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Document 52015DC0064
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Final evaluation of the Customs 2013 programme
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Final evaluation of the Customs 2013 programme
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Final evaluation of the Customs 2013 programme
/* COM/2015/064 final */
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Final evaluation of the Customs 2013 programme /* COM/2015/064 final */
Table of Contents 1. Background. 3 2. The programme. 3 3. The set-up of the evaluation. 4 4. The European added value of the programme. 6 5. Effectiveness of Customs 2013. 8 5.1. Strengthening safety and
security. 9 5.2. Protection of the EU’s
financial interests. 10 5.3. Facilitation of trade. 10 6. Factors influencing the programme’s performance. 11 7. Programme dissemination (awareness, knowledge and implementation) 12 8. Efficiency. 13 8.1. Communication and
information-exchange systems. 13 8.2. Joint actions. 14 9. Conclusions and recommendations. 16 9.1. Conclusions. 16 9.2. Recommendations. 17
1.
Background
The Customs Union is a foundation of the European Union
and an essential element in the functioning of the internal market. The internal
market can only function properly when there is a common application of common
rules at its external borders. This implies that the 28 customs administrations
of the Union must act as though they were one. The Customs 2013 programme (henceforth referred to as:
Customs 2013) was established by Decision 624/2007/EC[1] as a
multiannual action programme for customs in the European Union to support and
complement action undertaken by Member States in ensuring the effective
functioning of the internal market in the customs field. It builds upon four
previous programmes: Matthaeus, Customs 2000, Customs 2002 and Customs 2007.
The programme was primarily aimed at providing support to and fostering
co-operation and co-ordination between the national customs administrations of
the Member States, who were also the main beneficiaries. In compliance with Article 22 (1) of the programme
Decision, a final evaluation was carried out under the responsibility of the
Commission concentrating on the effectiveness and efficiency of the activities
of the programme. The European Commission designed and contracted the final
evaluation of the programme to an external consultant. The evaluation study was
carried out by"The Evaluation Partnership", assisted in the process
by a Steering Group composed of relevant Commission staff and representatives
of 5 participating countries. The Steering Group supported the evaluation team
at all stages of the evaluation process. The evaluation started in September
2013 and was finalised in August 2014. The present report is based on the findings and
conclusions presented in the external evaluation report. The Commission
appreciates the overall quality of the external study supporting this
evaluation and acknowledges the methodological difficulties and efforts
undertaken to mitigate them. The findings are deemed credible and the
conclusions accurately drawn. This report issued by the European Commssion meets the
obligation mentioned in Article 22 (3) of the programme Decision to communicate
the results of the final evaluation to the European Parliament, the Council,
the European Economic and Social Committee, and the Committee of the Regions.
2.
The programme
Customs 2013 ran from the 1st of January 2008 until the 31st of
December 2013. Participation in the programme was open to the Member States,
the candidate countries benefiting from a pre-accession strategy, as well as
potential candidate and certain partner countries of the European Neighbourhood
Policy. In addition to the 28 EU Member States[2],
five other countries took part in the programme: Turkey, Serbia, the former
Yugoslav Republic of Macedonia, Montenegro and Albania. All the countries that
participated in the programme activities are referred to as “participating
countries” throughout the report. According to the programme Decision, the five overall objectives of
Customs 2013 were to: 1.
ensure that customs activities match the needs
of the internal market, including supply chain security and trade facilitation,
as well as support the strategy for growth and jobs; 2.
strive for increased interaction and performance
of the duties of Member States’ customs administrations as efficiently as
though they were one administration, ensuring controls with equivalent results
at every point of the Community customs territory and the support of legitimate
business activity; 3.
provide the necessary protection of the
financial interests of the Community; 4.
strengthen security and safety; 5.
