  developments  in  this  area,  including 
projects funded under Horizon Europe. 

Evaluation  findings  confirm  that,  despite  some  early  results,  it  is  still  too  early  to 
assess the extent to which individual digital systems or clusters of systems have helped 
to support the three general objectives of the Customs programme, i.e.: (i) protecting 
the financial and economic interests of the EU and its Member States, (ii) ensuring 
security and safety within the EU; and (iii) protecting the EU from unfair and illegal 
trade, while facilitating legitimate business activity. 

The  case  studies  show  that  the  most  concrete  example  is  ICS2  and  its  contribution  to 
ensuring  safety  and  security  within  the  EU  (general  objective  2).  The  new  centralised 
system improves the EU’s ability to detect high-risk consignments arriving by all modes 
of transport before they enter the EU. The new centralised system does this by drawing on 

16 Corresponds to national authorities’ approval rating from “fully disagree”/0% to “fully agree”/100% with 
the statement that “the new common components of the EES play a key role in facilitating innovation in 
the area of customs authorities”. 

28 

 
 
more  detailed  data,  improved  data  quality,  supporting  more  sophisticated  risk  analysis 
processes  and  earlier  intervention  across  all  transport  modes,  compared  with  its 
predecessor. The ICG could also be considered to contribute to this objective, since cultural 
goods  trafficking  in  its  various  forms  (including  subsequent  money  laundering)  can  be 
used to finance terrorism or organised crime. 

All four digital systems assessed through the case studies are expected to contribute 
to  protecting  the  EU  from  unfair  and  illegal  trade,  and  to  facilitating  legitimate 
business activity (general objective 3). ICS2 and PoUS have already delivered concrete 
benefits, and the first contributions from the other systems are expected when the ICG goes 
live on 28 June 202517, and when the EU CCI becomes available for use by authorised 
traders at the end of 2025 and then by all Member States in 2026. In particular, the new 
centralised ICS2 has proved that it can help with detecting and seizing goods that are non-
compliant  or  pose  a  security  risk.  Several  Member  States  highlighted  during  the 
stakeholder consultation 

 that postal consignments, in particular, have seen a significant increase in such goods. At 
the  same  time,  several  stakeholders  noted  that,  despite  the  improvements,  there  are 
significant  issues  with  data  quality,  also  for  postal  consignments,  where  a  lack  of 
awareness or understanding (especially, but not exclusively, among private individuals) 
leads to incomplete, and/or poor-quality data. 

Through the issuing of standardised documents across the EU, the new PoUS results in 
fewer  errors,  improved  data  accessibility  and  reduced  opportunities  for  bad  actors. 
However, some economic operators argue that effectiveness is limited by the current lack 
of a system-to-system functionality for them. 

Effectiveness of collaborative activities 

In line with the findings from previous evaluations, the interim evaluation confirms that 
collaborative activities are yielding the expected results, as evidenced by feedback from 
national customs authorities and the quantitative results indicators outlined in the MEF. 
The feedback from national customs authorities provided in the online survey18 indicates 
that  stakeholders  can  identify  clear  benefits  stemming  from  the  collaborative  activities. 
The  main  benefits  are:  (i)  networking  opportunities;  (ii)  learning  opportunities  and 
exchange of best practices; (iii) ownership of common solutions to common problems; (iv) 
opportunities for solving problems; and (v) opportunities to input into solutions that are 
effective for national situations. The detailed answers are presented in the figure below. 

17  As  highlighted  above,  ICG  is  the  first  DG  TAXUD  system  that  is  mandatory  under  the  Regulation 
introducing the EU Customs Single Window Certificates Exchange System (EU CSW-CERTEX) within 
the EU Single Window Environment for Customs legal framework. 

18 The detailed findings of the online survey with national customs authorities are presented in Annex V to 

this report. 

29 

 
 
 
Figure  6:  To  what  extent  would  each  of  the  following  be  affected  if  funding  from  the 
Customs programme for collaborative actions was reduced or eliminated? 

Networking opportunities

Opportunities to learn from approach in other
Member States, such as through the exchange of…

18

15

9

1

1

10

2

1

Ownership of common solutions to common
problems

13

8

5

1

2

Opportunities to problem-solve

10

9

Opportunities to input into solutions that are effective
for national situation

6

13

8

8

1

1

1

1

Other

2

5

Significant extent High extent Moderate extent Minor extent Don't know/Not applicable

Source: National survey addressed to Member States and submitted to the Commission 

National customs authorities clearly indicate that they find these actions valuable. In the 
survey, all the national customs authorities believed that the expert teams, the European 
Customs Coordination Group (ECCG) and other collaborative actions were useful, with 
most  of  the  authorities  finding  the  actions  very  useful  (expert  teams:  18  out  of  27 
respondents, ECCG: 21 out of 27, other collaborative activities: 21 out of 29), as presented 
in the figure below. 

Figure 7: How useful are the following to the work of your administration? 

21

21

18

9

8

0

0

0

0

4

2

0

Expert teams

Other collaborative actions

ECCG

Very useful Useful Not very useful/Not useful at all Don’t know/Difficult to say

Source: National survey addressed to Member States and submitted to the Commission 

National customs authorities reaffirmed the overall positive assessment of collaborative 
activities’ contribution to better operational customs cooperation (specific objective 2). In 
the  online  survey,  nearly  all  administrations  agreed  that  the  collaboration  and  training 

30 

 
 
 
 
 
activities funded by the programme foster collaboration and trust building among Member 
States, with a significant majority (24 out of 30) strongly agreeing with this statement, and 
the remaining 5 out of 30 tending to agree19. 

The interim evaluation confirms that collaborative activities contribute to the preparation 
and  uniform  implementation  of  customs  legislation  and  policy  (specific  objective  1), 
support  for  customs  cooperation  (specific  objective  2)  and  capacity  building  (specific 
objective 3). In contrast, collaborative activities contribute to a lesser extent to delivering 
innovation  (specific  objective  4).  According  to  data  from  the  Annual  Reporting  Tool 
(ART),  collaborative  activities  contribute  primarily  to  customs  cooperation  (62%  of 
actions were classified as supporting this objective) and support for the preparation and 
uniform implementation of customs legislation and policy (21% of actions). However, the 
number of events organised within these actions was more evenly distributed across the 
three specific objectives: 35% of the events were organised for the preparation and uniform 
implementation of customs legislation and policy (specific objective 1), 28% for customs 
cooperation (specific objective 2), and 30% for capacity building (specific objective 3). 
Innovation (specific objective 4) was addressed in only 2% of actions and 0.2% of events. 
(See the next section for further details on innovation). 

In  2024,  the  programme  contributed  to  the  preparation  and  uniform  implementation  of 
customs legislation and policy (specific objective 1) by, for instance, supporting seminars 
on key topics for the future of customs, such as e-commerce, the future digital landscape 
and  trust-based  facilitations  for  economic  operators.  The  programme  also  helped  the 
enlargement countries with their integration into the EU acquis for customs, and continued 
to support uniform implementation of sanctions related to Russia’s full-scale invasion of 
Ukraine.  In  the  area  of  customs  cooperation  (specific  objective  2),  the  programme 
supported  156  physical  meetings,  133  virtual  meetings  and  18  hybrid  meetings  (with 
almost  6 000  participants)  and  working  visits  (with  147  participants).  In  the  area  of 
capacity building (specific objective 3), 10 new e-learning courses were developed with 
the support of the programme20. 

In  most  cases,  the  collaborative  actions’  performance  indicators  achieved  their  target 
values in the first three full years of the programme (2022-2024). The perceived quality of 
collaborative actions remains high, exceeding 80% in all three years, which is well above 
the  target  of  70%.  Some  indicators  decreased  between  2022  and  2023,  but  they 
subsequently increased again in 2024. An example of this is the  percentage of national 
officials  reporting  that  their  authorities  adopted  a  working  practice,  guideline,  or 
recommendation  developed  with  the  support  of  the  programme.  Despite  year-to-year 
fluctuations, the value of this indicator remains above the target of 75%, thereby helping 
to improve customs authorities’ capacity (specific objective 3). 

19 None of the administrations disagreed, one answered ‘Don’t know’. 
20 European Commission, COMMISSION STAFF WORKING DOCUMENT. Customs programme Annual 
final, 

Progress  Report 
https://data.consilium.europa.eu/doc/document/ST-8243-2025-INIT/en/pdf. 

2024,  Brussels, 

SWD(2025) 

23.4.2025, 

year 

113 

on 

31 

 
 
A similar trend was observed in the user satisfaction with PICS (the online collaboration 
platform) which is the programme’s key platform for facilitating collaboration. The level 
of  user  satisfaction  declined  between  2022  and  202321  but  increased  again  in  2024  to 
70.1%.  This  indicator  continues  to  meet  its  target  value  of  70%,  indicating  that  the 
programme  is  contributing  more  to  better  operational  cooperation  between  customs 
authorities (specific objective 2). However, the target value of this indicator will further 
increase to 75% in 2025. 

National  authorities’  assessment  of  how  collaborative  and  human  competency  actions 
contribute to improving their operational performance reveals a positive trend. This saw a 
significant  increase  of  eight  percentage  points  in  2024  to  nearly  69%  (close  to  the 
previously unattained target value of 70%), thereby further helping to improve customs 
authorities’ capacity (specific objective 3), as presented in the figure below. 

Figure  8:  Contribution  of  collaborative  and  human  competency  actions’  outputs  to 
improving national authorities’ operational performance (%) 

59,68%

60,57%

68,75%

70%

100,00%

50,00%

0,00%

2022

2023

2024

Target

Source: Customs Programme Annual Progress Reports for 2022-2024  

Finally, the interim evaluation confirms that the LMS portal contributes significantly to 
the  uniform  implementation  of  customs  legislation  by  all  Member  States  (specific 
objective 1) and to customs cooperation (specific objective 2), by serving as a common 
training and knowledge-sharing platform. 

The LMS is a more effective tool than the combination of approaches used previously. The 
number of both public- and private-sector users has grown significantly since its launch in 
May 2021. Stakeholders’ feedback provided in the LMS survey22 indicates that the portal 
is widely regarded as an effective one-stop shop for training opportunities (79%) and has 

21 In 2023 the drop could be explained by the launch of the platform ‘Open Social’ which could have lowered 
user satisfaction during the transition phase, according to the Manual for the collection of indicators for 
the Customs programme. 

22 The survey of LMS users, which was launched on 17 February 2025, and closed on 10 March 2025, was 
a joint survey on behalf of this case study and the parallel case study for Fiscalis. Of the 62 respondents, 
47 had an interest in customs, and were included in the analysis for this case study. Of those, 41 (87%) 
were  from  national  authorities,  6%  (3  respondents)  were  part  of  other  Customs  entities  (e.g.  Tax & 
Customs Academy), 4% (2 respondents) belonged to companies, and 2% (1 respondent) belonged to an 
academic/research institution. 

32 

 
 
 
 
increased participation in DG TAXUD e-learning modules (79%) and in CLEP training 
events (56%). Moreover, 71% of the respondents confirmed that they recommend the use 
of  the  portal  to  others.  LMS  users  mostly  consider  the  portal  to  be  effective  for 
collaborative activities (83%) and user-friendly (80%), but there appear to be issues around 
ease of navigation, with only 63% rating it as good or very good. This is one of several 
issues identified where fine-tuning is needed now that the portal has reached its cruising 
speed. 

Innovation 

The implementation of innovation during the first years of the current Customs programme 
faced conceptual challenges. 

Innovation was introduced in the programme for the first time, both as a specific objective 
and an eligible action type. Therefore, it was deemed necessary first to discuss and agree 
internally on the scope of the notion of innovation and to operationalise how it would be 
implemented in line with the conclusions in the action plan after the final evaluation of the 
predecessor Customs programme23. 

The internal discussions were effective in creating awareness of the need for a more 
widespread  use  of  innovation  in  the  upcoming  years  and  the  development  of  an 
assessment matrix to define the scope of innovation. 

The adoption of the broad definition of the concept of innovation and the confirmation that 
innovation does not need to be associated exclusively with the eligible actions identified 
in the Regulation paved the way for the programme’s existing mechanisms (collaborative 
and  training  activities,  digital  systems)  to  contribute  to  this  specific  objective.  The 
narratives  in  the  2023  and  2024  annual  progress  reports  reflect  this  development  and 
present examples of several activities featuring an innovation component. For example, 
the  annual  progress  reports  also  identified  progress  in  facilitating  the  work  of  customs 
laboratories in exploring and adapting to emerging technologies, innovative equipment and 
scientific analytical methodologies. 

Despite the positive narrative and examples, the results of the relevant programme output 
and the result indicators confirm that the innovation targets have not been achieved. During 
the first three years of the current programming cycle, the MEF indicator values linked to 
innovation  have  systematically  scored  below  the  targets  set.  In  particular,  the  result 
indicators on the extent to which new common components of the EES (result indicator 
4.1)  and  collaborative  and  human  competency  actions’  outputs  (result  indicator  4.2) 
contributed to innovation in the area of customs policy received scores between 56.3% and 

23 The internal reflection within DG TAXUD (which was a joint exercise also conducted for Fiscalis) aimed 
to  make  progress  in  several  important  aspects  that  required  consideration,  including  how  to  tackle 
innovation as an objective of the programme and as an eligible action type, and ways to ensure synergies 
with other EU programmes and innovation activities. 

33 

 
 
 
63.4%  (compared  with  targets  of  70%  in  both  cases).  While  indicator  4.1  on  the 
contribution of IT systems to innovation has remained stable over the years, indicator 4.2 
on  the  contribution  of  the  outputs  of  collaborative  and  human  competency  actions  to 
innovation registered its highest value in 2024 and is the closest to the target of 70%. 

Against  the  backdrop  described  above,  there  are  still  unresolved  challenges  and 
potential opportunities linked to innovation. Unresolved challenges include a risk that 
the concept will become too broad, thereby losing sight of the real notion of innovation, 
which should be linked to creating new ways of working, new processes and insights, or 
to developing new technologies or applications of state-of-the-art technologies. In terms 
of potential opportunities, findings from the evaluation suggest that it would be important 
to find ways to tap into potential synergies with other EU programmes and initiatives. As 
further  developed  under  the  coherence  section,  the  lack  of  mechanisms  to  ensure 
systematic collaboration with Horizon Europe is an obvious example. 

Achievement of the general and specific objectives 

The effects of the programme identified through this interim evaluation confirm that 
the  programme  is  contributing  to  its  specific  objectives  and  supporting  the 
achievement of the general objectives. 

As discussed above, progress has been positive but uneven, and in the cases explored in 
depth, the investments made have yet to fully deliver their expected results. All but 5% of 
the  2021-2027  programme  budget  is  dedicated  to  the  EES.  In  the  first  years  of  this 
programming  period,  progress  has  been  most  notable  under  the  first  general  objective: 
security  and  safety  within  the  EU.  This  progress  has  been  driven  by  the  significant 
investments made in ICS2, which make it possible to carry out  better risk analysis, but 
also  by  sharing  risk  information  through  CRMS2.  Both  of  these  measures  are  already 
bringing  benefits  and  can  be  expected  to  continue  to  do  so.  The  ICG  contributes  to 
preventing the illicit trafficking of cultural goods (such as looted, stolen or forged cultural 
goods) and has the potential to disrupt this illicit source of income for organised crime and 
terrorism. Therefore, the ICG is expected to also make a contribution to the first general 
objective. 

ICS2 and other systems, such as the ICG, EU CCI and PoUS, are making or are expected 
to make a significant contribution to the second general objective, which is to protect the 
EU from unfair and illegal trade and facilitate legitimate business activity. Indeed, in 
the case of ICS2, the available data (for 2021 and 2022) show that seizures have increased 
for most categories of goods compared to the baseline values (in particular explosives24 
but also goods posing a risk to consumers25 and counterfeit goods26). This suggests that the 

24 Up from 7 500 in 2019, to 6.7 million items seized in 2022 (probably explained in part by Regulation (EU) 
2019/1148  on  the marketing and  use  of  explosives  precursors  which  updated  the  rules  for  explosive 
precursors, effective from 2021 (see https://ec.europa.eu/commission/presscorner/detail/en/ip_19_849). 

25 Up from approximately 32 000 in 2019, to closer to 35 000 in 2022. 
26 From 91 000 in 2019 to 24.2 million in 2022. 

34 

 
 
 
control and risk management arrangements  in  place are effective.  It  is  also  plausible to 
assume that the impact of ICS2 (which is not yet fully reflected in the data) and of the other 
systems will support further progress towards these general objectives. As concerns the 
EU CCI, its common specifications are helping Member States to upgrade their national 
import systems, which (when fully deployed) will improve the efficiency, harmonisation 
and coordination of import customs procedures across Member States, contributing to the 
overall competitiveness of the EU in international trade. 

With regards to the third general objective of the programme, the detailed analysis of the 
systems  did  not  reveal  significant  progress  in  the  protection  of  the  financial  and 
economic interests of the EU and its Member States. However, the ICG is expected to 
do so in the future, by contributing to the fight against organised crime (including money 
laundering) and terrorism. Furthermore, other vital procedures currently in place27 and IT 
systems that are routinely maintained and updated continuously support this objective. In 
the current context of tariff uncertainty, TARIC, which provides detailed up-to-date tariff 
information to both customs administrations and economic operators, ensures accurate and 
consistent  application  of  customs  duties  at  the  border.  The  limited  available  data  on 
impacts to date suggests that the amount of detected unpaid duties is increasing28, as is the 
number  of  detected  instances  of  fraud  and  irregularities29,  which  indicates  –  somewhat 
counterintuitively – that customs checks are effective. 

Meanwhile, although the budget for collaborative activities is (by comparison) small, these 
activities are an important complement to the resource-intensive IT activities. By enabling 
exchanges and opportunities for joint problem-solving, the collaborative activities support 
the design of more effective systems and ensure consistency with other policy areas. As 
importantly, they help create relationships/networks among customs officials and foster a 
collaborative  culture.  Numerous  examples  are  provided  in  the  annual  progress  reports 
(2021-2024) demonstrating the tangible results from these activities. Indeed, the research 
conducted  for  the  case  studies  confirmed  the  role  of  the  associated  project  groups  in 
facilitating exchanges of knowledge and best practices for the development of the systems 
investigated in detail. 

Programme support for capacity building has also increased during the early years of the 
programme  with  the  rollout  of  the  new  LMS.  While  there  are  still  aspects  of  the  LMS 
which can be improved, it is a more effective tool than those preceding it, and it is valued 
by users. 

The  Customs  programme’s  support  for  common  components  of  the  EES 
complemented  by 
full 
implementation of the UCC systems, though challenges remain. 

the  national  components  are  progressing 

towards 

27 For example, cash above EUR 10 000 crossing the border is routinely monitored by customs. 
28 From nearly EUR 525 million in 2021 to closer to EUR 785 million in 2022. 
29 From around 4 000 in 2021 to around 4 660 in 2022. 

