Annexes to COM(2022)635 - Final evaluation of the Customs 2020 programme

Please note

This page contains a limited version of this dossier in the EU Monitor.

dossier COM(2022)635 - Final evaluation of the Customs 2020 programme.
document COM(2022)635 EN
date November 18, 2022
agreements (bilateral or multilateral agreements where provisions are applied reciprocally), which would be significantly more difficult and costly to implement in practice and maintain. Given the scale of the Customs 2020 operations in terms of the sheer number of joint actions, versatility of topics, their European dimension or pan-European participation in actions and training, it is difficult to imagine that similar activities would have been organised at any other level. As regards the European Information Systems, if there was no future funding for their continuous development and maintenance, it would be difficult to continue to use them beyond the medium term. There would be a high risk of them becoming obsolete, and the economies of scale and reductions in overall costs would be lost.

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

7. Conclusions and lessons learned

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

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

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

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

-The evaluation provided evidence of differences in the application of customs controls, suggesting there was room to revise the risk management framework in place. In addition, several stakeholders referred to e-commerce fraud as an outstanding issue and some custom authorities consider that further programme support on the consequences of the UK’s withdrawal from the European Union is still needed. This is in line with the assessment provided in the European Court of auditors, Special Report Customs controls 13 and the 2022 Report by the Wise Persons Group (WPG) on challenges facing the Customs Union 14 . In this context, future programmes’ actions could be designed to help address such differences.

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

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

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

-The evaluation showed that the programme remains relevant to fund the development, implementation and operation of IT infrastructure and systems in the field as they are resource intensive and can benefit from economies of scale and scope. This is in line with recommendation 9 of the 2022 Report by the WPG to ‘Properly resource, skill and equip Customs to ensure their capacity to fulfil their missions.’

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

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


(1) Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code (OJ L 269, 10.10.2013, p. 1);
(2) Authorised Economic Operator system, European Binding Tariff Information-3 system and Information Sheets for Special Procedures
(3) i.e., TRAde Control and Expert System (TRACES) and ODS Licensing System
(4) COM (2020) 673 final
(5) The UCC was amended in 2019 to postpone the deadline for the deployment of three national systems to 2022 and of six trans-European systems to 2025. These include the system dealing with entry summary declarations, the system dealing with external and internal transit, the system dealing with goods taken out of the customs territory, the system concerning guarantees for potential or existing debts, the customs status of goods and the centralised clearance.
(6) European Court of Auditors, Special report – Customs controls: insufficient harmonisation hampers EU financial interests (04, 2021).
(7) See The European Interoperability Framework in detail | Joinup (europa.eu)
(8) Included in the Commission’s work programme 2022, pp 7 ( resource.html (europa.eu) )
(9) Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee “Taking the Customs Union to the Next Level: A Plan for Action”, COM(2020) 581 final.
(10) In the Action Plan, this area is referred to as “customs authorities acting as one”.
(11) An example of this is the Technical expert seminar (EU27) on the impact of withdrawal of the United Kingdom from the EU on Customs IT (CPG/054/047) held on 13 February 2019. This meeting was addressed to experts regularly attending the Electronic Customs Coordination Group (ECCG).
(12) Through the development of fast-track upskilling and on-boarding customs training programmes for direct use by national authorities.
(13) European Court of Auditors, Special report – Customs controls: insufficient harmonisation hampers EU financial interests (04, 2021).
(14) See TAX-20-002-Future customs-REPORT_BIS_v5 (WEB).pdf . The report states ’divergences remain between national Customs authorities in the application of rules and procedures and customs face growing difficulties to control borders’.
(15) See COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION INTERIM EVALUATION of the implementation of the Union Customs Code - Publications Office of the EU (europa.eu)
(16) Recommendation 2 is as follows: ‘Introduce a new approach to data, focussed on obtaining better quality data based on commercial sources, ensuring it is cross-validated along the chain, better shared among administrations, and better used for EU risk management. Clarify which private actors – including e-commerce platforms - must provide data, with costs for non-compliance. Provide businesses with a single data entry point for customs formalities and a single window/portal. Data to be stored and properly managed in a central data warehouse. The existing budget for 2021-2027 could be refocused for these goals.’