prepare candidate and potential candidate
countries for accession, including by means of sharing of experience and
knowledge with the customs administrations of those countries. The overall financial envelope for the programme was set at
EUR 323.8 million. In order to achieve the programme’s
objectives, the following activities were carried out: ·
The development, maintenance and operation of communication
and information-exchange systems. Approximately 80% of the programme’s
budget was spent on IT systems and they underpinned the other activities
carried out within the framework of the programme. ·
Joint actions which
included seminars, workshops, project groups, steering groups, working visits,
training activities, monitoring actions, benchmarking and other actions that
allowed officials from the participating countries to work together on topics
of common interest. Collaboration between customs authorities took place on the secured
Common Communication Network/Common Systems Interface (CCN/CSI), which assured
the interoperability of all national information systems and acted as a secure
platform for customs authorities to communicate with one another and exchange
messages. There were about 60 information-sharing programs and trans-European
applications running on this secure platform. Some of the main IT programs and
applications supported by the programme which have been scrutinized during the
evaluation were: ·
the Export Control System (ECS) and the Import
Control System (ICS), ·
the New Computerised Transit System (NCTS), ·
the Information system on the integrated tariff
of the Community (TARIC) and the Tariff quotas and ceilings database (QUOTA), ·
the Economic Operators Registration and
Identification system (EORI) and the system for Authorised Economic Operators
(AEO), ·
the Customs Risk Management System (CRMS).
3.
The set-up of the evaluation
The focus of the evaluation was on the results and impact that the
programme had on the Customs Union and the customs administrations that took
part in the programme. About 80% of the programme budget was devoted to IT
systems and these were in large part responsible for the programme’s
contribution to higher-level policy objectives. Therefore, the evaluation was
specifically designed to look in more depth at the ways in which the IT systems
funded by Customs 2013 added value to the customs cooperation and thus
facilitated the achievement of the programme’s overall objectives. In order to gain an understanding of how the programme worked on the
ground, the main evaluation criteria and perspectives employed were: 1.
the European Added Value of Customs 2013 (see
heading 4); 2.
effectiveness - the
extent of the contribution of the pan-European electronic customs environment
towards helping the customs authorities to better
protect the EU’s financial interests, to strengthen safety and security for
citizens and to facilitate trade (see heading 5); 3.
the unexpected and unintended results and impacts
generated by the programme’s activities (see heading 6); 4.
the programme dissemination - awareness,
knowledge and implementation (see heading 7); 5.
efficiency of the programme (see heading 8). The external consultant employed a mix of techniques, combining the
standard programme assessment that had already been used for the 2011 mid-term
evaluation of the programme and the contribution analysis (see heading 5 for more details). The Commission considers that the data that was gathered for the
evaluation of the programme has been extensive and cross-checked in order to
obtain robust information and to be able to base the conclusions on sound
evidence, confirmed by several sources. The main sources of information used
for the evaluation included ·
desk research; ·
a questionnaire which gathered the views of
national customs administrations in all participating countries (one answer per
country which resulted in 33 responses); ·
a survey to customs officials which gathered
feedback from individual customs officials in the national
administrations. The survey addressed officials who had
participated directly in the programme as well as those that have not taken
part directly in the programme (overall, the survey resulted in 5 401
responses); ·
six case studies of EU
Member States conducted to test the theory of change of the programme. There were several constraints which had to be taken into
consideration when evaluating Customs 2013. Firstly, many of the programme’s
activities were continued from its predecessor, namely Customs 2007. Thus, the
results and impacts could only rarely be linked uniquely to the Customs 2013
programme. Secondly, the need to focus the evaluation on a limited number of
objectives and Member States, while allowing for a better understanding of the
programme’s effectiveness, the case studies results cannot be generalised in
statistically representative way . Thirdly, there was very little quantitative
data available to the evaluators in particular on the costs of developing IT
systems at national level or the reduction of administrative costs as there was
no monitoring framework to keep track of these indicators; therefore the
evaluators relied largely on the perceptions of the stakeholders consulted
(through the surveys, targeted interviews or the case studies). Even these
experts on the ground were often not unable to quantify the benefits or
advantages that they nevertheless felt to have occurred. Therefore, the
evaluation conclusions mostly rely on rich, qualitative evidence and only to a
smaller extent on quantitative data. The following chapters summarise the conclusions on each of the five
evaluation criteria and evaluation perspective.