35 

 
 
While  programme  support  is  central  to  the  delivery  of  the  common  components,  full 
implementation relies on complementary national components (which the programme does 
not support) being delivered on time. However, 40% of Member States are experiencing 
delays  in  the  delivery  of  the  national  components,  with  10-15%  experiencing  serious 
delays 30. The delays are attributed to management issues, shortages of human and financial 
resources, delayed procurement processes and an array of external factors (including the 
continued impact of Brexit and COVID-19, the Russian war of aggression in Ukraine)31. 
For systems that require national components to be operational, the in-depth case studies 
demonstrate  the  negative  impact  of  delays  in  the  delivery  of  the  respective  national 
systems. For example, the timely rollout of the EU CCI is dependent on national import 
system  upgrades  (the  responsibility  of  Member  States);  delays  in  these  upgrades 
automatically affect the timely development of the EU CCI system. The ICS2 also relies 
on interconnected national components (i.e. the national presentation systems) that have 
not  been  fully  implemented  yet.  This  means  that  the  benefits  of  the  EU  central  system 
cannot be fully realised. 

DG TAXUD has communicated and disseminated information on the achievements 
and opportunities of the Customs programme, but more can be done in this regard. 

DG  TAXUD  has  kept  stakeholders  informed  of  developments  by  publishing  annual 
progress  reports,  organising  high-level  seminars32  and  maintaining  informative  online 
platforms. These efforts have enhanced transparency and encouraged active participation 
among  Member  States  and  economic  operators  alike.  However,  there  is  still  scope  to 
further improve communication and stakeholder engagement (see section on relevance). 

Efficiency 

The efficiency of the Customs programme depends on how effectively the inputs (costs) 
deliver  achievements  and  the  performance  of  the  programme  governance  mechanisms 
during the period covered by the current MFF. This is assessed in four questions, which 
look at the following aspects: 

•  cost-effectiveness of the EES; 
•  cost-effectiveness of programme funding for collaborative activities; 
•  cost-effectiveness of programme funding for human competency activities; 
•  performance of the programme’s governance mechanisms. 

30 According to the UCC Annual Progress Report, 2023. 
31 Ibid. 
32 For example, high-level seminars held during the Belgian and Hungarian Presidencies of the Council of 
the  EU  provided  greater  clarity  on  topics  such  as  e-commerce  and  the  future  digital  landscape  as 
confirmed in the Annual Progress Report for 2024. More recently, in April 2025, a high-level seminar 
under  the  Polish  Presidency  of  the  EU  was  used  as  an  occasion  to  highlight  the  role  of  customs  in 
security. 

36 

 
 
 
Cost-effectiveness of the EES 

The evaluation findings confirm that the costs of the common components of the EES 
financed by the Customs programme are proportionate to the programme objectives. 
The investments made in the early years of the current programming period – particularly 
in the common components of digital systems – are more cost effective compared to the 
counterfactuals considered33. Evidence from the IT case studies supports this conclusion 
for all the systems assessed34. 

For the ICS2, national customs authorities estimated that the distributed alternative would 
cost Member States between two to four times more than the centralised system actually 
in  place.  Additionally,  a  centralised  ICS2  ensures  efficient  use  of  computing  power, 
storage and networking resources, avoiding duplication across Member States. A single 
centralised investment in high-capacity infrastructure is a better way to ensure long-term 
scalability  and  adoption  of  emerging  technologies.  The  centralised  system  in  place  can 
dynamically allocate resources based on demand, preventing under-utilisation or overload 
in individual Member States, among other benefits. Indeed, Member States struggled to 
identify clear advantages associated with the counterfactual scenario. 

Feedback  collected  for  PoUS  confirms  that  under  a  fully  distributed model,  the  overall 
financial burden on national budgets would be more than five times higher than under the 
hybrid system, with notable increases in both investment and operating costs. The PoUS 
case  study  also  tested  a  second  counterfactual  scenario  that  would  require  adapting  the 
existing  NCTS  to  incorporate  the  PoUS  functionality.  Feedback  from  Member  States 
indicates that, in this scenario, the total financial burden on national budgets would also 
exceed  that  of  the  hybrid  system.  All  Member  States  expressed  concerns  about  higher 
development  and  maintenance  costs  associated  with  such  a  scenario,  including  initial 
development, long-term maintenance and training expenses. 

Member States also estimate that programme support for the EU CCI system is more cost 
effective  compared  to  an  alternative  scenario  in  which  Member  States  would 
independently  develop  or  upgrade  their  NIS,  without  access  to  common  specifications 
provided by the Commission. The common specifications have been widely used by the 
Member  States,  resulting  in  efficiency  gains.  As  with  ICS2  and  PoUS,  Member  States 
found it challenging to identify clear benefits associated with the counterfactual scenario. 
The  potential  benefits  of  the  centralised  clearance,  particularly  for  economic  operators, 
remain promising and the above-mentioned NIS upgrade brings additional harmonisation 
in the customs declaration requirements for traders and the import processes at EU level. 
However, comprehensive data to quantify these benefits is not yet available; the precise 
cost-benefit ratio can be determined only once the system is fully deployed and becomes 

33 Annex II provides more detailed information on the methodological approach used to quantify the cost-

effectiveness of the common components of the EES. 

34 See Annex II for further details on the methodological approach underpinning the IT case studies. 

37 

 
 
 
fully  operational.  Without  shared  specifications  and  central  components,  each  Member 
State  would  incur  considerable  costs  due  to  the  need  to  maintain  fragmented  national 
procedures,  resulting  in  reduced  global  competitiveness  and  increased  administrative 
burdens on national customs authorities. 

No counterfactual was developed for the ICG as this system was developed from scratch, 
i.e. there was no predecessor system, and no basis  on which to determine the costs and 
benefits of an alternative option. However, the fact that the ICG is being developed as a 
module of an existing system (DG SANTE’s TRACES system) is already an indicator of 
its  cost  effectiveness.  This  module  is  expected  to  significantly  improve  administrative 
cooperation and exchange of information, which currently often relies on emails and phone 
calls.  The  collection  of  data  at  EU-level  on  the  import  of  cultural  goods,  which  had 
remained highly fragmented until this system went live on 28 June 2025, will also be more 
efficient as there will be a common statistical basis. Even without a clear counterfactual, it 
therefore is safe to assume that the costs of a distributed or hybrid approach would have 
been higher. 

As acknowledged in the latest UCC annual progress report and confirmed by the IT case 
studies, while the Customs programme has facilitated progress and contributed to the cost-
effective delivery of digital systems, there are still certain issues and inefficiencies which 
are beyond the control of the programme per se. Delays in the implementation of some 
UCC electronic systems – due to varying levels of national readiness and capacity – have 
led  to  uneven  progress  across  Member  States.  Differences  in  resource  allocation  and 
technical expertise among national customs administrations can also delay the expected 
results from the implementation of the common components35. 

Evidence from the IT case studies revealed several challenges affecting the efficiency of 
the systems. This includes the design of helpdesk support for ICS2, in particular the fact 
that traders cannot directly access the EU helpdesk. By design and as agreed with Member 
States, operators seek support from their national helpdesks, which in turn consult the EU 
helpdesk  when  and  as  needed.  In  the  case  of  PoUS,  the  limited  feedback  and  lack  of 
engagement  from  Member  States  and  economic  operators  during  the  design  and  pre-
production stages preceding the deployment of phase 1 led to the need to develop a system-
to-system  solution  for  traders  being  overlooked.  This  is  now  affecting  the  workload  of 
traders handling large volumes of proofs. Findings for the EU CCI case study suggest that 
the main obstacles preventing the full success of the system are the delays experienced by 
some  Member  States,  which  affect  the  planning  of  other  Member  States  and  economic 
operators. As the ICG is not yet operational, it is too early to assess its technical efficiency, 
but Member States interviewed for the ICG case study have positive expectations of the 
system as developed. 

35  Findings  of  the  survey  of  national  customs  administrations  also  support  the  conclusion  that  central 
applications such as thePoUS and the Customs Decisions Management System (CDMS) are more cost-
effective  than  national  ones  such  as  the  New  Computerised  Transit  System  (NCTS),  the  Automated 
Export System (AES) and EU CCI. 

38 

 
 
The  interim  evaluation  identifies  areas  where  efficiency  can  be  increased  through 
simplification and cost reduction. Several suggestions were made during the case study 
consultations,  including  more  timely  release  of  operational  guidance  during  complex 
system rollouts; better dissemination of technical documents and information to national 
customs authorities and business (e.g. sharing questions and comments ahead of meetings, 
organising regular webinars and ad hoc bilateral  meetings); avoiding changes in system 
specifications  once  considerable  work  has  been  completed  and  investments  have  been 
made;  providing  earlier  access  to  conformance  testing  and  training;  and  avoiding 
scheduling the launch of a system on a Friday (as was the case with PoUS). 

Cost-effectiveness of the programme’s funding of collaborative activities 

The  interim  evaluation  finds  that  the  cost  of  the  collaborative  activities  is 
proportionate  to  the  contribution  they  make  to  the  results  and  impacts  of  those 
activities and of the programme. However, it also highlights challenges in the grant 
management  approach,  specifically  in  incentivising  Member  States  to  take  a 
proactive role in leading the collaborative activities. 

One of the elements influencing the cost-effectiveness of the collaborative activities is the 
format of meetings organised under the programme. A shift to online formats following 
the  COVID-19  pandemic  has  improved  cost-efficiency  (and  accessibility),  significantly 
reducing travel and accommodation expenditure, as well as saving time. However, national 
authorities consulted for this interim evaluation perceived the online format as a limitation, 
stating  that  it  reduces  opportunities  for  informal  interactions,  networking  and  trust-
building,  elements  considered  essential  for  sustaining  long-term  cooperation  among 
customs  officers.  As  a  result,  it  is  no  surprise  that  the  proportion  of  online  meetings 
declined over time from 69% in 2022 to 48% in 2023 and 43% in 2024. This shift back 
towards more in-person meetings is viewed positively by stakeholders, as it supports more 
effective networking and collaboration. The higher costs of in-person meetings therefore 
appear well-balanced against the qualitative benefits. 

Member  States’  limited  involvement  as  grant  coordinators  or  action  managers  of 
collaborative actions is a concern. This raises questions about the general relevance of 
the  activities  and  their  benefits.  The  Customs  programme’s  annual  progress  reports  for  
both  2023  and  2024  highlight  the  lack  of  beneficiary  ownership  of  the  collaborative 
actions, including by expert teams. Examples show that when the Commission steps back 
from managing activities, these initiatives tend to falter due to a lack of engagement from 
Member States (for instance, the RALFH contact group of customs managers operating in 
the major northern ports of the EU). Consequently, there is a perception in DG TAXUD 
that Member States prefer for the Commission to take the lead, even if the Member States 
themselves have a strong interest in a topic. Indeed, this interim evaluation suggests that 
the reasons for this limited engagement are not related to a perceived lack of relevance 
or benefits of the collaborative actions but rather to internal administrative capacity 
issues. This raises concerns about the suitability of the current governance model. 

39 

 
 
In the survey, respondents pointed to insufficient time and resources as the primary reason 
preventing national administrations from participating in or leading an expert team (see 
below). This answer was selected significantly more often than the second most important 
reason:  the  administrative  complexities  and  reporting  requirements  involved.  What  is 
important from the perspective of explaining the reluctance of Member States to lead these 
actions is that four of the five top reasons (insufficient resources, incentives and expertise, 
and  competing  priorities)  were  in  some  way  related  to  the  internal  capacity  of 
administrations. It is also important to note that none of the administrations selected ‘lack 
of interest or insufficient awareness of achievements of  collaboration’ in their top three 
reasons36. 

Figure  9:  What  are  the  main  reasons  preventing  your  administration  from  leading  or 
participating in an expert team? Please select the three most significant reasons that apply. 

Insufficient human resources / time

Administrative complexities and reporting…

Competing priorities within the administration

29

23

Insufficient financial benefits for grant coordinator

13

58,5

Insufficient awareness on opportunities for…

Lack of specific expertise

Consider that another party will do so

3

9

8

Insufficient awareness of achievements of…

Lack of interest / operational needs that could be…

0

0

Source: Survey of national authorities 

Leadership roles clearly come with a higher administrative burden. In the online survey, 
the administrative burden of leading expert teams was perceived by the vast majority of 
customs administrations as significant, high or moderate. The burden of just participating 
in an expert team was assessed by the vast majority as moderate or minor. Other forms of 
collaborative action are generally perceived as less burdensome compared to expert teams. 
Most  administrations  considered  the  administrative  burden  related  to  leading  them  as 
moderate, while the rest assessed it as significant or high (8 out of 23). Assessment of the 
burden related to participation was the reverse: almost half the respondents (14 out of 29) 
assessed it as minor, whereas 13 out of 29 assessed it as moderate, only two assessed it as 
high and none rated it significant. 

36 Respondents were asked to give their top three  reasons for not participating in or leading an expert team. 
A score was then calculated, with the primary reason receiving 3 points, the secondary reason, 2 points, 
and the third reason, 1 point. The final scoring was as follows: Insufficient time and resources (score of 
58.5),  Competing  priorities  within  the  administration  (23),  Insufficient  financial  benefits  for  grant 
coordinators (13). 

40 

 
 
 
 
The key reason preventing administrations from leading or participating in  expert 
teams is related to capacity constraints and administrative complexities. Participation 
in  collaborative  activities,  which  is  typically  not  remunerated,  is  primarily  driven  by 
customs  officers’  personal  motivation  and  an  appreciation  of  the  added  value  of  such 
activities.  However,  stakeholders  noted  that  several  factors  may  prevent  national 
administrations  from  taking  part  in  collaborative  activities.  These  include  the  internal 
allocation of resources, competing tasks, the lack of designated personnel at the national 
level, in particular within smaller Member States, and the departure (e.g. retirement) of 
officials responsible for overseeing cooperation. As a way forward, the majority of national 
authorities  consulted  indicated  that  simplifying  administrative  procedures,  at  both  the 
European  Commission  and  national  levels,  would  increase  their  preparedness  to  act  as 
grant  coordinators.  However,  it  is  not  clear  whether  that  is  feasible  in  either  case.  The 
provision  of additional financial incentives was  also  deemed relevant  and was the third 
most frequently selected option. When asked to provide additional comments about ways 
to  encourage  more  active  participation,  some  respondents  commented  on  the  cost  of 
participating in these collaborative activities, indicating that they do not have sufficient 
resources and that the unit costs for accommodation do not reflect actual prices. 

Cost-effectiveness of human competency activities 

The  programme  improved  the  accessibility  of  EU  training  materials  and  the 
organisation  of  CLEP  events.  By  introducing  the  LMS  as  a  central  hub  for  training 
courses  and  by  centralising  the  organisation  of  CLEP  events,  the  programme  has 
streamlined processes related to e-learning and collaborative activities at EU level, thereby 
reducing the fragmentation of knowledge and learning across the EU. The portal is also 
low-cost and aligns well with users’ expectations. 

Effectiveness indicators (such as the growing number of users in the public and private 
sectors and users’ increased likelihood to enrol in a course or take part in CLEP event as a 
result of having all courses on a single portal) suggest that the activities are well received 
by the target audience. The perceived user-friendliness of the portal can also be assumed 
to be contributing to its effectiveness. Respondents in Member States indicated that they 
have  a  positive  view  of  the  portal.  The  only  area  where  they  identified  an  additional 
administrative burden was in relation to organising (as opposed to taking part in) CLEP 
events. 

Nonetheless, certain areas for improvement were identified. For example,  some general 
functionalities, and those relating to the organisation of CLEP events, could be fine-tuned. 
Uptake of the Learning Tools Interoperability (LTI) function by Member States has been 
limited, despite the clear benefit of having up-to-date courses powered by the EC LMS 
directly available on national portals. Although it is possible to request translations, the 
predominance  of  English  is  perceived  by  stakeholders  as  a  barrier  to  usage.  Finally,  a 
greater  return  on  investment  in  making  courses  available  to  the  private  sector  can  be 
achieved by taking some low-cost audience development measures. 

41 

 
 
The programme promotes a unified and common approach to training, based on the 
EU customs competency framework. Overall, LMS users hold a positive view of the EU 
competency framework for the customs profession, information on which is now available 
on the DG TAXUD website, with a link from the portal. Users valued the quality and the 
usefulness  of  this  standardised  approach  to  training  and  development.  When  starting  a 
particular course, participants are given information on how it will contribute to developing 
specific  skills  under  the  competency  framework.  However,  the  usefulness  of  the  EU 
competency framework is in some cases limited by differences in the taxonomies used by 
the Commission and the Member States. 

The  programme  is  aligned  with  learning  opportunities  provided  by  national 
administrations and international organisations. As demonstrated by the case study on 
the LMS, human competency activities conducted under the programme are perceived as 
complementary to training courses  and materials provided by national  and international 
LMS. More specifically, the content available on the LMS is considered to mainly provide 
general  and  common  background  for  customs  officials  across  the  EU,  while  national 
learning modules tackle more specific subjects, mainly linked to the local context, e.g. the 
specific nature of the border (maritime or land border, internal or external border of the 
EU). Courses offered by the WCO are seen as complementing those of the LMS in areas 
such as soft and digital skills. 

Assessment of the programme’s overarching governance mechanisms 

Two  aspects  of  the  programme’s  overarching  governance  were  considered:  the  MEF 
introduced under the 2021-2027 programme and the MASP-C. 

The  resources  and  effort  required  under  the  new,  streamlined,  MEF  are  better 
aligned  with  the  programme’s  design  and  distribution  of  resources.  Significant 
improvements  and  rationalisations  were  introduced  with  the  new  MEF  in  terms  of  its 
design and the distribution. The number of sub-indicators used was cut roughly in half (see 
figure below) and at the same time made fitter for purpose by better reflecting the fact that 
most resources go to the EES. 

42 

 
 
 
 
 
 
 
 
 
Figure 10: Monitoring framework (2021 - onwards) v the old monitoring framework. 

Source: External support study 

to 

the 

feedback  received 

Despite  these  significant  improvements,  the  MEF  remains  overly  complex  and 
burdensome,  according 
from  national  customs 
administrations  in  the  targeted  survey.  This  view  was  common  in  particular  among 
officials  responsible  for  handing  the  data  for  reporting  purposes  and  those  using  it  for 
analytical purposes. For the efficient development of the annual progress reports,  and to 
improve its use as a tool for measuring progress towards achieving the objectives of the 
programme, the MEF could be further simplified.  