4.
The European added value of the
programme
In the context of the final evaluation of Customs 2013, the European
added value was understood as the additional gains stemming from acting at the
EU-level as compared to national initiatives. This includes aspects of:
i.
complementarity of the programme to the national
initiatives;
ii.
reduction of administrative cost and burden
(e.g. through common IT platforms, guidelines, procedures; cross-implementation
of best practices identified in the course of the programme’s activities; reduction
of duplication and overlaps), or seen from another perspective: the cost of
‘non-Europe’; iii.
the trans-European nature of the customs
cooperation best addressed across, not within the Member States and the value
of human networks created through the programme; iv.
increased uniformity of the EU Customs Union
(‘acting as one administration’) and the value of a common administrative
culture;
v.
sustainability of results/impacts if the
programme was to be discontinued. The evaluation has identified a strong case for the European added
value of the programme, particularly regarding its role in supporting the
implementation of EU customs legislation at national level.
i.
At a general level, the national customs
officials found that the IT systems funded through the programme were highly
complementary to national initiatives as they were mostly related to
implementing the EU customs legislation. According to them, this led to
reductions in administrative costs, which would not have been possible if each
Member State had to develop similar IT systems on its own. For example,
centralised databases like TARIC and QUOTA provided Member State
administrations with important information they would otherwise have to request
in each case from the Commission and store at their own expense. However, the
stakeholders could not quantify the precise reduction of administrative costs.
ii.
A question regarding the reduction of
administrative costs was also put to customs authorities directly in the
evaluation questionnaire. Most responded that the programme helped to implement
EU legislation more quickly and at a lower cost than would been possible
without support from the programme. As shown in Figure 1 below, 23 out of 28 responding administrations
indicated that the programme helped them “to a large or some extent” to
implement such measures more quickly. Furthermore, 25 administrations
felt that the programme had helped “to a large or some extent” to implement the
necessary measures at a lower cost. Figure 1:
Extent to which Customs 2013 reduced administrative burdens for national
administrations Source: Questionnaire addressed to customs
administrations of EU
Member States (n = 28,
none of the respondents answered "not at all" )
iii.
The joint actions enabled direct collaboration
between officials from different countries. The evaluation found that they also
fostered trust and thereby encouraged the free sharing of information and
uptake of common IT systems and other processes. In this way, the evaluation
concluded that the created networks played an important role in attaining the
programme's objective to “act as one administration”.
Much of the harmonisation brought in by the
trans-European and centralised IT systems could only be achieved on the
condition that customs authorities shared information with other Member States
and/or recognised the validity of operations carried out by them. For instance,
risk-related information sent through the Import Control System would be of
little use unless the receiving authority placed credence to the analysis that
led to it. Similarly, recognising the Authorized Economic Operator status
awarded in another Member State implies relying on the fact that the respective
issuing authority applies community guidelines consistently.
The evaluation found that the level of trust required between Member State
authorities for such systems to be effective cannot be taken for granted, given
the variety of administrative cultures and working methods. Rather, this trust
needs to be earned, and the programme played an essential role in building it.
This was achieved partly through traditional networking effects, which allowed
customs officials to develop personal contacts and engage with each other on an
informal basis. Perhaps more importantly, trust was also built through repeated
meetings and exposure to each other’s working methods.
iv.
The evaluation found that there was still
considerable diversity in the execution of customs processes related to import
around the EU. One indicator that is useful in quantifying this diversity is
the time it takes to import goods. According to the Doing Business report of
the World Bank[3],
the time to import a standard container of goods can vary from 5 days to 19
days across the 28 members of the Union.
However, while this diversity still persists, the evaluators found that it was
significantly reduced during the programming period. This is an important
development, given that programme period of Customs 2013 is an intermediary
phase preceding the eventual introduction of centralised clearance. As the
objective of the Union Customs Code is to establish centralised clearance by
01.10.2020[4],
the progress accomplished by Customs 2013 so far is valuable in preparing the
ground for such an ambitious endeavour.
Without a forum for collaboration and sharing experiences, or a spending
programme like Customs 2013 able to fund common IT systems, the evaluation
concluded it was highly unlikely that Member States would align their
procedures and customs laws for acting in a similar fashion, and ultimately
performing as a single customs administration. Among other things, implementing
such legislation without a programme financing common IT systems or knowledge
sharing would require substantially higher costs. This would steam from the
fact that in the absence of common IT systems and technical specifications,
there would be a need to create 28 different versions of each specific system.
v.
Regarding sustainability of results in the
absence of further funding, the evaluation concluded that Member States would
find it difficult to continue to use the IT systems past the medium-term, given
the considerable running and maintenance costs the IT systems imply and the
substantial management function currently played by the European Commission.
While customs administrations felt that the results achieved so far would be
long lasting, tools produced through the programme, such as IT systems and
training modules, would become gradually obsolete without periodic renewal.
Similarly, without continuous interaction, the networks created through
continuous participation in the joint actions would begin to fade and their
results would gradually be lost. Staff turnover and administrative
reorganisations could have a similar effect on networks built through the years
of the programme. Thus, while the progress already achieved will continue to be
seen into the future, its reliance on future Commission support should not be
underestimated.
5.
Effectiveness of Customs 2013
In order to assess the programme’s effectiveness with regard to
reaching the overall objectives, the evaluation employed a methodological
approach called the contribution analysis. This analytical approach is
particularly suited for examining whether a programme or policy contributed to
achieving certain results and impacts. In order to have a balanced evaluation
that was both sufficiently broad but also went in the depth of the subject, the
contribution analysis focused on a selection of ·
policy objectives: out of the five overall
objectives mentioned by the Decision establishing Customs 2013, the following
three were selected: (1) protecting the financial
interests of the EU; (2) strengthening safety and security; (3) facilitating
trade; ·
customs processes: the
import of goods and related customs processes; ·
countries: six Member States out of the twenty
eight were selected. The criteria used for selection were the volume and nature
of customs traffic, types of customs controls employed, participation in the
programme and geographical diversity. The sample included Croatia, the Czech Republic, France, Germany, Hungary, and the
Netherlands. Below, the main evaluation finding and conclusions as related to the
contribution of the programme to the three selected policy objectives are
presented.
5.1.
Strengthening safety and security
The progress made under the programme towards this objective is the
most striking and can be regarded as an important step towards the eventual
harmonisation of risk management processes for customs, as prescribed by the
Union Customs Code[5].