The interim evaluation finds that there are several limitations related to data usefulness, 
clarity  and  alignment  with  programme  objectives.  Multiple  sub-indicators  are  overly 
complex, lack context or have limited analytical value unless supported by narratives or 
case studies. There is currently a disconnect between the narrative in the main body of the 
annual progress reports and the MEF data, which is reported in a supporting annex. This 
may  be  because  the  MEF  remains  somewhat  unwieldy:  even  after  the  number  of  sub-
indicators has been cut in half, there are still many sub-indicators to analyse and report on. 
In the process of any further streamlining of the MEF, establishing better links between 
the qualitative insights and quantitative MEF data in the annual report could allow for a 
more integrated analysis that demonstrates how the different aspects support one another; 
how they support the programme objectives37; which activities are showing signs of not 
reaching their targets; and, crucially, what action has been taken to explore the reasons for 
and to mitigate any performance problems. 

37  The  contribution  of  the  EES  is  still  difficult  to  demonstrate.  Although  the  systems  take  up  the  most 
significant portion of the programme budget, they are mostly unchanged year-on-year and are not the 
responsibility of the programme management team (who, by contrast, take the responsibility of drafting 
the  report).  Naturally,  the  programme  management  team  have  a  more  comprehensive  and  hands-on 
overview of the contribution of collaborative actions (which they manage). 

43 

Monitoring and Evaluation Framework (MEF) for the Customs ProgrammeMEF (2021 - onwards) Old frameworkOutputIndicators710Sub-indicators2124ResultIndicators610Sub-indicators1644ImpactIndicators36Sub-indicators518Total indicators1626Total sub-indicators4286 
 
 
 
Taking into account current IT projects and deadlines, the MASP-C is considered 
suitable as a project and planning support tool. Given recent updates to the MASP-C 
structure and the fact that it may require wholesale revision if the changes foreseen under 
the proposal for the Customs Reform go ahead, its current format was judged to be suitable 
for project planning. If a possible replacement of the MASP-C is considered in the context 
of  the  proposal  for  the  Customs  Reform,  it  would  be  a  good  idea  to  explore  ways  to 
integrate  best  practices  in  management  and  to  improve  readability  for  audiences  who 
engage less frequently with customs topics. 

Coherence 

The  assessment  of  coherence  considers  the  extent  to  which  the  Customs  programme  is 
internally  and  externally  coherent.  In  practice,  this  means  assessing  how  well  different 
activities  that  share  common  objectives  work  together.  The  assessment  of  coherence 
requires looking outwards at how the programme aligns with other EU initiatives, policies 
and  programmes  as  well  as  looking  across  the  different  actions  supported  by  the 
programme and how they support one another. 

The final evaluation of Customs 2020 found the programme to be internally and externally 
coherent.  Some  possibilities  for  minor  adjustments  to  deepen  complementarities  and 
synergies  and  improve  internal  communication  were  noted.  The  focus  of  the  present 
interim evaluation is to confirm the validity of these findings for the current programme 
and to assess the coherence of the Customs programme with the new CCEI and the Fiscalis 
programme. 

Internal and external coherence (follow-up to final evaluation of the Customs 2020 
programme) 

improvements,  notably 

Internal and external coherence have been improved under the current programme, 
and  progress  has  been  made  in  addressing  specific  shortcomings  identified  in  the 
previous  programming  period.  Nevertheless,  there  remain  opportunities  for 
in  exploiting  further  synergies.  Extensive 
marginal 
consultations  in  the  preparations  for  the  next  MFF  and  the  process  of  developing  the 
proposal for the Customs Reform have, as an indirect consequence, increased the visibility 
of  the  programme  within  the  Commission.  Specific  political  initiatives  linked  to 
(programme support for) e-commerce and the European Ports Alliance are examples of 
high-profile operational collaboration that have also raised the visibility of the Customs 
programme among key partners (in DG GROW and DG HOME respectively), although 
the synergies with the European Ports Alliance could be exploited even further. Similarly, 
the EU SWE-C, realised under the current programme, has as its very essence the objective 
of  ensuring  the  smooth  exchange  of  information  between  customs  and  non-customs 
authorities. This has facilitated cross-policy cooperation. This is demonstrated in the case 
study on the ICG, as the ICG module on DG SANTE TRACES will be interconnected with 

44 

 
 
 
the  EU  CSW-CERTEX.  As  discussed  in  the  case  study  research,  this  was  a  successful 
collaborative project with DG SANTE. 

More broadly, in view of e-commerce and trade developments, and geopolitical events and 
crises, there has been an increasing need to collaborate across policy domains in recent 
years. There are numerous examples of how the Customs programme is achieving such 
collaboration. National officials surveyed for the evaluation (see figure below) reaffirmed 
the insights gained from stakeholder interviews described above. None of the respondents 
strongly  disagreed  with  the  statement  that  the  programme  is  coherent  with  other  EU 
initiatives. 

Figure 11: Please indicate to what extent your administration agrees that each statement 
still applies 

The programme is coherent with other broader EU
initiatives that must be applied at the border by…

7

There are synergies and linkages between the 
programme and other initiatives (health & safety, …

5

19

22

4

1
0

1

1

2

Strongly agree

Tend to agree

Tend to disagree

Strongly disagree

Don't know

Source: Survey of Member States 

Structured cooperation to achieve complementarities with key partners across policy 
areas continues and has been consolidated over the course of the current programme. 
Formal  mechanisms  include  the  requirement  to  consult  relevant  Commission  services 
through  an  inter-service  steering  committee  when  drawing  up  the  Customs  programme 
multiannual work programme and to engage systematically in project-based collaboration. 
Additionally, where there are close connections, project proposals are assessed by officials 
from different DGs to avoid overlaps in funding and maximise synergies and efficiencies. 
A recent example concerned funding available through DG REFORM’s Technical Support 
Instrument  and  the  Customs  programme38,  where  contact  was  established  to  avoid 
duplication. 

In addition to these formal mechanisms, possibilities for synergies and cooperation may 
be  identified  through  both  formal  and  less  formal  interactions.  The  preamble  of  the 
Regulation establishing the Customs programme cites specific measures where possible 
synergies should be exploited. Stakeholders associated with most of these measures (such 
as the Anti-Fraud Programme and the Single Market Programme) were consulted to assess 
their views on cooperation, and national authorities were consulted on coherence. It was 
found that these interactions are typically not systematic or structured but rather based on 

38 The exchange meant a possible duplication of EU support via TSI for technical support, which was to an 
extent  already  available  via  guidance  developed  with  the  support  of  the  Customs  programme,  and 
training available through the Customs programme was identified and avoided. 

45 

 
 
 
 
staff initiative, for example based on existing relationships (except in the case of the CCEI 
and Fiscalis, both described below). Within the Commission, this challenge is not unique 
to the Customs programme39. 

Cooperation on innovation appears to be one area where synergies are not currently 
being exploited. Given the specific objective of fostering innovation in the area of customs 
policy, mechanisms to ensure synergies with other programmes and initiatives that include 
innovation in their scope, with direct or potential links to innovation and customs, could 
be explored.  Several EU initiatives relevant  in  this  respect have been identified by DG 
TAXUD40, in particular Horizon Europe with its considerable budget of EUR 93.5 billion, 
of which EUR 11.3 billion is dedicated to ‘Innovative Europe’, and EUR 1.5 billion for 
2021-2027 allocated to Cluster 3 “Civil security for society”, which covers Research and 
Innovation for border management and customs-specific capabilities 41. 

Coherence of the programme with the new CCEI 

The interim evaluation provides evidence that the interaction between the Customs 
programme  and  the  CCEI  is  seamless  and  synergistic,  a  finding  mirrored  by  the 
interim evaluation of the CCEI42. The CCEI was born out of a clear need expressed by 
Member States for financial support to procure equipment for more effective and efficient 
customs controls. The CCEI supports the purchase, maintenance and upgrade of customs 
control equipment, whereas, as the equipment itself needs to be operated by the national 
customs  administrations,  any  additional  needs  identified  (such  as  exchanges  of  best 
practices,  study  visits,  training,  etc.)  are  financed  under  the  Customs  programme.  The 
study  visits  and  the  e-learning  and  training  modules  in  the  context  of  the  customs 
laboratories and CELBET were found to be particularly useful for the national customs 
administrations dealing with customs controls. Training courses on the CCEI are available 
on the Customs and Tax EU Learning Portal. 

39 Indeed, concurrent evaluations of other funding programmes have confirmed this is the case (see interim 

evaluation of the Single Market Programme). 

40 These were listed as part of the internal reflection process and include the EU Anti-Fraud programme, the 
Recovery and Resilience Facility, the Technical Support Instrument, the Customs Control Equipment 
Instrument,  the  Border  Management  and  Visa  Instrument  (BMVI),  Horizon  Europe,  Digital  Europe 
programme, and the programme for Environment and Climate Action (LIFE). 

41  Indeed,  a  project  under  the  title  ‘Pan  European  Network  of  Customs  practitioners  (PEN-CP)’,  which 
launched  in  2018  and  is  to  be  completed  in  2025,  specifically  considers  the  need  for  innovation  in 
customs  and  supports  cooperation  in  this  area.  Synergies  between  this  project  and  the  Customs 
programme have not been systematically developed. There has, however, been ad hoc collaboration, for 
example,  a  ‘Joint  PEN-CP  Training  Network  Workshop  with  non-PEN-CP  members’  funded  by  the 
Customs programme based on the  identification of synergies by stakeholders involved in a Customs 
programme expert team and PEN-CP. Officials dealing with the import and export of cultural goods 
have been following projects funded under Horizon Europe (which are exploring the use of AI to detect 
fake  artworks  and  cultural  artifacts)  closely,  and  participated  in  December  2024  in  a  workshop  on 
innovation against traffic of cultural goods organised by CERIS (the Community of European Research 
and Innovation for Security). 

42 SWD(2025) 385 final 

46 

 
 
 
The  coordination  mechanisms  between  the  Customs  programme  and  the  CCEI 
function well and strengthen the complementarities in the day-to-day implementation 
of customs controls. The two funding instruments work well together, with specific DG 
TAXUD units in charge of the general management aspects of the Customs programme 
and  covering  the  CCEI,  and  other  units  contributing  to  more  specific  aspects.  Member 
States also collaborate under the umbrella of the CCEI Coordination Group. Stakeholders 
consider that the arrangements in place do not present any risks of overlaps between the 
two  programmes.  This  assessment  was  also  shared  by  feedback  from  national  customs 
administrations, who considered that the CCEI complements the Customs programme, as 
evidenced by the responses to the online survey. 

Coherence between the Customs programme and the Fiscalis programme 

The  interim  evaluation  confirms  that  the  Customs  programme  and  the  Fiscalis 
programme are well-aligned, both in theory and in practice. The two programmes are 
closely  related  and  similar.  The  respective  regulations  mirror  each  other;  however,  the 
programmes  fund  different  activities.  The  exception  is  the  Customs  and  Taxation  EU 
Learning portal, where training resources on customs and taxation (and the CCEI) come 
under a single umbrella and have a shared budget. 

The coherence between the programmes is ensured by formal and informal mechanisms 
for cooperation. For example, joint meetings are held for staff of the two programmes (e.g. 
within the Programme Coordinator Network and the Chief Information Officers Network), 
ensuring  that  cooperation  goes  beyond  each  programme’s  respective  thematic  domain, 
with  the  aim  of  encouraging  mutual  learning.  When  necessary,  joint  activities  are 
implemented on cross-cutting topics. According to the 2023 Annual Progress Report for 
the Customs programme, synergies between customs and taxation were actively fostered 
regarding VAT on import and the import of excise goods, which are relevant to both policy 
areas.  In  2023,  such  cross-cutting  topics  were  addressed  for  example  in  the  high-level 
seminar on  e-commerce; at a meeting of the Risk Management Group on financial risk 
criteria; during a working visit on special customs procedures; and during another working 
visit  on  cooperation  between  tax  and  customs  authorities  and  invalidation  of  the  VAT 
number43.  In  2024,  synergies  were  fostered  by  two  joint  project  groups,  on  the  ViDA-
Secured IOSS import process and the import one-stop shop. 

When relevant, common tools are used (e.g. PICS, ART) to create synergies and reduce 
costs. The Customs and Tax EU Learning Portal serves both programmes (as well as the 
CCEI), which is appreciated by users because, among other reasons, most of the training 
staff cover both domains and so do some of the courses. 

43  European  Commission,  Customs  Programme  Annual  Progress  Report  on  year  2023,  COMMISSION 

STAFF WORKING DOCUMENT, Brussels, 29.4.2024, SWD(2024) 120 final, p. 11. 

47 

 
 
 
The assessed coherence of the Customs and the Fiscalis programmes was also confirmed 
by  the  national  authorities  in  the  survey  are  also  well-aligned.  The  vast  majority  of 
respondents were of the opinion that the Fiscalis programme primarily complements the 
Customs programme (24 out of 31 responses), compared to just 2 out of 31 who considered 
that it primarily overlaps with the Customs programme (5 indicated that it was difficult to 
say). 

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

The programme is achieving efficiencies of scale and efficiency gains in IT capacity  
building  that  could  not  have  been  achieved  in  any  other  way.  The  findings  of  this 
interim evaluation are in line with the conclusions of the final evaluation of the Customs 
2020 programme, confirming that the programme was instrumental in implementing the 
UCC  by  financing  essential  European  information  systems,  enabling  data  sharing,  and 
fostering cooperation. According to the survey among national customs administrations, 
most participating countries (28 out of 30 respondents) agree that the programme’s funding 
for the EES enables data sharing and cooperation, and creates economies of scale. Most 
respondents were of the view that, if the common components of the EES were no longer 
supported by the Customs programme, cooperation and exchange of information among 
EU  Member  States  would  be  significantly  affected  (20  out  of  24  respondents  who 
answered this question). 

Findings from the case studies of selected digital systems show that without programme 
funding, the systems in their current form and the associated benefits would not have been 
achievable by national administrations with the resources available. According to feedback 
from economic operators, the efficiency gains that these digital systems are expected to 
bring are not yet fully visible, either because of the complexity of the system (ICS2), or 
because the simultaneous deployment of larger projects has led to a loss of focus or interest 
from Member States and economic operators (PoUS), or as a result of varying capacity 
and level of readiness of Member States to introduce a new system (EU CCI). 

The  collaborative  and  human  competency  activities  are  providing  opportunities  for 
cooperation,  communication  and  networking  across  the  EU  that  could  not  have  been 
achieved in any other way. Similar to the conclusions of the final evaluation of the Customs 
2020 programme, the interim evaluation finds that collaborative and human competency 
activities  clear  benefits  for  programme  stakeholders.  Despite  representing  a  very  low 
proportion  of  the  total  programme  funding  in  comparison  to  the  allocation  for  the  IT 
component,  most  national  customs  authorities  responding  to  the  survey  (29  out  of  30 
respondents) agreed that the collaborative and human competency activities funded by the 
programme facilitate collaboration and trust-building among participating countries. There 
was  broad  consensus  among  survey  respondents  that  if  programme  funding  for 
collaborative  activities  were to  be reduced, most  of the benefits  would  be affected to  a 
significant or to a high extent. The main result would be reduced networking opportunities 
(27 out of 30 respondents saying that their administrations would be impacted), followed 

48 

 
 
by a reduction of opportunities to learn from approaches in other Member States (25 out 
of 30 respondents). 

The LMS case study shows that the portal is regarded as an improvement in comparison 
to the situation prior to 2021. Moreover, most  stakeholders (71%) consider that the LMS 
has provided additional value in relation to what is offered at the national level or by other 
international organisations, such as the WCO. 

4.3. Is the intervention still relevant? 

Since its launch in 2021, the Customs programme has demonstrated a high degree of 
relevance  to  the  evolving  needs  of  the  EU  customs  union.  The  programme’s  design, 
with its focus on supporting the uniform implementation of customs legislation through IT 
and  administrative  capacity  building,  has  enabled  it  to  respond  swiftly  to  unexpected 
political, economic and operational challenges. 

Much  like  the  previous  programming  period,  which  saw  two  significant  unanticipated 
events,  i.e.  Brexit  and  the  COVID-19  pandemic,  the  current  2021-2027  programming 
period has been marked by the continued need to adapt to the reality on the ground. Since 
Russia’s illegal full-scale invasion of Ukraine in February 2022, the programme support 
has  been  instrumental  in  supporting  customs  officials  with  guidance  on  translating  the 
requirements of successive restrictive measures (sanctions) into the language of customs 
operations.  Program  resources  were  also  quickly  mobilised  for  the  rapid  inclusion  of 
Ukraine as a beneficiary of the programme (see effectiveness). 

The Russian aggression in Ukraine and broader security threats have brought into focus 
the  role  of  customs  in  security  policy.  These  developments  have  reconfirmed  and 
heightened the need for the EU’s system for advance cargo information (known as ‘ICS2’). 
This  system  demonstrates  the  relevance  of  a  centralised,  EU-driven  approach  to  the 
development of digital systems to achieve faster results. This is important in the context of 
evolving needs. 

In another example of the value of a centralised  approach, the current climate of tariffs 
uncertainty  has  highlighted  the  critical  importance  of  the  TARIC  database,  which  is 
maintained  and  updated  with  the  financial  support  of  the  Customs  programme.  TARIC 
provides  customs  officials  and  economic  operators  with  up-to-date  information  on  the 
duties  applicable  to  goods  entering  the  EU,  including  where  tariffs  have  changed  after 
having been stable for several decades, i.e. since the end of the end of the Uruguay Round 
in 1994, ensuring consistent application of these duties. 

The  programme  has  also  remained  relevant  in  light  of  constrained  resources  in 
national  administrations.  By  funding  shared  IT  systems,  collaborative  platforms  and 
expert  teams,  it  has  enabled  Member  States  to  pool  resources,  avoid  duplication  and 
maintain operational capacity despite staffing and budget pressures at national level. The 
joint development of EES reduces the need for each Member State to fund its own separate 

49 

 
 
solutions, offering economies of scale that are particularly valuable in a context of limited 
national funding capacity. 

In general, the evidence collected for this interim evaluation confirms that the programme 
addresses  the  needs  of  key  stakeholders.  However,  some  specific  limitations  were 
identified. One is the lack of involvement of accession countries in collaborative actions. 
Another  is  the  need  of  taking  a  more  business-friendly  approach  to  developing 
technical/operational guidance, particularly when there is a heavy administrative burden 
or cost of compliance. This was consistently pointed out as a shortcoming in the ICS2, 
PoUS and EU CCI case studies. 

The  Customs  programme  faces  broader  structural  limitations  as  well.  Certain 
challenges facing the customs union, notably the rapid and continuing rise of e-commerce, 
cannot be addressed by the programme alone. While the programme can provide funding 
for relevant tools and forums for exchanging best practices among customs officials, the 
scale and nature of the challenge require broader policy interventions as proposed by the 
Commission in the EU Customs Reform proposal44. In the context of the proposed reform 
(see  box  below),  the  current  support  provided  by  the  programme  for  its  main  building 
blocks will need to be explicitly assessed in detail as part of the final  evaluation of  the 
2021-2027 programme. 

Box 4: Proposed EU Customs Reform 

Under the proposed Customs Reform, a new EU Customs Authority will oversee an EU 
Customs Data Hub. The Data Hub will replace the existing customs IT infrastructure in 
EU  Member  States.  The  new  authority  will  also  help  deliver  on  an  improved  EU 
approach  to  risk  management  and  customs  checks.  The  proposed  reform  has  three 
pillars: 

•  A  new  partnership  with  business:  Businesses  importing  into  the  EU  will  log 
information on their products and supply chains into a single online environment: 
the new EU Customs Data Hub. This will give authorities a complete overview of 
supply chains and the movement of goods. Businesses will only need to interact with 
one single portal to submit customs information and will do it once even for multiple 
consignments. A fast-track process will exist for trusted traders. The Data Hub will 
be  open  for  e-commerce  in  2028,  and  to  other  importers  by  2032,  at  first  only 
voluntarily but mandatorily by 2038. 

•  A smarter approach to customs checks: Member States will have access to real-
time  data  and  will  be  able  to  pool  information  and  intelligence  to  respond  more 
quickly, consistently and effectively to tackle risks. AI will be used to analyse data 
so  that  customs  authorities  can  perform  more  targeted  checks.  The  Customs 
Authority will be able to act on the data from the Data hub and work with relevant 
partners for surveillance and enforcement purposes. 

•  A  more  modern  approach  to  e-commerce:  The  reform  makes  online  platforms 
responsible for ensuring customs duties and VAT are paid at purchase, eliminating 
hidden charges and ensuring compliance with EU standards. It removes the EUR 150 

44 COM(2023) 257 final 

50 

 
 
duty  exemption,  targeting  fraud  from  undervalued  parcels,  and  simplifies  duty 
calculations. This new system is expected to streamline e-commerce, combat fraud, 
and generate an additional EUR 1 billion in customs revenue annually45. 

45 See: https://taxation-customs.ec.europa.eu/customs-4/eu-customs-reform_en. 

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1. Conclusions 

Effectiveness 

During  the  current  2021-2027  programming  period,  the  Customs  programme  has  been 
crucial in taking forward the delivery of the common components of the UCC systems, 
which are to be deployed by the end of 2025. Most notable is the (ongoing) rollout of the 
new system for import control (ICS2), to which most of the programme budget has been 
allocated, and which is already contributing to the security and safety of the EU. For the 
newer systems, such as PoUS, EU CCI and ICG, some of the expected benefits will take 
time  to  fully  materialise.  At  the  same  time,  certain  recurrent  challenges  in  the  field  of 
customs cooperation are structural and cannot be met by the activities of the programme 
alone, as recognised in the proposal for customs reform. 

The numerous and varied collaborative activities funded under the programme continue to 
yield strong results and are a necessary complement to the programme support for digital 
systems.  They  create  networking  opportunities,  provide  learning  opportunities  and 
consistent  training  content  across  the  EU,  support  the  exchange  of  best  practices,  and 
encourage  the  development  of  common  solutions  to  common  problems.  Expert  teams 
create room for collaboration between the Commission and the Member States in specific 
areas. They serve as platforms for collaboration and exchange of views, and have proved 
to be a useful tool for networking among national experts. 

The LMS launched in 2021 is well regarded by users, and use of its resources is increasing, 
by Member States (though not necessarily candidate countries) as well as other external 
stakeholders. Users appreciate it for offering both e-learning courses and CLEP courses in 
a single, user-friendly platform, and they are taking more courses as a result. Despite some 
minor issues with  navigation and the search function, the overall assessment of the features 
and functionalities of the portal is positive. However, Member States have failed to take 
advantage of the possibility to link their learning management systems directly to the LMS, 
without the need to transfer courses from one to the other; as a result, officials may end up 
taking out-of-date courses when updated ones are available. More attention could also be 
paid to audience development, in particular to obtain a return on the costs of making some 
courses available to the private sector. 

One novel feature of the Customs programme is the introduction of innovation, both as a 
specific  objective  and  as  an  eligible  action  type.  An  argument  could  be  made  that 
innovation is already embedded in the programme activities, specifically digital systems. 
However, the addition of innovation as a specific objective sought to generate new types 
of activities in response to new and unexpected challenges. For a mature programme such 
as the Customs programme, the integration of new activities can be expected to take some 
time. Indeed, the targets under this specific objective were not met in the first years. The 
time spent on agreeing on how to define the concept of innovation and the activities under 

52 

 
was likely due to the fact that there is a lack of dedicated internal leadership to champion 
the notion of innovation in customs. 

Efficiency 

Using a counterfactual approach, this  interim evaluation has found that for the sampled 
digital systems for which a counterfactual scenario was developed, i.e. ICS2, PoUS and 
EU CCI, the approach taken was more cost effective than the alternatives. The alternatives 
in each case would have required a greater effort in terms of human resources and funding 
on the part of the Member States. These costs outweigh any benefits of the counterfactual 
scenarios,  such  as  greater  control  for  Member  States  or  fewer  problems  with 
interoperability with existing systems. 

In all three cases, the leadership role taken by the Commission was appreciated by national 
customs  administrations  and  industry  stakeholders.  In  fact,  in  most  cases,  any 
inefficiencies  identified  stemmed  from  aspects  that  have  not  been  centralised.  Still, 
industry  feedback  emphasised  the  need  for  advance  and  more  business-friendly 
communication to ensure the best chances of  compliance in the context of many (often 
simultaneous) complex projects. 

While  stakeholders  acknowledge  the  positive  value  of  collaborative  activities,  the 
evaluation indicates that the current approach of giving the ownership to Member States 
has underdelivered. Although these activities are recognised as valuable and beneficial, the 
low level of involvement by Member States is insufficient to fully leverage their potential. 
The main reason for this is lack of administrative capacity, especially for taking leadership 
roles,  which  come  with  an  additional  administrative  burden.  This  suggests  that  a 
revaluation of the governance model is necessary to ensure that adequate incentives are in 
place.  More  proactive  communication  /  awareness-raising  of  the  benefits  of  leading 
activities, in addition to any adjustments to the governance of the collaborative activities 
to make them more attractive, may also be needed to encourage Member States to embrace 
leadership roles and engage more actively in collaborative efforts. 

This interim evaluation has made extensive use of the new MEF introduced with the 2021-
2027  programme,  which  is  recognised  as  a  very  significant  improvement  over  its 
predecessor framework. Yet, the MEF does not seem to be exploited to its full potential. 
Feedback from national authorities suggest that the MEF remains somewhat burdensome: 
even after the number of sub-indicators has been cut in half, the remaining number still 
remains  high.  This  suggests  that  more  streamlining  would  be  beneficial.  A  further 
reduction  in  the number of indicators could  further reduce  the administrative burden  of 
preparing  the  annual  progress  reports;  this  would  allow  for  a  more  integrated  analysis 
demonstrating  how  the  different  aspects  support  one  another  and,  crucially,  how  they 
support  the  programme  objectives.  Such  streamlining  would  potentially  enable  a  more 
focused analysis of whether targets are being met on time, and if not, of the reasons and 
possible remedies. 

53 

 
 
Coherence 

Customs authorities’ role in border management has expanded, as they continue to face 
ever evolving and increasing challenges. To address this, a new instrument (CCEI), based 
on a different legal basis, was launched to support the purchase of equipment to perform 
more sophisticated and more consistent controls. The Customs programme has been used 
to complement this new instrument, ensuring that officials have access to the appropriate 
training and opportunities to exchange knowledge and best practices. 

The blurring of the line between customs and non-customs work has made it even more 
crucial to ensure that the programme support is coherent with other instruments, including 
but not limited to, the sister programme managed by TAXUD for delivering tax policy, the 
Fiscalis  programme.  The  interim  evaluation  provides  evidence  of  clear  synergies  and 
complementarities between the Customs programme and both Fiscalis and the CCEI. 

In  continuity  with  the  previous  programme,  the  Custom  programme  remains  consistent 
with other relevant instruments, but this requires continuous proactive efforts. In particular, 
given the specific objective of fostering innovation in the area of customs policy, more can 
be done to explore synergies with Horizon Europe. 

EU added value 

EU support for cooperation in the field of customs dates back over 30 years. As one of the 
few areas of exclusive EU competence, customs policy is vital for the implementation of 
the UCC, the key legal framework underpinning the Customs Union. As such, unlike some 
other policy areas, when it comes to support for customs policy, the question of the EU’s 
specific role and what could have been achieved without the EU’s involvement is difficult 
to answer, due to the fact the EU’s role is so integral and has been so for such a long time. 

Yet, the counterfactuals developed as part of this interim evaluation make it possible to 
obtain a more concrete, evidence-based picture of the added value of the EU’s role. For 
ICS2, the centralised approach was considered to be two to four times more cost effective 
than the alternative, according to those consulted. Feedback collected for PoUS confirms 
that under both counterfactual scenarios tested (a fully distributed model or a model based 
on an already existing system adapted to incorporate the PoUS functionality), the overall 
financial burden on national budgets would be significantly higher than under the hybrid 
system,  with  notable  increases  in  both  investment  costs  and  costs  related  to  regular 
operations. The implementation of a new trans-European system such as the EU CCI also 
brings cost savings for Member States. For example, the EU CCI’s common specifications 
were widely used by the Member States to both build and upgrade their NIS, resulting in 
cost savings and efficiency gains and ensuring regulatory compliance at EU level. Without 
shared  specifications  and  central  components,  each  Member  State  would  incur 
considerable costs due to the need to maintain fragmented national procedures, resulting 

54 

 
 
 
in  reduced  global  competitiveness  and  increased  administrative  burdens  on  national 
customs authorities.  

Indeed, the interim evaluation finds that the Customs programme is achieving efficiencies 
of scale and efficiency gains in IT capacity building, while the collaborative activities are 
providing  opportunities  for  cooperation,  communication  and  networking  across  the  EU 
that could not have been achieved without the involvement of the EU. 

The  customs  authorities  consulted  found  it  difficult  to  imagine  alternative  ways  of 
operating  and  cooperating,  especially  regarding  the  management  of  the  digital  systems 
supported by the EU, which play a key role in the Customs Union. In the absence of the 
Customs programme, cooperation between participating countries would have to be based 
either  on  informal  and  unstructured  relations  between  Member  States  and  between 
Member States and the Commission, or on formal channels and reciprocity agreements, 
which would be significantly more complex and costly to implement. 

Implementing common components of these systems at EU level mitigates the challenges 
of  customs  administrations’  unequal  capacity  in  terms  of  IT  and  equipment,  human 
resources  and  operational  processes;  the  uneven  interpretation  and  implementation  of 
relevant  legislation  by  customs  administrations;  and  the  obstacles  to  cooperation 
(including of a geographical, administrative, legal and strategic nature). 

Relevance 

Successive  evaluations  have  confirmed  the  relevance  of  EU  support  for  customs 
cooperation. This finding remains broadly valid. The current programme was launched in 
March 2021, during one crisis (the COVID pandemic), before the occurrence of another: 
Russia’s full-scale invasion of Ukraine in February 2022. While much of the programme 
support is relatively fixed (since it is dedicated to  the EES), some room for manoeuvre 
exists in the margins, which made it possible for the programme to respond to unexpected 
needs in the early years of the 2021-2027 programme period. Notably, programme support 
was  used  to  prepare  guidelines  to  translate  the  unprecedented  restrictive  measures 
(sanctions) imposed on Russia and Belarus into processes which customs officials (who 
would not typically deal with sanctions of this scale or scope) can effectively implement 
in  their  day-to-day  work.  In  addition,  programme  resources  were  quickly  mobilised  to 
include Ukraine as a programme beneficiary.  

The challenges posed by e-commerce, on the other hand, had been identified prior to the 
programme’s launch and have since continued to increase. These are considered to require 
a more fundamental customs policy change, as proposed under the Customs Reform and 
may  need  to  be  re-assessed  following  the  adoption  of  the  Customs  Reform  proposal, 
potentially as part of the final evaluation of the programme. Notwithstanding the support 
provided by the Customs programme, little has been achieved to address the challenges of 
e-commerce during the current programming period. 

55 

 
 
At  present,  the  evidence  confirms  that  the  programme  is  addressing  the  needs  of  key 
stakeholders,  despite  certain  limitations.  One  is  the  lack  of  involvement  of  accession 
countries in collaborative actions. Another, mentioned by industry stakeholders, is the need 
for  a  more  business-friendly  approach  to  developing  technical/operational  guidance, 
particularly when there is a heavy administrative burden or cost to compliance. This has 
been consistently pointed out as a shortcoming in the ICS2, PoUS and EU CCI case studies. 

5.2. Lessons learned 

Lesson  1:  EU  support  for  the  common  components  of  digital  systems  remains 
essential for the implementation of the UCC. 

Programme support for the EES is essential for the implementation of customs policy. As 
demonstrated by the in-depth research into EES, the alternatives considered would have 
been less effective and less efficient. The  Commission has successfully demonstrated it 
can  deliver  large-scale,  technically  challenging  systems  on  time.  The  experience  with 
ICS2,  the  largest  and  most  complex  system  launched  under  the  programme  to  date, 
underlines  the  importance  of  a  phased  implementation  schedule,  early  and  close 
cooperation  with  the  private  sector,  and  clear,  timely  communication  with  relevant 
stakeholders as critical features of cost-effectiveness. However, and as documented in the 
UCC progress reports, the timely implementation of the UCC work programme also relies 
on  the  progress  of  national  projects  which,  while  monitored  and  supported  by  the 
Commission, fall outside the Customs programme’s remit as they are the responsibility of 
the Member States. At the same time, there are a lot of parallel demands on both Member 
States and economic operators, which put pressure on already squeezed resources. This 
points to the continued need for programme support to drive progress but also suggests an 
area for improvement: namely, making technical/operational guidance more accessible in 
order to minimise the burden when introducing new systems. 

Lesson 2: Harnessing the full potential of collaborative actions requires revisiting the 
governance arrangements. 

Collaborative actions serve a niche and crucial function. They are the human element of 
the  programme.  While  some  collaborative  actions  work  well,  those  with  limited  direct 
involvement of the Commission face challenges. If the leadership/ownership of actions by 
Member  States  is  to  be  encouraged,  the  approach  to  the  governance  of  collaborative 
activities should be revised. Support for Member States should be bolstered, to ensure that 
taking a leadership role is an attractive and justifiable investment on their part. This could 
be  coupled  with  awareness-raising  to  develop  a  greater  understanding  among  senior 
management within national administrations of the importance of these activities and the 
prestige that could be associated with assuming a leadership role. If this model cannot be 
adopted within the current programming period, it could be considered within the proposed 
Customs Reform. 

56 

 
 
 
Lesson 3: The benefits of the LMS could be optimised by fine-tuning some features 
and functionalities, and by low-cost promotion to the private sector. 

Training activities are critical to the Customs programme’s overarching goal of supporting 
customs  authorities  to  act  as  one.  Traders  should  encounter  the  same  practices  and 
interpretation of the rules at whichever border their goods enter the EU. The single LMS 
combining e-learning and CLEP events in one portal specifically designed as a learning 
management system, accessible to both public and private-sector stakeholders, has proved 
to be successful in providing a unified training approach for customs professionals.  Four 
years after the launch of the new portal, some functionalities are, understandably, in need 
of fine-tuning. In addition, to increase efficiency, Member States could be encouraged to 
take up the functionality that links national learning management systems directly to the 
EC LMS. There is also an opportunity to take low-cost measures to broaden the private-
sector audience and thus improve the return on the investment in making courses available 
to them. 

Lesson 4: Dedicated and enhanced leadership could help fully embed the new specific 
objective of innovation. 

Given that activities falling under the specific objective of ‘supporting innovation in the 
area  of  customs’  have  been  slow  off  the  ground,  to  encourage  innovation  within  the 
Customs programme, it is  recommended to  appoint a dedicated  ‘innovation  champion’. 
This individual should foster an innovation-oriented culture in the activities funded by the 
programme, lead and participate in working groups, and collaborate with colleagues from 
DG TAXUD, the Directorate-General for Migration and Home Affairs (DG HOME) – the 
service in charge of the policy aspects of the research and innovation activities for civil 
security, including border management and customs – as well as the Joint Research Centre 
(JRC) and DG Research and Innovation (DG RTD). Additionally, the champion should 
engage with external partners, such as the TAXUD Trade Contact Group, relevant EU-
funded customs research projects under Horizon Europe, and international organisations 
such as the WCO, to provide strategic direction and cohesive leadership that benefit all 
stakeholders involved. 

Lesson 5: Taking an agile approach to project management, where appropriate, can 
support adaptation to the evolving and expanding role of customs. 

Support under the Customs programme has been deployed to address new and unexpected 
needs. Given the recent challenges related to geopolitical developments, the evolution of 
international trade and ongoing digitalisation, maintaining scope for flexible and coherent 
support is  required. Since much of the programme budget  is  allocated to large-scale  IT 
projects,  looking  further  ahead,  embracing  the  most  agile  approaches  to  project 

57 

 
 
 
 
management could further strengthen the flexibility of support in the face of fast-changing 
needs. 

Lesson 6: In view of the experience gained in operationalising the new MEF, further 
streamlining would likely improve use and reduce burdens. 

While the current MEF is simpler than its predecessor, it still uses a large set of indicators 
which are difficult to manage and report on. Further reducing the number of indicators and 
even the frequency of reporting would make it possible to make better use of the remaining 
smaller set  of indicators in the  future.  For indicators related to  IT projects,  providing a 
narrative about active projects and their alignment with programme objectives would offer 
more meaningful insights than mere numerical data. Certain sub-indicators seem to have 
limited value and could potentially be removed and some others may be better suited to 
periodic evaluations instead of annual surveys. Indicators related to collaborative activities 
could be better aligned with specific objectives of the programme and types of activities 
listed in the Regulation or the Work programme. Innovation could be better demonstrated 
by  specific  case  studies  presenting  tangible  innovations  rather  than  opinions  gathered 
through  a  survey.  Detailed  considerations  for  further  consolidation  of  the  MEF  and 
streamlining of reporting (amending specific indicators) are presented in Annex III to the 
report (Table 11). 

58 

 
 
ANNEX I: PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/Work Programme reference 

The final (PLAN/2024/911) evaluation is a non-major initiative organised in accordance 
with Article 15(2) of Regulation (EU) No 2021/847 of 20 May 2021 establishing an action 
programme to improve the operation of taxation systems in the European Union. 