Moreover, several of the key developments have taken place since the previous
evaluation. They related in large part to safety and security and stemmed from
initiatives taken to implement the Safety and Security Amendment[6] to the Community Customs
Code, whose full range of provisions did not come into force until 2011. The Import Control System was fully rolled out in 2011, requiring
economic operators to provide supplemental security information before goods
arrive in the European Union and facilitating the sharing of this information
between Member State administrations and the European Commission. The data
economic operators provide at this stage is fed into risk management processes
and thereby enhances risk analysis that national administrations perform at the
place where goods arrive as well as subsequent destinations. For instance, the
customs officials interviewed for the case studies indicated that the programme
facilitated the exchange of information with the other Member States, allowing
them to respond to risks quicker and more efficiently. In particular, the
exchange of information via the Import Control System helped national
authorities to exchange advance import information when goods were for example
re-routed. In the opinion of the customs officials, this has helped facilitate
trade, as economic operators did not have to submit information twice, while at
the same time ensuring the same level of security and safety. The Customs Risk Management System also became fully operational
during the lifetime of the programme. This system set a minimum standard for
risk analysis by institutionalising the sharing of risk information forms
between Member States and the taking into account by all Member States of
common priority control areas and common risk profiles in their national risk
management processes. As an illustration, some of the case study interviewees
praised the fact that the system provided a minimum level of risk analysis and
that the system stimulated the sharing of risk information between Member
States, via risk information forms. Officials felt that they had more access to
relevant risk information and were better able to warn other countries about
potential risks. Therefore, by raising the bar for risk controls and increasing
their consistency, the systems funded through the programme also increased
trust, helping the Member States to regard the risk analysis carried out by
others as credible and thereby targeting controls more effectively. The Economic Operator Systems were mainstreamed during this period,
increasing the ability of customs authorities to pool information about
individual economic operators and increasing the amount of information about
traders available for risk analysis. For example, the
case studies showed that the Economic Operators
Registration and Identification system made it much
easier for the customs authority to take the history of an economic operator
into account when conducting risk analysis, including its record in other
Member States. The Authorised Economic Operator system allowed the customs authorities to focus on riskier
companies, increasing the chance that controls, which necessarily are only
carried out on a small proportion of consignments, will uncover dangerous
goods.
5.2.
Protection of the EU’s financial interests
The correct calculation of tariffs and the fight against fraud are
crucial to the protection of the EU’s financial interests. The Information system on the integrated tariff of the Community
(TARIC) and the Tariff quotas and ceilings database (QUOTA) are the only
official sources for providing tariff-related information to national
authorities and the evaluation found them to be current, reliable and
user-friendly. More than two-thirds of the administrations indicated that the
applications contributed “to a large extent” to the specific objectives of the
information systems, namely those of helping traders and authorities to obtain
correct classification and tariff rate of imported goods (19 out of 27
administrations). The potential contribution of other IT systems to the protection of
the EU’s financial interest relates more to preventing and discovering fraud,
and is thus somewhat less straightforward and harder to pin down. For example,
the New Computerised Transit System (NCTS) was generally regarded to have
greatly reduced fraud by creating traceable records for each transit
transaction and reducing the scope for deviation from standard procedures. In addition, the enhanced effectiveness of risk management systems
has contributed not only to the enhanced control of dangerous goods, but also
to the effective identification and collection of customs duties. This has a
direct and positive impact on protecting the EU’s financial interests. For
instance, some of the interviewees from the case studies considered this system
as especially relevant given the role of their country as a transit country.
They explained that the system allowed the customs offices to electronically
register and exchange information with customs offices in other Member States,
thereby enhancing the reliability of information and significantly speeding up
the transit process. This allowed them to better monitor the movement of goods and thus to identify any cases of fraud or
non-payment of duties.
5.3.
Facilitation of trade
In the field of customs this objective is mainly pursued passively,
as improved risk management systems like those mentioned above are put in place
with as little an inhibiting effect on trade as possible. The entirely
paperless environment that now exists for handling customs declarations, in
addition to the mainstreaming and greatly increased uptake of the Authorised
Economic Operator system, has allowed the Customs Union to become more secure
while carrying out fewer of the manual controls that slow down the flow of
trade. Similarly, the New Computerised Transit System has helped do away with
paper-based transit declarations. This has speeded the transit process and
reduced the amount of time during which guarantees must be withheld from economic
operators and therefore facilitated trade, while creating electronic records that reduced the potential for
errors and fraud. The passage of Mutual Recognition Agreements with third countries,
off the back of meetings funded by the programme, has accelerated the growth of
the Authorised Economic Operator system further and thus also contributed to
this objective. That being said, it should also be pointed out that, in the
eyes of economic operators, besides the perceived positive impact on customs
processes, the scaling up of system has not brought unmitigated benefits. As
the Evaluation of the Customs Union found “although a majority of business stakeholders with AEO status
appreciate the extra services [easier access to customs
simplifications, priority treatment, fewer physical and
document based controls for those with AEO status], the benefits experienced
are perceived to be limited in practice” [7].