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

2.  Organisation and timing 

The  interim  evaluation  was  informed  principally  by  the  ‘study  supporting  the  interim 
evaluation of the Customs programme 2021-2027’ conducted by an external contractor, 
Tetra Tech International Development Europe, during the period from June 2024 to June 
2025.  An  inter-service  steering  group  with  the  following  Commission  services  who 
expressed their wish to participate in the group supported the study. 

Table 3: Commission services that formed the final study’s ISG 

Meetings and written procedure  
DG AGRI - Agriculture and Rural Development 
DG BUDG - Budget  
DG DIGIT - Informatics 
DG ENV - Environment  
DG FISMA - Financial Stability, Financial Services and Capital Markets Union 
DG GROW - Internal Market, Industry, Entrepreneurship and SMEs 
DG HOME - Migration and Home Affairs  
DG JUST - Justice and Consumers 
DG REFORM - Structural Reform Support  
DG SG - Secretariat-General 
DG TRADE - Trade  
JRC - Joint Research Centre 
Legal Service  
OLAF - European Anti-Fraud Office 

The  inter-service  steering  group  for  the  evaluation  met  five  times,  on  7  March  and 
1 October  2024,  and  15  January,  19  May  and  16 June  2025.  The  last  meeting  was  a 
validation  for  the  ‘study  supporting  the  interim  evaluation  of  the  Customs  programme 
2021-2027’  during  which  the  external  consultants  presented  their  findings,  conclusions 

59 

 
 
 
 
 
and recommendations. These were then discussed with the group, and their validity and 
credibility were confirmed. 

3.  Evidence used together with sources and any issues regarding its quality 

The present interim evaluation is based on work carried out by external consultants. The 
material  informing  this  evaluation  consisted  of  (1)  programming  documentation,  (2) 
previous studies, reports and evaluations, and (3) the MEF, as detailed in Table 5, which 
also presents the intended purpose of use. 

The  evaluations  also  gathered  primary  data  on  the  programme’s  implementation, 
functioning,  results  and  use  directly  from  the  best-placed  stakeholders:  the  tax 
administrations  of  the  participating  countries  and,  albeit  to  a  smaller  extent,  economic 
operators.  Evidence  was  collected  through  targeted  consultations  and  cases  studies;  the 
details of how these were collected can be found in Annex II. 

Table 4: Sources of information used for the interim evaluation of the Customs programme 
2021-2027  

Source 
1. Programming documentation  
1.1  Programme  Regulation  (EU)  No 
2021/444 

1.2 Annual Work Programmes (AWP) 
The  Customs  AWPs  are  annexed  to 
each yearly financing decision  

1.3  Monitoring  and  Evaluation 
Framework (MEF) 

2. Studies, reports and evaluations  
2.1 Annual Progress Reports (APR) 
Published yearly, available for 2023, 
2022, 2021 and 2020.  

Purpose 

-  underlying rationale, history and context 
-  main features of the programme 
-  key stakeholders and beneficiaries 
-  specific and operational objectives 
-  headline budget figures 
-  overview of activities and priorities 
-  structuring and selection of case studies 
-  priorities in terms of resource allocation 
-  continuing relevance and policy issues of interest for 

the programme 

-  expected results and annually updated goals  
-  evaluation  design,  mapping  MEF  indicators  to 

evaluation questions 
-  limits of MEF indicators 
-  purpose and design of different indicators 
-  practicalities  of  MEF  data  collection  and  their 

consequences 

-  intervention logic 
-  programme 
-  performance/effectiveness  in  terms  of  outputs  and 

results 

-  insight into how the MEF is used and reported 

60 

 
 
 
-  structuring  and  topicality  for  the  evaluation  case 

studies 
-  perceived 

strengths 

further 
and 
development  –  early  warnings  and  learning  within 
the programme  

areas 

for 

-  previous 

findings, 

conclusions 

and 

recommendations 
for 

-  background 
programme 

recent  developments 

in 

the 

-  ideas for other sources of data 
-  ideas  for  issues  to  explore  /  build  on  past  and 

envisaged policy context going  

-  collect further insights on the perspectives of policy 
officers,  national  customs  authorities  and  EES 
system users 

-  collect insights from the contractor responsible for 

developing and operating the LMS 

2.2  Evaluations,  impact  assessments 
and reports 
Final evaluation of the Customs 2020 
programme 
Action 
evaluation  of 
programme 

plan: 
final 
the  Customs  2020 

follow-up 

3. Interviews and targeted surveys  
3.1 Interviews with representatives of 
national  customs  authorities, 
the 
European  Commission  and  relevant 
economic operators  

3.2 Targeted  survey 

for  national 
customs  administrations,  LMS 
user  survey  and  survey  of  the 
Training Support Group 

4.  Use of external expertise 

The  Commission  carried  out  the  evaluation  study  using  external  consultants  procured 
through  a  framework  contract.  The  ‘Study  supporting  the  interim  evaluation  of  the 
Customs  programme  2021-2027’,  which  is  the  main  study  informing  this  interim 
evaluation, was conducted by a consortium led by Economisti Associati (now Intellera)46. 
The contract  was signed on 17 June 2024 for a period not exceeding 10 months; a non-
cost extension of the contract until 30 June 2025 was granted afterwards. 

46 Framework Contract TAXUD/2024/CC/171 - Lot 1. 

61 

 
 
  
 
 
 
 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

1.  Approach 

The  interim  evaluation  of  the  Customs  programme  2021-2027  mainly  builds  on  the 
findings of an external support study conducted by a contractor between June 2024 and 
June 2025. The  appraisal  of the programme over the period 2021-2024  took an overall 
approach that consisted  of assessing  the effectiveness,  efficiency,  coherence, EU  added 
value and relevance of the Customs programme. To ensure that the assessment is robust, 
it has a structured approach based on an elaborated intervention logic, an operationalised 
evaluation  matrix  and  a  mix  of  data  collection  and  analytical  methods.  The  overall 
approach included the following three main tasks: 

structuring and scoping; 

- 
-  data collection and 
-  analysis and lesson learned. 

In line with the Commission’s Better Regulation Guidelines47, the evaluation criteria of 
effectiveness, efficiency, coherence, EU added value and relevance were covered. They 
were addressed through 13 key evaluation questions: 

1. To what extent have the IT capacity building activities (incl. programme support for 
the  EES)  contributed  to  the  achievement  of  the  programme’s  general  and  specific 
objectives? 

2.  To  what  extent  have  the  collaborative  and  human  competency  building  activities 
contributed to the achievement of the programme’s general and specific objectives? 

3. To what extent has the programme’s new eligible action on innovation been used? 

4.  Overall,  how  effective  has  the  programme  been  in  progressing  towards  the 
achievement of its objectives? 

5. To what extent is the programme’s funding to the common components of the EES 
cost efficient? 

6.  To  what  extent  is  the  governance  of  the  programme’s  funding  of  collaborative 
activities cost efficient? 

7.  To  what  extent  is  the  programme  funding  of  human  competency  activities  cost 
efficient? 

8.  To  what  extent  has  the  programme  governance  been  efficient  during  the  current 
MFF considering the tools available (i.e. the MEF and MASP-C)? 

9. To what extent are the conclusions in relation to the coherence of the programme as 
per the Customs 2020 final evaluation still valid? 

47 Better Regulation Guidelines, Commission staff working document SWD (2021) 305 final. 

62 

 
 
 
10. To what extent does the programme achieve complementarity with the new CCEI 
in light of customs policy needs? 

11.  To  what  extent  does  the  programme  achieve  complementarity  with  the  Fiscalis 
Programme in light of customs policy needs? 

12.  To  what  extent  are  the  conclusions  in  relation  to  the  EU  added  value  of  the 
programme as per the Customs 2020 final evaluation still valid? 

13. To what extent is the programme support relevant in view of evolving needs? 

These  questions  were  operationalised  and  associated  indicators  and  judgement  criteria 
were  developed  to  provide  a  framework  for  collecting  data  and  making  evaluative 
judgements (see Annex III). 

The approach to this exercise was informed by five main considerations:  

1)  the  evolution  of  the  Customs  programme  since  1991  -  and  the  fact  that  its  various 
iterations has undergone periodic evaluations ever since - allows for targeted analysis of 
specific components, maintaining its core activities without necessitating another holistic 
assessment; 

2) significant investment in IT systems requires a comprehensive understanding of their 
effectiveness;  

3)  extensive  coverage  of  collaborative  activities  and  capacity  building  in  past 
evaluations,  and  regular  monitoring  activities,  has  led  to  “consultation  fatigue”  among 
stakeholders (meaning that additional consultation should be targeted and limited to what 
is strictly necessary);  

4) previous evaluations encountered difficulties in measuring the costs and benefits 
of complex IT systems due to limited data; and 

5) the recently introduced MEF offers more data and insight on the programme than was 
available for previous evaluations. 

2.  Overall methodological framework 

The methodological approach was based on combining depth (via case studies) and breadth 
(via targeted and general research on key (horizontal) aspects of the Customs programme). 
This work was guided throughout by the intervention logic. 

The approach prioritised the most resource-intensive aspects of the data collection efforts 
on a set of four stand-alone case studies on specific EES. A detailed cost-benefit analysis 
was carried out for three of these systems, which – while evidently not representative of 
all EES – were indicative of the types of costs and benefits of the programme and covered 
different expected benefits. 

A great deal of work was put in to conducting a Learning Management System (LMS) case 
study. 

The approach to these case studies, including the cost-benefit analysis, incorporated the 
specific  challenges  of  the  previous  evaluation,  namely  the  difficulties  of  quantifying 
benefits. Counterfactual scenarios were developed for three IT systems - ICS2, PoUS and 

63 

 
 
EU  CCI  -  to  better  quantify  the  contribution  of  the  programme  compared  with  an 
alternative without EU support.  

For these three EES, the cost-effectiveness of the programme funding was quantified by 
comparing  the  costs  actually  incurred  under  the  current  system  architectures  with  the 
projected  costs  under  the  most  realistic  counterfactual  scenarios.  Data  on  the  projected 
costs for the theoretical counterfactuals were obtained through interviews and a survey for 
national customs administrations. Although variation in the granularity of responses made 
it difficult to gain a comprehensive understanding of costs in all cases, the data allowed for 
an approximated quantification of the cost-effectiveness for ICS2 and PoUS (but not EU 
CCI). 

While the case studies provide depth, the evaluation also needs to cover the breadth of the 
support the programme provides, i.e. including other EES, general collaborative actions 
and the horizontal aspects of delivering the programme. In the case of general collaborative 
actions, this is particularly true of certain ‘new’ elements under the seventh iteration of the 
Customs  programme.  In  terms  of  programme  delivery,  an  updated  assessment  of  the 
functioning  of  the  MEF  is  required.  It  is  also  necessary  to  assess  the  governance 
mechanism for collaborative actions. 

The data-collection process for assessing the programme as a whole was designed to be 
comprehensive, again prioritising primary research on the key issues. Desk research was 
used  extensively  throughout.  Targeted  interviews  mainly  concerned  the  main  areas  of 
interest as per the Terms of Reference and initial scoping discussions with DG TAXUD 
(mainly  focusing  on  effectiveness  and  efficiency).  The  survey  of  national  customs 
administrations was used primarily to fill in gaps and to broaden the findings from the case 
studies. 

Structuring and scoping 

The  initial  analytical  framework  was  supported  by  desk  research  reviewing  existing 
programme documentation, annual progress reports and policy documents. An evaluation 
matrix was aligned with the customs intervention logic to establish clear indicators, data 
sources and judgement criteria for each evaluation question. The evaluation matrix (Annex 
III)  addressed  13  questions,  focusing  on  the  programme’s  effectiveness,  efficiency, 
coherence,  EU  added  value  and  relevance.  This  task  also  involved  developing  a 
methodology, which included defining the sample of four EES and the LMS for in-depth 
case studies and the data-collection strategy, both of which are described in more detail 
below. 

The most extensive and important feature of the methodology for this evaluation was 
the case studies on four EES, which were carried out to facilitate an in-depth assessment 
of IT systems, which account for the biggest proportion of Customs programme funding.  

In previous evaluations, providing quantified estimates of the costs and benefits of the IT 
systems (and of support for them from the Customs programme) had proved very difficult, 
partly because the point of comparison for assessing such costs and benefits was not always 
clear.  

64 

 
 
This was because i) IT systems typically go hand-in-hand with EU legislation under which 
digital data exchange is mandatory, and ii) it cannot be assumed that the absence of the 
(common  components  of)  the  EES  would  simply  imply  a  return  to  mostly  paper-based 
exchange of information. To address this issue, a new approach in this interim evaluation 
was to compare each system to a hypothetical, ‘counterfactual’ scenario of what may have 
been expected in the absence of EU funding. 

The purpose of the only non-IT case study – on the LMS – was to examine an aspect of 
the  programme  that  was  new  for  the  current  funding  period.  Rather  than  covering  all 
remaining actions in detail, the programme assessment was aimed solely at confirming 
the  validity  of  previous  evaluations  and  gathering  new  insight  on  issues  of  particular 
interest,  most  importantly  the  EU  added  value  of  the  collaborative  actions  and  expert 
teams. 

Data collection and analysis 

Existing  documentation  such  as  policy  and  programming  documents,  Customs  annual 
progress  reports  (APRs)  and  MEF  data  were  reviewed  to  provide  understanding  and 
context.  Key  information  and  gaps  were  systematically  mapped  to  guide  further  data-
collection  steps.  Data  for  both  the  case  studies  and  the  programme  assessment  was 
collected using three main methods: 

1.  desk research to review a wide range of sources of secondary data and information; 

2.  targeted  interviews  with  representatives  of  national  customs  authorities  and  the 
European  Commission  and,  where  relevant,  economic  operators  and  external 
contractors; and 

3.  two  targeted  surveys,  one  for  the  national  customs  authorities  of  participating 

countries (31 responses) and for online users of the LMS (62 responses). 

Overall, the interim evaluation sought to collect qualitative and quantitative data, and data 
on the implementation of the programme and its impact. 

Case studies on EES 

The interim evaluation focused on a series of in-depth case studies of specific EES which 
account for a very large proportion of the budget allocation and are frequently described 
as the backbone of the Customs Union. The programme supports around 70 systems, and 
this uses up most of the programme budget, around 95%. 

The sample comprised systems developed and/or to be deployed during this programming 
period, which contributed to different programme (and customs policy) objectives: ICS2, 
PoUS, EU CCI and ICG. The case studies provided an assessment of the effectiveness, 
efficiency, relevance and EU added value of the sampled systems. In three cases this was 
based on a counterfactual approach. 

65 

 
 
 
 
Table 5: EES case studies 

European 
Electronic 
System (EES) 

Point in 
customs 
process 

Maturity 
(2021-2024) 

Expenditure 
intensity 

System 
architecture 

Import Control 
System (ICS2) 

Pre-arrival 
security and 
safety 

Most advanced 
(phase 3 of 3 
deployed) 

Very high 

Centralised  

Proof of Union 
Status (PoUS) 

Goods status 
determination 

Emerging (phase 
1 of 2 deployed) 

Medium 

Hybrid  

EU Centralised 
Clearance for 
Import                   
(EU CCI) 

Import of 
Cultural Goods 
(ICG) system 

Import 
clearance 

Emerging (phase 
1 of 2 deployed) 

Medium 

Distributed  

Specialised 
import controls 

Newest (deployed 
in 2025) 

Low 

Centralised 
(based on 
TRACES) 

The methodology for the case studies was tailored to the system but in each case involved 
comprehensive  desk  research  and  in-depth  stakeholder  interviews.  In  the  case  of  ICS2, 
PoUS,  EU  CCI  a  written  questionnaire  was  sent  to  authorities  to  support  the  detailed 
costing of the counterfactual (see below). The interviews included EU officials, national 
authorities and economic operators1. Triangulation was used to ensure the robustness of 
the reported analysis. 

Alternative or counterfactual scenarios were developed for three of the EES case studies 
to  better  assess  the  systems’  impacts,  by  comparing  the  actual  costs  and  benefits  they 
generate with a hypothetical alternative situation where no customs (or other EU) funding 
is  available  to  develop  and  maintain  the  systems.  Two  main  types  of  counterfactual 
situation were considered, with the most appropriate one for each case study chosen as a 
point of comparison: 

•  The  first  was  a  hypothetical  continuation  of  the  prevailing  situation  before  the 
system  became  operational,  allowing  for  a  simple  ‘before  and  after’  comparison. 
However,  this  counterfactual  was  not  always  appropriate  as  i) certain  systems  have 
been in use for over 20 years, making a return to paper-based information exchange 
unrealistic,  and  ii)) many systems  serve to  address  specific, requirements  under EU 
legislation,  meaning  that  a  scenario  where  they  simply  did  not  exist  would  be 
unfeasible, i.e. disregarding the obligation for the various actors (including the Member 
States) to comply with the legal requirements on the electronic exchange of data. 

•  The second was to assume that Member States would still need to meet the relevant 
legal  obligations,  but  without  EU  support  –  in  particular,  without  Customs 
programme funding for common systems, components and/or technical specifications. 
In other words, the Member States would have to find ways to ensure that data could 

66 

 
 
be exchanged electronically, without relying on the EU to support interoperability or 
centralised systems. 

Table 6: Counterfactual scenarios selected for ICS2, PoUS and EU CCI 

ICS2 

PoUS 

EU CCI 

A  scenario  where 
there 
would not be an EU CCI in 
place 
force 
(a  case  of 
majeure)  

1.  A 

distributed 

system 
nationally, 
developed 
where each Member State 
would  have  to  provide 
in 
economic  operators 
their  country  with  an 
equivalent 
electronic 
system.  

2.  Adapting 

already 
an 
existing system such as the 
NCTS to add the PoUS of 
goods.  

distributed 

A 
system 
where each Member State 
would  have  to  develop 
for 
their  own 
system 
to 
economic  operators 
comply  with  the  relevant 
(additional) 
obligations 
and share information with 
all  Member 
States 
involved.  

Source: the author 

Non-IT case study 

In addition to the four case studies on EES, the evaluation included a dedicated case study 
on the learning management system (LMS). The LMS (officially called the Customs & 
Tax EU Learning Portal),2 was launched in May 2021 as a one-stop shop for all training 
and capacity-building activities carried out under the Fiscalis and Customs programmes. 
The LMS portal provides access to e-Learning courses, webinars, nano-learning modules 
and e-books; some of these are solely for customs and tax officials whereas others are also 
open to other interested stakeholders such as economic operators and academics.  

It also acts as the central access point  for training courses in the CLEP,  where national 
officials can submit applications to take part in online or in-person events. 

This  case  study  did  not  evaluate  the  content  of  the  e-Learning  materials  or  the  CLEP 
training  courses,  which  had  already  been  analysed  comprehensively  in  previous 
assessments, and the findings remained applicable. Instead, it concentrated on the LMS. It 
examined  how  well  the  platform  met  the  needs  and  expectations  of  Member  States, 
identified areas for functional improvement and assessed its complementarity with other 
national and international initiatives.  