6.
Factors influencing the programme’s
performance
The evidence from the evaluation suggests that the programme has not
had negative unintended impacts on any of the stakeholders involved. This is
mainly due to the fact that the beneficiaries of the programme were clearly
defined and decisions were typically made in a consensual manner. However, the
evaluators identified a few influencing factors, outside the control of the
programme, which had an impact on the manner in which the programme was
implemented: ·
Costs incurred by national administrations:
While the specifications of trans-European IT systems were funded by the
programme, the actual implementation costs were borne by Member States.
Implementation costs resulted in particular from making national systems
compatible with the EU specifications. Interviewees in the case studies
indicated that these costs were often substantial and budget cuts at the
national level have led to concerns about the administrations’ ability to
implement changes to the systems within the agreed deadlines. This
differentiation between costs stems from the Decision itself [8], which established
which costs were to be borne by the European Union and which costs were to be
borne by the participating countries. ·
Complexity and diversity of national IT
infrastructures: The complexity of national IT infrastructures and the lack of
integration at national level of trans-European systems were also mentioned by
a number of interviewees as being an important barrier to the successful
implementation of IT systems. The ‘patchwork’ of IT systems led the adaption
and upgrading of systems to be a complicated and costly exercise in a number of
Member States. However, it should be noted that this did not detract from the
recognised benefits of implementing such systems. The evidence from the case
studies showed that once fully integrated in the national infrastructures, the
IT systems brought substantial improvements to the countries’ customs
processes. Thus, this influencing factor acted as both an inhibitor as well as
an activator for the programme, depending on the national context and resource
availability. ·
Historical and geographical context: The results
from the case studies revealed that there were substantial differences in the
nature and scale of the programme’s contributions to the overall objectives,
depending on the historical and geographical contexts of individual Member
States. Participating countries could be divided into two broad categories: (1)
those that had relatively small amounts of customs traffic and thus less
advanced customs IT infrastructures and (2) those that had significantly large
amounts of customs traffic and thus more advanced IT infrastructures. Due to
these historical and geographical differences, the first group of countries was
much more enthusiastic about the benefits of programme-funded IT systems than
the second group of countries, as in this way they could use and share the
lessons learned from the countries with more customs traffic. ·
Clarity of EU legislation: There had been
substantial delays with the implementation of the Import Control System in
particular, which were reported to be a consequence of the lack of clarity of
the legislative requirements on this system (e.g. in terms of the content and
timing of Entry Summary Declarations). It was felt that the legislators had
underestimated the practical implications and complexities of implementing the
system. Additionally, evidence suggested that EU legislation in relation to the
classification of goods was perceived to be inherently complex, which affected
the clarity and user-friendliness of systems like TARIC and the European
Binding Tariff Information system. ·
Legal channels for sharing information: There
was a general agreement that the programme-funded IT systems contributed to
enhanced cooperation between customs administrations. However, a number of
respondents explained that the sharing of risk information was sometimes
inhibited by the fact that national legislation prevented customs offices from
sharing sensitive information with other Member States, for example because of
on-going criminal investigations, thus preventing the IT systems from realising
their full potential. ·
Governance of joint actions: Despite the widely
praised usefulness of joint actions, the questionnaire and interviews revealed
some criticism in relation to the way in which the joint actions were governed.
For example, some national coordinators felt that there had been a
proliferation of joint actions over the last years, and some found it hard keep
an overview of all the relevant joint actions in place and to determine which
ones their officials should participate in. In order to overcome this issue,
some administrations suggested putting in place measures to determine the
utility of project groups before they are set up and to review them
periodically. ·
Language capacities of customs: A few
interviewees pointed to the language capacity of national customs officials as
a potential barrier to the successful implementation of the programme. For
example some case study interviewees mentioned that the varying levels of
language capabilities of national customs officials sometimes complicated
effective discussions during the meetings.
7.
Programme dissemination (awareness,
knowledge and implementation)
The evaluation looked at the dissemination and awareness of
information related to the programme in order to assess to what extent the
programme has been successfully promoted and its results were used by the
officials of the participating countries. However, it should be noted that
there is no direct causal relationship between awareness of the programme and
its overall effectiveness. For instance, customs officials may use programme
outputs, such as IT systems or guidelines, without necessarily knowing that
they were programme-funded. According to the evaluation findings, Customs 2013 was relatively
well known among customs officials: 52% of the surveyed officials knew of the
programme[9].
However, from those who were aware of the programme, the majority described
their knowledge as “very basic” or “basic” (77%). This suggests there is still
room for improvement with regard to explaining how the programme fits within
national administrations and how customs officials can make use of the
programme. The survey also revealed that 94% of participants of the programme’s
activities[10]
shared their experiences with colleagues within their administration in some
way or form. The awareness and understanding of multipliers (such as national
coordinators or customs officials who took part in joint actions) were found to
be crucial for mainstreaming the outputs of the programme and ensuring that
suitable officials participate in joint actions, while other officials can
benefit from the programme without necessarily having much knowledge of it.
Several interviewees in the case studies mentioned the importance of sharing
programme information with the right kind of people in the administration,
rather than as many people as possible, so that they in turn can decide on how
best to implement and use the outputs of the programme. There was a high level of agreement that the programme outputs (i.e.
IT systems and outputs of the joint actions) had a positive impact on the
functioning of national customs processes. The effect was most obvious in the
area of risk management, where a large number of administrations and individual
interviewees emphasised the important contributions of the programme. The IT
systems were mainly seen as beneficial for the facilitation of rapid and
systematic exchange of information between Member States. The joint actions
facilitated the exchange of experiences, expertise and best practices as well
as a common understanding and implementation of EU legislation, and in-depth
discussion of complicated topics. In addition to their concrete outputs, such as guidelines or
training programmes, joint actions were above all appreciated for their
contributions in establishing personal contacts and networks between Member
States’ officials, thereby helping them contact their counterparts more quickly
and to cooperate more efficiently.
8.
Efficiency
According to Decision 624/2007/EC, the financial envelope for the
six-year period covered by
the programme was set at EUR 323.8 million. However,
examination of the budget commitments showed that the real cost of the
programme was about 15% lower, amounting to about EUR 272 million. Out of
this, the IT systems accounted for EUR 225 million and the remaining
EUR 47 million was dedicated to joint actions.
8.1. Communication
and information-exchange systems
Expenditure allocated to the IT systems can be further broken down
in terms of development costs for new systems (which include major upgrades),
support and maintenance, the Common Communication Network/Common Systems
Interface and quality and methodology[11].