The case study also looked ahead at potential changes and possible new features that could 
boost its value to the Member States. To achieve this, it investigated possible new features 
that might benefit the Member States and assessed their receptiveness to broadening the 
LMS’s role to include hosting national training modules, in addition to European ones. 

67 

 
 
 
The  data  collection  for  this  case  study  included  background  information,  including  the 
original business case for the LMS, tender specifications and contracts for its development 
and operation, and budgetary data. It also included the LMS platform itself and the training 
catalogue.  

Statistical data were also gathered on i) courses downloaded, ii) courses completed, iii) 
registered users, iv) participation levels among public officials and private stakeholders, 
v) learning outcomes and basic website statistics. Documents on the LMS produced by DG 
TAXUD and the Training Support Group (TSG) were also included, such as the results of 
a survey conducted of national training coordinators and a paper by DG TAXUD on the 
future of the LMS. 

The stakeholder consultation comprised two main sections. Firstly, eight interviews were 
conducted with DG TAXUD, the contractor responsible for developing and operating the 
LMS, and customs officials taking part in the TSG from five Member States. Secondly, a 
survey  of  LMS  users  conducted  by  TSG  members  was  published  on  the  LMS  site, 
alongside  a  parallel  case  study  on  the  LMS  for  the  Fiscalis  platform,  and  garnered  62 
replies. Of these, 33 expressed an interest in customs only, and 19 expressed an interest in 
both  taxation  and  customs;  the  remaining  10  respondents  expressed  an  interest  only  in 
taxation and are not referred to in this report. 

Programme assessment 

The data collection for the programme assessment involved an extensive desk review of 
documents  and  sources  of  information  including  i)  the  updated  MEF,  ii)  programming 
documents,  iii)  previous  evaluations  and  assessments,  and  other  monitoring  documents 
such as annual progress reports and iv) elements of the programme such as the MASP-C 
and UCC work programme and reports). 

In  addition  to  the  review  of  documents,  18  targeted  interviews  were  conducted  with 
Commission officials from DG TAXUD and other DGs, and an online survey took place 
among national coordinators in national customs administrations to fill gaps in the findings 
and to validate the main emerging lessons. 

Final Analysis and Lessons Learned 

Extensive  analysis  of  quantitative  and  qualitative  data  was  conducted  throughout  the 
programme, with statistical software used for survey responses and programme indicators 
used to identify trends, correlations and impact metrics. This included cost-benefit analyses 
derived  from  the  case  studies.  Qualitative  data  were  processed  to  reveal  themes  and 
patterns in interview transcripts and survey responses. Triangulating data across multiple 
sources ensured that the conclusions were reliable and consistent. 

The  conclusions  drawn  from  this  comprehensive  analysis  addressed  the  five  evaluation 
criteria:  effectiveness,  efficiency,  relevance,  coherence  and  EU  added  value.  They 
highlighted  the  achievements  of  the  programme  while  also  pinpointing  areas  for 
improvement, supported by robust evidence. 

68 

 
 
The  analysis  phase  identified  lessons  learned,  best  practices  and  areas  for  potential 
improvement,  which  are  detailed  in  the  interim  evaluation  itself.  Further  details  on  the 
underlying evidence, including the functioning of the assessed EES and their contribution 
to  the programme’s general  and specific objectives,  can be found in  the annexes of the 
external support study. 

3.  Limits to the evidence base and robustness of findings 

For several different types of system, the case studies sought to go into more depth than 
has been possible in  the past,  shedding new light on the costs and benefits, and factors 
boosting and hindering  success.  In previous evaluations  it was very difficult  to  provide 
quantified  estimates  of  the  costs  and  benefits  of  the  IT  systems  (and  of  Customs 
programme support for them), partly because the point of comparison was not always clear. 
This was because  IT systems typically go hand-in-hand with  EU legislation that makes 
digital data exchange mandatory, and it cannot always be assumed that the absence of the 
(common components of) the EES would imply a return to the previous situation of mostly 
paper-based exchange of information.  

To address this issue, a new approach to this evaluation was to compare each system to a 
hypothetical ‘counterfactual’ scenario – agreed with DG TAXUD – of what may have been 
expected in the absence of EU funding. 

The purpose of the only ‘non-IT’ case study – on LMS – was to examine an aspect of the 
programme  that  was  new  for  the  current  funding  period.  The  programme  assessment, 
rather than covering all remaining actions in detail, was aimed  solely at  confirming the 
validity of previous evaluations and gathering new insight on issues of particular interest 
to DG TAXUD, most importantly the EU added value of collaborative actions and expert 
teams. 

Overall, the methodology proved effective. The counterfactual approach to the case studies 
on EES, allowed for harvesting insight of a different nature and scale than had previously 
been achieved, by pinpointing the ways in which EES – and related collaborative actions 
– contribute to the work of national administrations and economic operators and generate 
EU added value, compared to the most likely alternative scenario.  

With some minor exceptions, it was possible to identify and engage with stakeholders as 
hoped, and case studies were able to build a solid evidence base. The LMS case study and 
programme  assessment  were  also  implemented  largely  as  planned  and  obtained  the 
expected input. That said, there are two key limitations that should be pointed out: 

▪  Trade-off between depth and breadth: based on the considerations set out above, 
the  evaluation  deliberately  chose  to  go  into  more  depth  on  certain  IT  systems, 
which  meant  that  other  IT  systems  and  aspects  of  the  programme,  particularly 
collaborative  actions,  could  not  be  assessed  in  as  much  detail  as  in  previous 
evaluations.  For  this  reason,  the  evidence  for  certain  evaluation  questions 
(particularly those not focused on the EES) was limited. In these cases, key findings 

69 

 
 
and conclusions from previous evaluations were used as a starting point, and either 
confirmed, disproved or on the basis of the available data and information. 

▪  Fragmented IT cost data: the rationale for the approach based on in-depth IT case 
studies  was  also  to  conduct  a  detailed  cost-accounting  exercise  on  the  systems 
concerned. Due to confidentiality reasons, only a reduced data set was available, 
covering  fewer  cost  categories  and  a  shorter  timeframe  than  initially  planned. 
Accordingly, while the IT case studies were able to generate significant and – in 
many instances, quantitative – insight, it was not possible to conduct a full cost-
accounting exercise. 

70 

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

This Annex sets out the detailed analysis by judgement criterion to reply to the evaluation 
questions (EQs) by criterion (see table below), providing all relevant detail on the evidence 
base informing the narrative replies to the evaluation questions in Section 4 of the main 
report.  This  document  also  includes  the  evaluation  matrix  that  formed  the  organising 
framework of the interim evaluation. Please note, the current order of questions has been 
slightly amended in the interests of logical flow. 

The  evaluation  matrix  and  the  analysis  of  the  EQs  address  all  the  evaluation  criteria: 
effectiveness, efficiency, coherence, EU added value and relevance, following the order of 
the  main  report.  The  interim  evaluation’s  robustness  comes  from  triangulated  evidence 
from a comprehensive set of targeted data-collection tools (provided in Annex II). 

Table 7: Effectiveness evaluation matrix 

Evaluation Question 

Judgement Criteria 

Indicators 

Sources 

1.  Overall, how 

effective has the 
programme been in 
contributing to the 
achievement of its 
objectives?  

Scoping interviews 

Desk research 

Survey 

Answers to EQs 2-4  

Perception of 
beneficiaries and 
stakeholders in 
interviews and online 
consultation that the 
programme as a whole 
is on track to achieve its 
objectives, both general 
and specific 

Analysis and 
triangulation of findings 
from other effectiveness 
EQs 

Data from the 
programme indicator: 
Union Law and Policy 
Application and 
Implementation Index  

Impact indicators from 
MEF relating to general 
objectives 

The effects of the programme 
referred to in the specific EQs 
under ‘effectiveness’ confirm 
that the programme is 
supporting: 

• 

the customs union 
and customs 
authorities working 
as one; 

is contributing to: 

• 

• 

ensuring security and 
safety within the 
Union 

protection of the 
financial and 
economic interests of 
the Union 

• 

facilitating legitimate 
business activity. 

is supporting: 

• 

the preparation and 
uniform 
implementation of 
customs legislation 
and policy; 

• 

customs cooperation; 

71 

 
 
 
 
 
 
 
 
 
• 

administrative and 
IT capacity building, 
including human 
competency and 
training, as well as 
the development and 
operation of 
European electronic 
systems; 

• 

innovation in the 
area of customs 
policy. 

Perception of 
beneficiaries and 
stakeholders in 
interviews and online 
consultation of 
programme-related 
factors that have 
contributed to or 
hindered the 
achievement of the 
specific and general 
objectives 

There have been unexpected 
or unintended (positive or 
negative) consequences that 
have driven or hindered 
progress, and it is possible to 
identify the causes. 

Quantitative and/or 
qualitative data from 
and data from key 
Customs programme 
documentation 

The link between the Customs 
programme’s IT and the EES 
complemented with the 
national components is 
allowing for full 
implementation of the UCC 
systems. 

The programme is 
communicating and 
disseminating its 
achievements and the 
opportunities it offers. 

The Member States (primarily 
the customs authorities) have 
taken steps to ensure their 
administrations and economic 
operators make full and 
effective use of the EES.  

There are identifiable benefits 
for stakeholders from the IT 
capacity-building activities of 
the Customs programme 

Individual IT systems or 
clusters of systems are 
delivering the intended 

72 

2.  To what extent have 
the IT capacity 
building activities 
(incl. programme 
support for the 
EES) contributed to 
the achievement of 
the programme’s 

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation): 

- of the benefits of the 
Customs programme 

EES case studies 

Scoping interviews 

Desk research 

 
 
 
 
 
 
  
 
 
general and specific 
objectives  

Survey 

outputs achieving the 
expected results (specific 
objectives) and having the 
intended impact (general 
objectives) 

There is evidence that some 
IT systems or clusters of 
systems are contributing more 
than others to achieving the 
expected results and having 
the intended impact  

and the hierarchy of 
benefits 

- of the extent to which 
the IT capacity-building 
activities (individually, 
in clusters or as a 
whole) are contributing 
to achievement of the 
general and specific 
objectives 

Scoping interviews 

Desk research 

Targeted interviews on 
general collaborative 
activities 

Survey 

Quantitative and/or 
qualitative data on 
programme indicators 
(e.g. on the availability 
of systems), indicators 
from the MEF, and data 
from key Customs 
programme 
documentation  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation): 

- of the benefits of the 
Customs programme 
and the hierarchy of 
benefits 

- of the extent to which 
the collaborative and 
human capacity-
building activities 
(individually, in clusters 
or as a whole) are 
contributing to 
achievement of the 
general and specific 
objectives 

Quantitative and/or 
qualitative data on 
programme indicators 
(including the Learning 
Index, the Collaboration 
Robustness Index and 
the Best Practice and 
Guideline Index), 
indicators from the 
MEF, and data from 

3.  To what extent have 
the collaborative 
and human 
competency 
building activities 
contributed to the 
achievement of the 
programme’s 
general and specific 
objectives?  

There are identifiable benefits 
for stakeholders from the 
Customs programme’s 
collaborative and human 
capacity- building activities, 
i.e. 

•  meetings / events – 
project-based 
collaboration 

• 

• 

human competency 
building (training) 

support (including 
innovation) and 
other actions 
(including Expert 
Teams (such as the 
ECCG and the 
Expert team on 
Customs IT 
(ETCIT)) 

The collaborative and human 
capacity-building activities 
are delivering the intended 
outputs, achieving the 
expected results (specific 
objectives) and having the 
intended impact (general 
objectives), but some are 

73 

 
 
 
 
 
  
 
 
 
 
 
  
making a greater contribution 
than others 

The LMS for customs 
contributes to the objective of 
‘acting as one’  

key Customs 
programme 
documentation  

4.  To what extent has 

the programme’s 
new eligible action 
on innovation been 
used?  

The new eligible action on 
innovation is being used. It is 
meeting a need and there are 
no obstacles to 
implementation 

The programme is 
accommodating new 
technological developments 
satisfactorily  

Targeted interviews on 
innovation 

Desk research (add 
sources)  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of putting 
the new action into 
practice and the extent 
to which innovation is 
embedded in other 
activities rather than 
being dealt with as a 
stand-alone activity 

Quantitative and/or 
qualitative data from 
key Customs 
programme 
documentation  

Table 8: Efficiency evaluation matrix 

Evaluation Question 

Judgement Criteria 

Indicators 

Sources 

5.  To what extent is the 
programme’s funding 
to the common 
components of the 
EES cost effective?  

EES case studies 

Scoping interviews 

Desk research 

Survey 

The costs of the common 
components are 
proportionate to the 
objectives of the specific 
systems and the 
expected results (specific 
objectives) and impact 
(general objectives) of 
the programme 

There are critical issues 
or inefficiencies which 
need to be addressed in 
order to optimise 
efficiency1 

There is scope for 
increasing efficiency via 

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
benefits relative to cost of 
the common components 
of the EES, and the scope 
for greater efficiency and 
/or additional measures 
that can be introduced in 
the short- and medium-
term to bring about 
improvements 

Quantitative and/or 
qualitative data on 
programme indicators, 
indicators from the MEF 
and data from key 

74 

 
 
 
 
 
 
 
 
 
 
 
 
  
simplification and cost 
reduction 

Customs programme 
documentation 

Cost elements and costs 
of the specific EES 
(common components) 
financed by the 
programme  

The benefits of the 
current approach to 
contractual management 
of common components 
of the EES outweigh the 
risks of the identification 
of costs per electronic 
system 

6.  To what extent is the 
governance of the 
programme’s funding 
of collaborative 
activities cost 
effective?  

The resources for the 
collaborative activities 
are proportionate to their 
contribution to the 
results and impacts of 
those activities and of 
the programme 

The grant management 
approach is achieving 
the desired objective of 
incentivising Member 
States to take a proactive 
role in the collaborative 
activities 

There is scope for 
increasing efficiency via 
changes in governance  

The resources for the 
training activities 
financed by the 
programme are 
proportionate to the 
contribution they make 
to the results and impact 
of those activities and of 
the programme itself 

7.  To what extent is the 
programme’s funding 
of human competency 
activities cost 
effective?  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
benefits of the 
collaborative activities in 
relation to their cost, and 
the scope for greater 
efficiency 

Quantitative and/or 
qualitative data on 
indicators on 
collaborative activity, the 
direct and indirect costs 
of the grant management 
system, and other 
relevant documentation  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
benefits of human 
competency activities in 
relation to their cost 

Scoping interviews 

Desk research 

Survey 

Targeted interviews on 
collaboration 

Case study on learning 

Scoping interviews 

Desk research 

Survey  

Coordination with 
national training 
activities and those of 
other bodies (e.g. the 
WCO, the European 

Quantitative and/or 
qualitative data 
supporting the Learning 
Index and Knowledge 
Sharing and networking 
indicators, indicators 

75 

 
 
 
  
 
 
 
 
 
 
 
 
  
 
 
 
 
 
8.  How efficiently has 
the programme 
governance worked 
during the current 
MFF given the tools 
available (i.e. the 
MEF and MASP-C)?  

from the MEF, minutes 
of the Training Support 
Group etc. 

Cost data on human 
competency activities  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
benefits of the MEF and 
MASP-C in relation to 
their cost and the extent 
to which there is scope 
for improvement 

Quantitative and/or 
qualitative data from the 
MEF and MASP-C and 
customs programme 
documents or workflows 
which rely on them as 
inputs  

Union Agency for Law 
Enforcement Training 
(CEPOL)) ensure 
optimal use of 
programme resources 

There is scope for 
simplification without 
any loss of efficiency  

The resources required 
by the MEF and MASP-
C are proportionate to 
the contribution they 
make to the expected 
results and impact of 
these activities and of 
the programme 

There are improvements 
that could be made to the 
MASP-C to optimise its 
use as a project and 
planning support tool. 

The MEF could be 
improved and simplified 
in ways that enhance its 
use as a tool to measure 
progress towards 
achieving the objectives 
of the programme  

Scoping interviews 

Desk research 

Survey 

Targeted interviews on 
programme 
management  

Table 9: Coherence evaluation matrix 

Evaluation Question 

Judgement Criteria 

Indicators 

Sources 

9.  To what extent are the 
conclusions on the 
coherence of the 
programme set out in the 
Customs 2020 final 
evaluation still valid?  

The Customs programme 
is continuing to support 
other EU initiatives and 
programmes and benefit 
from them. 

The Customs programme 
is avoiding overlaps and 
developing synergies with 

76 

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
continuing validity of 
the conclusions of the 
Customs 2020 final 
evaluation 

Scoping interviews 

Desk research 

Survey 

Targeted 
interviews 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case studies where 
relevant  

Quantitative and/or 
qualitative data on 
Programme indicators, 
indicators from the 
MEF and data from key 
customs programme 
documentation, such as 
annual progress 
reports  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
coherence between the 
Customs programme 
and the CCEI in the 
implementation of their 
roles 

Data from, for 
example, annual 
progress reports of the 
Customs programme 
and CCEI annual 
reports, work 
programmes, and data 
from other key 
Customs programme 
documentation  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
coherence between the 
Customs programme 
and Fiscalis in the 
implementation of their 
roles 

Scoping interviews 

Desk research 

Survey 

Targeted interview 

Scoping interviews 

Desk research 

Survey 

Targeted interview 

other EU spending 
programmes 

Key elements of the 
Action Plan issued in 
follow-up to the Customs 
2020 final evaluation are 
being implemented, i.e. 
improved risk 
management, improved 
management of e-
commerce, improved 
promotion of compliance, 
customs authorities acting 
as one.  

The interface between the 
roles of the Customs 
programme and the CCEI 
is seamless and 
synergistic, in line with 
the requirements of 
current policy  

10.  To what extent is the 

programme’s 
complementarity with the 
new CCEI achieved, in 
terms of policy needs?  

11.  To what extent is the 

programme’s 
complementarity with the 
Fiscalis programme 
sufficiently achieved, in 
terms of policy needs2?  

The interface between the 
roles of the Customs 
programme and Fiscalis is 
seamless and in line with 
the requirements of 
current policy  

77 

 
 
 
 
 
 
 
  
 
 
 
 
 
  
Quantitative and/or 
qualitative data from 
for example, DG 
TAXUD annual 
activity reports and 
management plans, 
work programmes, and 
other Customs 
programme and 
Fiscalis documentation  

Table 10: EU added value evaluation matrix 

Evaluation Question 

Judgement Criteria 

Indicators 

Sources 

12.  To what extent are 
the conclusions on 
the EU added value 
of the programme set 
out in the Customs 
2020 final evaluation 
still valid?  

Case studies on EES 
and learning 

Scoping interviews 

Desk research 

Survey 

Targeted interview 

The Customs programme 
is achieving efficiencies 
of scale and efficiency 
gains in IT capacity-
building that save time 
and resources for national 
administration and 
economic operators that 
could not be achieved in 
any other way 

Joint actions and training 
are providing 
opportunities for 
cooperation, 
communication and 
networking across the EU 
that could not be achieved 
in any other way 

The IT capacity-building 
activities (the EU-level 
digital environment) help 
facilitate legitimate 
business activity in the 
internal market and in 
external trade to the 
benefit of all stakeholders, 
including citizens, 
achieving the expected 
impacts (general 
objectives) of the 
Programme 

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) that the 
benefits of the Customs 
programme in IT and 
human capacity building 
for national 
administrations and 
economic operators are 
ongoing. Such benefits 
could not be replicated in 
any other way 

Quantitative and/or 
qualitative data from EQs 
on effectiveness and 
efficiency 

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of how 
impossible it would be 
without EU funding to 
continue to obtain the 
benefits of: 

- IT capacity building for 
EU stakeholders and 
citizens in terms of 
facilitation of the Single 
Market and international 
trade  

78 

 
 
 
 
 
 
 
 
 
  
- human capacity building 
in terms of the uniform 
implementation of 
customs legislation and 
customs cooperation  

Quantitative and/or 
qualitative data on the 
benefits of the programme 
from evaluations and 
impact assessments and 
other Customs programme 
documentation  

The human competency 
building activities, such as 
the Customs & Tax EU 
Learning Portal, 
contribute to the uniform 
implementation of 
customs legislation by 
national administrations 
and help to achieve the 
expected impact (general 
objectives) of the 
programme 

The collaboration 
activities (e.g. expert 
teams and other 
collaborative activities), 
contribute to customs 
cooperation and help 
achieve the expected 
impacts (general 
objectives) of the 
programme  

Table 11: Relevance evaluation matrix 

Evaluation Question 

Judgement Criteria 

Indicators 

Sources 

13.  To  what  extent  is 

programme 
support  able 
to 
adapt  to  changing 
needs? 

The Programme has been 
able to adapt to evolving 
customs policy 
priorities4. 

There are new policy 
objectives/aspects to be 
taken into account that 
may have a negative 
impact on the added 
value of the programme, 
or may reinforce it (e.g. 
economic/policy context) 

The legal scope of the 
programme is 
appropriate in terms of 
meeting the evolving and 
expanding role of 

79 

Scoping interviews 

Desk research 

Survey 

Targeted interviews 
on relevance 

Case studies where 
relevant  

Perception of 
beneficiaries and 
stakeholders (in 
interviews and online 
consultation) of the 
ways in which the 
programme has (or has 
not) kept pace with 
changes in the 
economic and customs 
and EU policy 
environment, including 
enlargement 

Quantitative and/or 
qualitative data from 
documentation on 
customs and EU policy 
priorities since 2021 
and the way in which 
the economic context 

 
 
 
  
 
 
 
 
 
 
 
has affected them, 
including DG TAXUD 
and Customs 
programme 
documentation  

customs at the external 
borders. 

The scope of the actions 
provided for under the 
programme is suitable in 
terms of meeting the EU 
IT and collaboration 
needs of the Commission 
and the Member States 
(it is flexible, all 
necessary types of 
intervention and activity 
can be covered, and all 
stakeholders are 
sufficiently involved) 

There are no challenges 
or limitations restricting 
the ability to meet EU IT 
and collaboration needs  

80 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS 

The table below summarises the costs and benefits of the Customs programme itself 
(rather  than  the  policy  it  supports),  as  identified  by  the  interim  evaluation.  The 
programme focuses on activities forming two main building blocks: (i) support for 
the  common  elements  of  the  EES  and  (ii)  collaborative  activities.  The  interim 
evaluation  methodology  distinguished  between  the  costs  and  benefits  of  these 
different building blocks, an approach adopted in this overview. 

As regards the costs, the table does not include the cost of the programme itself for 
the  EU  budget  (EUR 950  million  for  the  period  2021-2027).  However,  it  is  worth 
recalling that approximately 95% of this amount is allocated to around 70 different 
EES. 

Regarding  the  EES  given  the  wide  range  of  digital  systems  supported  by  the 
programme, the study did not set out to comprehensively assess the costs or benefits 
of all systems. Rather, a carefully selected sample of digital systems was chosen for 
in-depth study (see Annex II). Across the selected cases, the study consistently found 
that the approach taken was less costly than possible alternatives (as detailed in the 
counterfactual analyses for three of the four systems). 

In  terms  of  direct  compliance  costs  to  businesses,  while  there  are  plenty  of  these 
associated  with  customs  policy  –  and  the  regulation  derived  from  it  –  but  the 
programme does not create compliance costs for businesses per se. While the systems 
supported by the programme do involve compliance costs, these were not quantified 
systematically for the purposes of this interim evaluation. Instead, the focus was on 
assessing  the  relative  cost-effectiveness  of  the  systems  compared  to  possible 
alternatives.  Again,  the  findings  confirmed  that  the  systems  supported  by  the 
programme were less costly than the possible alternatives. 

Regarding collaborative activities, the costs incurred by Member States were limited 
primarily  to  the  burden  of  managing  grants  and  reporting  for  participation  in 
collaborative  activities  (e.g.  expert  teams  and  project  groups).  These  costs  were 
assessed qualitatively by collecting information on the proportionality of the burden 
of participation via a questionnaire for national customs administrations. Follow-up 
interviews were conducted to fill gaps or clarify the interpretation of this data. 

81 

 
Table 12: Overview of costs and benefits identified in the interim evaluation 

Citizens  

Businesses 

Administrations 

Quanti
tative  

Comm
ent 

Quantit
ative  

Comme
nt 

Quant
itativ
e 

- 

None 

- 

None 

- 

- 

- 

- 

None 

None 

None 

- 

- 

- 

None 

None 

None 

- 

- 

- 

- 

None 

- 

None 

- 

Direct compliance 
costs 

Enforcement costs 

Indirect costs 

Direct benefits 

Indirect benefits 

Comment  

Costs (burden) of 
participation in 
collaborative actions is 
low, according to 
feedback received 
from administrations. 

None 

None 

Common components 
relieve burden on 
national 
administrations, 
generating savings 
estimated at 2 – 4 
times the investment 
required, based on the 
example of a complex 
and resource-intensive 
system like ICS2.  

Protection of the 
financial and 
economic interests of 
the EU and its 
Member States, 
ensuring security and 
safety in the Union 
and protecting the 
Union and EU citizens 
from illegal and unfair 
trade. 
Customs authorities 
working together, 
enhancing the uniform 
implementation of 
customs legislation 
and policy (LMS, 
collaborative actions) 

82 

 
 
 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT 

This annex summarises all stakeholder consultation activities undertaken for the interim 
evaluation of the Customs programme 2021-2027. It gives a qualitative and quantitative 
analytical overview of the results of all consultation activities. It also explains how and to 
what extent stakeholders’ views have been considered. Its aim is to inform policymaking 
on the outcome of all consultation activities, reflecting the views of the different 
categories of stakeholder. 

1. Outline of the consultation strategy 

The objective of the consultation strategy was to gather stakeholders’ views regarding 
various elements of the Customs programme and its performance, and to compare and 
integrate the evidence collected through desk research. 

Consultations included i) targeted EU-level interviews with Commission staff, ii) an 
online survey of the national customs authorities, iii) in-depth interviews with national 
customs authorities on case studies, iv) economic operators or associations of economic 
operators, and LMS external contractors, v) email questionnaires for national customs 
authorities on three of the five thematic case studies, and vi) an online survey of LMS 
users as part of the LMS case study.  

The following gives a summary of which stakeholders were consulted and the method 
used. 

•  EU-level interviews: Commission staff (DG TAXUD, DG GROW, DG RTD, DG 

SANTE, DG REFORM, OLAF, JRC) 

•  Online survey: national customs authorities 

•  Case studies (in-depth interviews): DG TAXUD officials, national customs 
authorities, economic operators and their associations, relevant external 
contractors (LMS) 

•  Case studies (email questionnaires): national customs authorities 

•  Case studies (online survey): LMS users. 

1.  EU-level interviews 

18 in-depth interviews at EU level were conducted, aimed at gaining a better 
understanding of i) the performance of the Customs programme, ii) the validity of 
findings from the previous evaluation, iii) an assessment of governance mechanisms, 
innovation and different modalities of the programme (DG TAXUD), and iv) its 
coherence with other EU funding mechanisms (DG TAXUD, GROW, REFORM, 
SANTE, OLAF). 

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Table 13: EU-level targeted interviews 

Topic  

General aspects  

Respondents  

1: General collaboration and governance   DG TAXUD  

2: Expert teams  

3: Innovation  

4: Collaborative activities  

5: MEF / MASP-C  

6: Validity of final evaluation findings 
/follow up of action plan  

DG TAXUD  

DG TAXUD  

DG TAXUD  

DG TAXUD  

DG TAXUD  

7: Customs control and risk management   DG TAXUD  

8: E-commerce  

DG TAXUD  

9: Relevance / enlargement  

DG TAXUD  

10: Cost accounting  

DG TAXUD  

Coherence aspects  

11: General  

12: Fiscalis  

DG TAXUD  

DG TAXUD  

13: Union Anti-Fraud Programme  

European Anti-Fraud Office (OLAF)  

14: CCEI  

DG TAXUD  

15: UFPA - AFIS strand  

OLAF  

16: Technical Support Instrument (TSI)  

DG REFORM  

17: Single Market Programme (SMP)  

DG GROW  

18: Horizon Europe  

Beneficiary  

84 

 
 
 
 
 
2.  Online survey of national customs authorities 

The online survey via the EUSurvey tool was launched on 26 February 2025 and it 
remained open until 17 March. DG TAXUD distributed the survey via the PICS to the 
national customs administrations of the participating countries. 30 respondents (out of a 
total of 37) contributed to the survey, as in the list in the table below. This corresponds to 
a response rate of 81%. 

Table 14: National customs authorities contributing to the online survey 

No   Country  

1   Czech Republic  

2   Latvia  

3   Cyprus  

4   Portugal  

5   Poland  

6   Bulgaria  

7   Lithuania  

8   Malta  

9   Hungary  

10   Slovakia  

11   Romania  

12   Estonia  

13   Germany  

14   Italy  

15   France  

No   Country  

16   Sweden  

17   Türkiye  

18   Greece  

19   Slovenia  

20   Denmark  

21   Kosovo  

22   Luxembourg  

23   North Macedonia  

24   Croatia  

25   Finland  

26   Netherlands  

27   Republic of Serbia  

28   Republic of Moldova  

29   Belgium  

30   Spain  

3.  Thematic case studies 

Five thematic case studies were conducted, including four case studies on specific 
customs IT systems: 

• 

Import Control System (ICS2) 

85 

 
 
 
•  Proof of Union Status (PoUS)  

•  Centralised Clearance for Import (EU CCI)  

• 

Import of Cultural Goods (ICG)  

The fifth non-IT case study covered the LMS system. 

The purpose of these IT case studies was to examine how IT outputs in the programme 
were used by beneficiaries, the contribution of the programme support for the EES to the 
specific and general objectives of the programme. They were also aimed at developing an 
understanding of the IT systems’ effectiveness, efficiency and relevance and, ultimately, 
the extent to which the support from the Customs programme for each IT system 
provides EU added value. Following preparatory meetings with DG TAXUD, each case 
study featured a different set of stakeholders interviewed by the study team, as 
summarised in the table below. 

Table 15: IT case studies’ interviews 

Stakeholder type  

Scope  

Interviewees  

IT system: Import Control System (ICS2)  

DG TAXUD (preparatory 
meetings)  

Business managers, 
communication and coordinator, 
etc.  

7  

Member State authorities  

ES, FI, DE, IE, LV, SK, LT  

12 in 7 MSs  

Economic operators and 
associations  

Express carriers, IT service 
providers, postal operators, freight 
forwarders, 

19 in 12 
organisations  

IT system: Proof of Union Status (PoUS)  

business associations  

DG TAXUD (preparatory 
meetings)  

Member State authorities  

Economic operators and 
associations  

Business, Policy and IT Units  

3  

PL, ES, DE, BE, IE, FR, AU, EE, 
SK  

20 in 9 MSs1 

Shipping sector association, 
automotive sector association, 
business association, clothing and 
footwear company, logistics 
companies  

14 in 7 
organisations  

86 

 
  
IT system: EU Centralised Clearance for Import (EU CCI)  

DG TAXUD (preparatory 
meetings)  

Business, Policy and IT Units  

2  

Member State authorities  

LU, PL, HR, ES, BE, FI  

10 in 6 MSs  

Economic operators and 
associations  

Business association, automotive 
companies, express carrier 
company, IT service providers, 
logistics associations  

6 in 5 
organisations  

IT system: Import of Cultural Goods (ICG)  

DG TAXUD (preparatory 
meetings)  

Member State authorities  

BE, EL, IT, MT, NL  

52  

In addition to the interviews, email questionnaires were sent out to selected Member 
States for three IT case studies (ICS2, PoUS and CCI), with the aim of comparing the 
costs of the architecture of the systems with the projected costs under theoretical 
counterfactual scenarios. The table below provides an overview of the scope and the 
number of respondents for these targeted surveys. 

Table 16: IT case studies’ targeted surveys 

Stakeholder type   Scope  

Respondents  

IT system: ICS2  

Member State 
authorities  

IT system: PoUS  

ES, FI, IE, LT, LV, SK  

6  

Member State 
authorities  

AT, CY, CZ, DK, FR, HR, HU, LT, LV, 
LU, PL, RO  

12  

IT system: EU CCI 

Member State 
authorities  

AT, CZ, EE, ES, FI, LV, LT, PL, PT, RO, 
SK  

11  

The fifth case study provides an overview of the key features from the perspective of the 
EU Customs programme 2021-2027 of the Customs & Tax EU Learning Portal3, known 

87 

 
 
 
 
 
as the EU Learning Management System (LMS). The purpose was to assess the 
effectiveness, efficiency (cost-effectiveness), coherence and EU added value of the LMS. 
The focus is on the functionalities of the platform as it is new under this Customs 
programme, having been launched in May 2021. The content of the LMS, including the 
courses provided, is out of scope. The table below provides an overview of those 
interviewed as part of the LMS case study. 

Table 17: LMS case study interviews 

Stakeholder type  

Scope  

Interviewees  

Learning Management System (LMS)  

DG TAXUD (preparatory 
meetings)  

Officials in charge of the 
platform  

National customs authorities  

Estonia, Greece, Ireland, the 
Netherlands and Türkiye  

LMS external contractor  

3  

5  

1  

In addition to the interviews, there was a survey of LMS users, which was launched by 
the study team on 17 February 2025, and closed on 10 March 2025. It was a joint survey 
for this case study and the parallel case study for Fiscalis. Of the 62 respondents, 47 had 
an interest in customs, who were included in the analysis for this case study. Of those, 41 
(87%) were from national authorities 3 (6%) were part of other customs entities (e.g. Tax 
& Customs Academy), 2 (4%) belonged to companies, and the other 1 (2%) was from an 
academic/research institution. 

3.  Results of the consultation activities 

1.  EU-level interviews 

1.  To what extent has the programme been successful so far and why? 

Effectiveness 

DG TAXUD officials considered the expert teams funded by the Customs programme to 
be effective. They created a space for collaboration and networking, promoting 
knowledge, the sharing of best practices, and cooperation between the Commission and 
Member States in areas where many, especially smaller Member States, did not have 
technical expertise. 

88 

 
 
 
However, DG TAXUD officials had difficulties in getting Member States to take on roles 
as grant coordinators in collaborative activities, including in expert teams, which raised 
questions on their relevance and benefits. 

According to DG TAXUD officials, the first years of the current Customs programme 
faced conceptual challenges to the implementation of innovation. Internal discussions 
were effective in creating awareness of the need for more widespread use of innovation 
in the years ahead and the development of an assessment matrix to define the scope of 
innovation. However, there continued to be unresolved challenges and untapped 
opportunities in this area. 

Efficiency 

Completing the new annual MEF has proved less burdensome than its predecessor, with 
almost half the number of (sub)indicators collected. This efficiency improvement, which 
was designed to prevent double reporting, was acknowledged by DG TAXUD officials 
but they admitted there was still room for improvement. The MEF was still described as 
cumbersome, and it was necessary to adjust the number of indicators and reporting 
frequency. For instance, some indicators still appeared less valuable or were 
disproportionate to the budget they represented. 

Coherence 

According to EU-level stakeholders, the coherence of the Customs Programme was 
enhanced by wider visibility to both internal (DG TAXUD) and external stakeholders. In 
other words, the more policymakers were aware of the Customs programme and its 
functioning, the greater the coherence. The visibility – to internal and external 
stakeholders – of the Customs programme has been increased through specific, structured 
initiatives. Furthermore, EU officials deemed informal interaction crucial for raising 
visibility and thus coherence. 

EU officials believed that the Fiscalis Programme and the CCEI) were complementary to 
the Customs programme and that there were clear synergies between them. 

In terms of coherence with Fiscalis, respondents said that formal and informal 
mechanisms were in place to ensure the complementarities between the two programmes. 
For instance, programme coordinator network meetings were often organised jointly, and 
the customs and Fiscalis Chief Information Officer Network established links between 
customs and taxation IT managers.  

Where relevant, joint activities for expertise and knowledge sharing on taxes and customs 
had been implemented, but they were still listed as separate activities for administrative 
purposes. The respondents perceived this separation as the only (minor) administrative 
burden relating to complementarity between the Customs and Fiscalis programmes. 

For the CCEI, DG TAXUD officials believed that there were synergies with the Customs 
programme since their nature and rationale were complementary by design. The CCEI 

89 

 
provided financial support for procuring, maintaining and upgrading customs equipment, 
and for initial training.  

Expert groups under the Customs programme were able to share technical knowledge 
and best practices of such equipment. For instance, the CCEI coordination group was an 
expert group funded by the Customs programme, which assisted with the implementation 
of the CCEI and strengthened the relationship between the Member States. The Customs 
Eastern and South-Eastern Land Border Expert Team (CELBET) shared technical 
knowledge on customs equipment and on how the CCEI could help with capacity 
building. EU officials also believed bilateral study visits and e-learning modules funded 
by the Customs programme were particularly useful in helping spread best practices on 
the CCEI and Customs equipment in general. 

2.  Is the programme still relevant? 

DG TAXUD officials believed that one of the key strengths of the Customs programme 
was its flexibility, making it relevant to evolving needs and policy priorities. There was a 
strong belief among DG TAXUD officials that the programme had shown clear signs that 
it had made the necessary changes to support the implementation of the UCC, and this 
flexibility was perceived as an important feature for implementing the upcoming 
Customs Reform and for facing emerging challenges.  

The restrictive measures against Russia were among the most recent examples of ways in 
which the programme had responded to external challenges. With the support of the 
programme, detailed guidance was developed for each package of sanctions against 
Russia. 

2.  Online survey of national Customs authorities4 

1.  To what extent has the programme been successful and why? 

Effectiveness 

The national administrations found the Customs programme effective in achieving its 
general goals. All respondents agreed that it was crucial to the consistent and effective 
implementation of EU Customs Union and legislation. They also agreed that the funding 
for the common components of the EES enabled data-sharing cooperation and created 
economies of scale. All national administrations also believed that collaborative and 
training activities facilitated collaboration and trust-building among Member States: 24 
out of 30 strongly agreed that this was the case. 

According to respondents, interventions funded through the Customs programme had 
generally contributed positively to fostering collaboration and knowledge sharing across 
national customs authorities. All national customs authorities believed that the expert 
teams, the ECCG and other collaborative actions were useful, with the majority stating 
they were very useful (Expert teams: 18 out of 27 respondents, ECCG: 21 out of 27, 
Other collaborative activities: 21 out of 29). 

90 

 
According to the national customs administrations, the funding of the Customs 
programme boosted networking opportunities and opportunities to share best practices, as 
27 out of 29 considered that these would be affected ‘to a high extent or more’ if funding 
were reduced or eliminated. 

Furthermore, the respondents believed that funding the EES significantly benefited 
communication between countries. This was especially the case for communication 
between the EU Member States, with 23 out of the 24 respondents who provided an 
assessment believing that administrative cooperation and the exchange of information 
between Member States would be affected to a high extent (3) or more (20) if the 
Customs programme no longer supported the common components of the EES. This was 
also true for communication between the EU Member States and potential candidate 
countries (23 out of 25 respondents) and between the EU and third countries (16 out of 
21). 

Efficiency 

The national customs authorities rated the administrative burden of participating in an 
expert team or other collaborative action as low, the vast majority rating it as moderate or 
minor (BTI II: 11 out of 12, CELBET III: 10 out of 12, CLET III: 10 out of 12, ETCIT 
III: 15 out of 16).  

The burden for leading, however, was considered significantly higher, though still 
moderate and the administrative burden for CLET II and ETCIT II was deemed the 
highest. 

More than half of the respondents who led an expert team rated the burden in the highest 
two categories. In terms of participating in collaborative actions other than expert teams, 
the vast majority (27 out of 29) considered the administrative burden to be moderate (13) 
or minor (14).  

For leading those collaborative actions, the administrative burden was considered higher, 
with 15 out of 22 respondents rating it moderate. For the expert teams and the other 
collaborative actions, the main reason why a national administration did not take part or 
lead was insufficient human resources or time. Other significant reasons were 
administrative complexities and competing priorities within the national administration. 

Coherence 

Almost all national administrations believed that other EU programmes and instruments 
are primarily complementary to the Customs programme. This was particularly the case 
for the CCEI (28 of 30 respondents assessed it primary complements the Customs 
Programme), the Fiscalis programme (23) and the Anti-Fraud programme (20). 

2.  How has the programme made a difference and to whom? 

Cost of non-Europe 

91 

 
The funding under the Customs programme that covers the expenses of the national 
administrations participating in collaborative actions was also considered efficient. Even 
with a 25% reduction in the expenses covered, most respondents (12) indicated it would 
significantly reduce their participation. Ten respondents stated that it would lead to a 
minor reduction in their participation, and four stated that their participation would not be 
affected at all. For lower levels of funding, the participation of national administrations 
would further decrease, with a 50% reduction already resulting in five countries no 
longer participating in any action. 

3.  Is the programme still relevant? 

The national administrations indicated that the Customs programme was flexible, in view 
of evolving needs and changing customs policy priorities. All respondents strongly 
agreed (14) or tended to agree (16) that the programme successfully adapted to policy 
priorities. Additionally, all but two agreed that the programme was flexible, with eight 
strongly agreeing and 20 tending to agree. 

3.  Case Studies 

1.  To what extent has the programme been successful so far and why? 

Effectiveness 

IT case studies 

Feedback  from  national  customs  authorities  and  economic  operators,  gathered  from 
interviews and email questionnaires, highlighted the benefits of the Customs programme 
in developing common components of the EES. However, it also noted that some systems 
were still at the early stages of deployment, and their benefits had yet to materialise. 

Regarding the ISC2, consultations with industry and public authorities  revealed that the 
rollout of the system was ongoing. Release 3 and the deployment of Security and Safety 
Analytics  capabilities  remained  incomplete,  and  national  components  (i.e.  national 
presentation systems) had not yet been fully implemented, leading to residual issues that 
hindered the effective execution of tasks. Consequently, some benefits could not be fully 
realised.  

Nevertheless,  customs authorities believed that the foundation for these  benefits  was in 
place, suggesting it was only a matter of time before they came to fruition. Member State 
authorities reported that ICS2 had already provided advantages in detecting and seizing 
non-compliant goods or those posing security risks, with several Member States noting a 
significant increase in effectiveness, particularly in the case of postal consignments. 

Regarding the EU CCI, all stakeholders consulted in the case study agreed that the system 
had  the  potential  to  facilitate  trade  by  allowing  economic  operators  to  submit  import 
declarations at a single customs office while presenting goods for release at the point of 

92 

 
 
entry. In the email survey, 9 out of 11 authorities stated that without the EU CCI, legitimate 
traders  in  the  EU  would  face  significant  challenges,  including  higher  costs,  slower 
processes and reduced competitiveness.  

However, uncertainty remained, primarily due to the delayed deployment of the EU CCI. 
Economic  operators  indicated  that  the  system  would  not  be  effective  until  it  was  fully 
deployed  across  the  EU,  with  some  Member  States  potentially  needing  until  2026  to 
implement it, beyond the legal deadline of June 2025. Delays in certain Member States 
were viewed by authorities as the main long-term obstacle to the success of the EU CCI 
system, identified by 7 out of 11 authorities in the email questionnaire. 

Regarding  the  PoUS,  consultations  with  Member  States  highlighted  several  benefits, 
including the fact that different customs authorities could exchange data and risk analysis 
results  and  the  possibility  of  comparing  statistical  records  with  those  of  other  Member 
States. Another advantage of the PoUS was that a central system solution eliminated the 
risk  of  using  false  paper-based  T2L  documents  in  the  destination  country,  as  data  is 
simultaneously  accessible  in  the  country  of  departure  and  available  to  the  customs 
authorities of the Member States of submission. However, some economic operators and 
Member States consulted argued that effectiveness was hampered by the current lack of 
system-to-system functionality. 

The feedback on the development of the ICG was, on the whole, positive. The interface 
was  considered  user-friendly  for  economic  operators,  and  the  development  process 
proceeded without major issues or negative feedback. Stakeholders appreciated the smooth 
cooperation between DG TAXUD and DG SANTE, relying on the expertise of national 
stakeholders. The ICG system was completed on time, ahead of the 28 June 2025 deadline 
for export licences for cultural goods older than 250 years.  

On the downside, stakeholders expressed slight concern as to whether economic operators 
would be ready for the new system, fearing potential teething problems, especially if there 
was a last-minute rush to obtain an Economic Operator Registration and Identification. 

Across  the  case  studies,  Member  States  and  economic  operators  made  it  clear  that  the 
design and deployment of IT systems needed to be assessed within the broader context of 
the demands of the UCC, characterised by the simultaneous implementation or updating 
of several IT systems. This had resulted in competing priorities and overwhelming capacity 
issues for Member States amid heavily constrained resources. 

LMS case study 

The EU LMS is contributing to customs cooperation under the Customs programme and 
to  customs  ‘acting  as  one’,  i.e.  ensuring  that  customs  legislation  is  implemented  in  the 
same way by all Member States. By serving as a common training and knowledge-sharing 
platform, it is a more effective tool than the approaches taken previously. 

The  LMS  was  widely  regarded  as  an  effective  one-stop  shop  for  these  training 
opportunities; it had enhanced participation in DG TAXUD e-learning modules and, albeit 

93 

 
to a lesser extent, in CLEP training events. Moreover, LMS users mostly considered the 
portal to be effective in collaborative activities. It was also considered user-friendly, but 
there appeared to be issues around ease of navigation. In addition, the LMS appeared to 
complement and not to duplicate national training systems. 

Challenges that remain include i) a lack of monitoring tools for national contact points, ii) 
language  barriers,  iii)  administrative  complexities  in  organising  CLEP  events  and  iv) 
inefficient  elements  of  event  registration  processes  (lack  of  notifications).  There  also 
appears to be scope for raising the portal’s profile. More consistency in the reporting of 
data on learners would provide a more accurate picture of the extent to  which Member 
States are making full use of the portal. 

Very  large  numbers  of  customs  officials  are  taking  the  courses  offered  by  the  portal 
through one of the several channels available to them. However, integration with national 
learning management systems  could  be  made  more effective through greater use of the 
LTI, which ensures that learners take the most up-to-date version of the course 

Efficiency 

IT case studies 

Findings from ICS2 confirmed that although the system brought more financial costs than 
benefits  for  industry,  these  varied  considerably  depending  on  the  characteristics  of  the 
trader/firm. Crucially, from a trade perspective, the centralised model was unanimously 
considered more cost effective for industry given the single, shared trader interface.  

For Member States, the centralised system was more cost effective than the alternative, 
which would  be two to four times more  costly. Having  a centralised  ICS2 also  ensures 
efficient  use  of  computing  power,  storage  and  networking  resources,  thus  preventing 
duplication across Member States. Centralised investment in high-capacity infrastructure 
is a better way to ensure the long-term scalability and adoption of emerging technologies. 
Among  other  benefits,  such  investment  can  dynamically  allocate  resources  based  on 
demand,  thereby  preventing  under-utilisation  or  overload  in  individual  Member  States. 
Indeed,  Member  States  struggled  to  identify  clear  advantages  associated  with  the 
counterfactual scenario. 

One  aspect  of  the  current  ICS2  deemed  inefficient  was  that  the  EU  helpdesk  was  not 
directly  accessible  to  economic  operators.  National  helpdesks  ended  up  passing  on 
messages from economic operators to the EU helpdesk, which wasted time. Trade and IT 
service  providers  also  pointed  out  the  technical  complexities  of  ICS2,  which  increased 
costs that they sometimes found hard to understand. 

Findings from the PoUS case study confirmed the Member States’ view that a nationally 
developed system would lead to higher development, maintenance and infrastructure costs. 
They also believed that they would have to scale up their IT workforce. Given the limited 
internal  capabilities  and  the  technical  complexity  of  UCC  requirements,  the  overall 

94 

 
implementation timeline would be extended if the PoUS were developed at national level: 
5 out of 11 stated that a nationally developed PoUS would offer no tangible benefits. 

The second counterfactual scenario that was tested –adapting the NCTS to include PoUS 
functionalities – would also have been a more costly option. All (11 out of 11) expressed 
concerns  that  this  would  lead  to  higher  development  and  maintenance  costs.  Most 
respondents (7 out of 11) also  mentioned financial risks such as budget overruns.  Most 
Member States (6 out of 11) stated that enhancing the NCTS to integrate the PoUS would 
offer no tangible advantages. 

According to the Member States, the current PoUS had additional efficiency benefits, such 
as  the  capacity  to  pool  IT  personnel  and  storage  capacity  at  EU  level.  Feedback  from 
Member  States  and  economic  operators  suggested  that  greater  involvement  at  the 
development phase would have led to a more efficient outcome. For example, the costs 
arising from the lack of a system-to-system solution could have been prevented. 

The Member States considered that the overall costs of implementing the EU CCI system 
were lower than those that would arise in its absence. Economic operators, on the other 
hand, believed that the EU CCI could potentially reduce the costs of customs operations in 
the long term. However, these benefits are difficult to estimate at this stage. 

Some Member States expressed disagreement with the prevailing view that the 
implementation of EU CCI did not lead to unexpected costs or workload. Their concerns 
stemmed primarily from changes to EU-level technical specifications, especially the shift 
in project direction from EU CCI Phase 1 to Phase 2, which required additional work to 
analyse the integration of specifications with national systems and legal frameworks (e.g. 
VAT regulations). Another concern was the timing of the release of EU CCI 
specifications, which, in several cases, came after the start of the development of NIS. As 
such, certain Member States doubled their costs as they were developing two different 
systems, thereby reducing cost-effectiveness. 

There was general agreement that the ICG, both as a solution and during its development, 
was cost effective. The cost to Member States was minimal, especially financially, as 
only one national interviewee said they had spent too much time on development. A 
centrally developed EU system was more efficient than if each Member State would have 
to develop their own way of complying with the legal requirements. At EU level, 
significant cost savings had been made by combining the existing TRACES NT and EU 
CSW-CERTEX as the basis for the solution. 

LMS case study 

The LMS is a relatively inexpensive tool, though this does not necessarily mean that it is 
cost effective. However, there is evidence that its costs are lower than those charged by 
DIGIT for PICS, and costs are in line with projections in the business case.  

Increased participation in customs training activities, e.g. stakeholders reported greater 
involvement in e-learning courses and in CLEP events, is evidence that the objective of 

95 

 
reducing fragmentation had been achieved by streamlining courses under a single 
umbrella. However, it would appear that the optimal use of resources had yet to be 
achieved, as evidenced by i) the fact that some Member States were using a different 
training tool, ii) the low uptake of the LTI integration feature, iii) misalignment with 
national competency frameworks and iv) administrative challenges in organising CLEP 
activities. 

2.  How has the programme made a difference and to whom? 

EU added value 

IT case studies 

There was widespread agreement that without programme funding, ICS2 and the benefits 
it brings would not have been achievable within the same timeline and at the same cost. 
The technical capabilities of the ICS2 had, according to a number of Member States, led 
to more seizures. The evidence confirms that the centralised nature of the ICS2 makes it 
the  most  cost-effective  option.  There  were  real  downsides  to  centralisation  –  including 
reduced  flexibility  to  adapt  to  local  practices,  limited  governance  control  and  less 
autonomy over system maintenance – but they were outweighed by the benefits.  

While ICS2 generated more costs than benefits for economic operators, costs were lower 
than if the same system were fully developed at national level. In fact, the decentralisation 
of the day-to-day support  from  national  helpdesks  was  seen as  inefficient,  suggesting a 
further EU added value. 

The findings from the PoUS case study confirm its EU added value. In the absence of the 
PoUS, another IT system would have emerged, as it was a legal requirement to move away 
from  paper  documents  to  a  harmonised  electronic  system.  According  to  stakeholders, 
developing such a system at EU level ensured efficiency, cost reduction and streamlined 
implementation. 

The EU CCI case study underscored the potential significant added value of the EU CCI 
system  within  the  EU  customs  policy  framework.  The  EU  CCI  system  represented  a 
significant opportunity for advancing a more integrated and efficient customs framework 
for imports within the EU, clearly demonstrating substantial EU added value in terms of 
trade  facilitation.  The  EU  CCI  harmonised  customs  procedures  across  Member  States, 
which was essential for reducing administrative burdens and improving the efficiency of 
cross-border trade.  

However, while the EU  CCI system  presented clear opportunities, challenges remained 
regarding  the  varying  levels  of  readiness  among  Member  States,  insufficient  progress 
among  Member  States  in  the  CCI  authorisation  process  of  economic  operators  and  the 
uncertainty surrounding the timeline for full EU CCI system deployment. 

A centralised EU system enabled authorities to exchange information, have a centralised 
register  of  experts,  and  adopt  a  unified  approach  to  describing  a  cultural  good.  A  joint 

96 

 
approach leads to more comparable data, which enabled the Commission and the Member 
States  to  monitor  implementation  and  detect  patterns.  Had  there  not  been  a  centrally 
developed European electronic system, it is likely this would have resulted in a patchwork 
of unconnected national systems that would struggle to work together. 

LMS case study 

The case study findings were able to establish only indirectly that the LMS was ensuring 
that the implementation of customs legislation was uniform across the EU. Evidence of 
this includes: i) the high number of courses taken, ii) levels of satisfaction with the LMS, 
as measured by DG TAXUD via the TSG, iii) high scores in the LMS user survey for user-
friendliness  and  iv)  positive  assessments  of  the  features  of  the  LMS  in  surveys  and 
interviews. There was no indication that Member States would fill the gap if there were no 
LMS, and it is hard to see how they would do so cost effectively. 

Improvements are needed in some features and in data gathering, which can be seen as part 
of the normal process of evolution of a new tool. Further key improvements would be to 
identify ways to  encourage Member States to make more use of the LTI feature and to 
assess whether more translations are needed into Member State languages, which would 
support audience development. 

3.  Is the programme still relevant? 

IT case studies 

The findings for the ICS2 case study confirmed that increased geopolitical tensions, and 
the sanctions imposed on Russia and Belarus, reinforced the rationale and added value of 
ICS2. The system provided a stronger basis for risk analysis and met the Member States’ 
need for a viable system at the lowest possible cost.  

Economic operators and their associations also recognised that there was increased need 
for security and that this carries a business cost. They also expressed concern that the level 
of such investment was not fully understood and stressed the importance of ensuring that 
the users’ needs were met by services such as the helpdesk.  

The PoUS system was developed in response to a clear legal requirement to move from 
paper-based documents proving Union status to a harmonised electronic process. As such, 
PoUS remains relevant to the legal need established by the UCC. There was consensus 
among both Member States and economic operators that the adopted PoUS architecture 
was the most appropriate solution to these legal needs. However, there were variable levels 
of support among Member States and economic operators for the resulting set-up, with the 
current lack of a system-to-system functionality for traders. 

Case study findings  for  the  EU CCI provided  evidence of the  IT system’s relevance in 
terms  of  the  evolving  needs  of  national  customs  authorities  and  economic  operators.  It 
helped national authorities to achieve regulatory compliance and may in time contribute to 
economic operators’ needs. Interest in the EU CCI among economic operators was uneven 

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across the EU; it was considerably higher among major EU importers such as Belgium and 
Spain. 

The ICG was a legal requirement under Regulation 2019/880. Since this legislation entered 
into force, the need to combat the trafficking of cultural goods remains as strong as ever. 

LMS case study 

The fundamental need for a common learning infrastructure that drove the business case 
has  clearly  been  met.  In  terms  of  specifics,  the  LMS  also  scores  highly  for  relevance, 
especially  as  a  vital  training  tool  for  new  customs  officers.  Stakeholders  identified 
emerging needs for more experienced professionals requiring more in-depth knowledge, 
e.g. soft skills, digital competencies and supply-chain issues, which are not currently fully 
addressed. Such issues, however, were outside the scope of this case study. There was also 
a demand for new formats. 

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