Figure 2 below shows that while expenditure on each of these aspects has
varied, overall spending has gone up consistently in the years since the
programme’s inception. Also noteworthy is that development costs peaked in 2010
(among other things, in the run-up to the full rollout of Import Control
System), while support costs were highest during last two years of the
programme (when most of the systems stemming from the Safety and Security
Amendment were already in place). Figure
2: Budget allocation to IT systems, 2008-2013 Source: DG TAXUD
data
8.2. Joint
actions
The joint actions, which accounted for about 20% of the programme
budget, complemented the IT systems and were of crucial importance to the
effectiveness and efficiency of the programme, as reported above. During the six years of the programme, about 7 500 activities were
organized across the eight types of joint actions which brought together
40 000 officials[12]
(see Figure 3). Figure 3:
Participation in the joint actions Joint action type || Participants || Actions || Meetings || Participants per action || Participants per meeting || Cost per meeting Benchmarking || 330 || 10 || 40 || 33 || 8 || € 6 512 Monitoring || 512 || 8 || 150 || 64 || 3 || € 2 795 Seminars || 2 570 || 38 || 75 || 68 || 34 || € 42 696 IT training || 2 875 || 8 || 346 || 359 || 8 || € 6 933 Workshops || 3 651 || 62 || 134 || 59 || 27 || € 25 118 Working visits || 5 223 || N/A || 5 211 || N/A || 1 || € 1 031 Steering groups || 10 567 || 7 || 275 || 1 510 || 38 || € 26 711 Project groups || 14 259 || 182 || 1 309 || 78 || 11 || € 9 505 Total || 39 987 || 315 || 7 540 || 310 (average) || 16 (average) || € 15 163 (average) Source: DG TAXUD
data The vast majority of spending from the programme budget related to
travel, accommodation and subsistence for participants to meet each other in
Brussels or another location. The average cost per participant stood at EUR 900. Out of
the eight types of joint action, the cost per participant for six of them
varied by less than 15% from this average. The two outliers were the steering
groups with an average cost of EUR 695 per
participant and the seminars with an average cost of EUR 1 246 per
participant. The cost differences are likely explained by the nature of the
joint actions in question. Steering groups usually took place in Brussels over
1-2 days and brought together the same officials on a regular basis. Seminars
were one-off events, usually hosted in a specific location by the customs
administration of a particular country, where factors other than cost and ease
of access were also considered and where activities to ensure networking among
participants was given higher priority. The joint actions provided administrations with a flexible set of
tools for bringing officials together. For example, sometimes, the meetings
lead to concrete outputs, such as a set of guidelines for operating a
particular IT system or common training programme. Other times, the immediate
results were less tangible, and consisted, for instance, of officials from one
Member State learning about how their counterparts in another country dealt
with a specific type of process or problem. It would be hard to imagine the development of mutually acceptable
common IT system, for example, if that development occurred in a top-down
fashion rather than under the auspices of a project group set up to bring the
relevant officials together. Within such a project group, officials could work
together to ensure their respective concerns and ideas were taken into account,
and that the final product was likely to fit within existing national
institutions. The Electronic Customs Group, while not oriented expressly
towards the development of a single product or IT system, deserves special
mention for having ensured that the opinions of all administrations were taken
into account in IT planning, that implementation issues were discussed
communally and that mutual solutions were found. This project group also helped
establish smaller offshoots for the development of new IT projects. The interviewees from the case studies repeatedly emphasised that,
without these joint actions and the fact that they enabled direct, face to face
contact and discussions between representatives of national customs
administrations, various problems and uncertainties would have been very
difficult to tackle and overcome.
9.
Conclusions and recommendations
9.1.
Conclusions
The Commission accepted the conclusions reached by the external
consultant, albeit with some reservations concerning the absence of quantitative
data to support the conclusions and the unmeasured and general nature of the
conclusions reached on the effectiveness and efficiency of the project. The
work carried out by the evaluation team was assessed to be in accordance with
the evaluation standards of the Commission[13].
The judgements and conclusions were derived directly from findings based on the
evidence collected. To ensure robustness of findings, the evaluation used
several data collection methods, including surveys, interviews, desk research
(including existing analyses and monitoring data) and case studies, although
monitoring data was very limited due to inadequate monitoring arrangements.
This methodological mix was on overall considered by the Commission and
stakeholders as sufficient. The main conclusions of the evaluation as drawn up
by the external consultant, with which the Commission agrees, are summed up
below. The evaluation concluded that even though many factors are at play
in the functioning of the Customs Union, the Customs 2013 programme made a
significant contribution towards enhanced safety and security, the protection
of the EU’s financial interest and the facilitation of trade. The EU’s exclusive competence for customs means that customs
legislation emanates from the European level and calls for the harmonisation of
customs policies and procedures. Feedback collected for the evaluation from
stakeholders has clarified the essential role of Customs 2013 in this. In other
words, the correct application of EU customs tariffs and more generally customs
legislation would not have been possible without the programme, and the mix of
actions has contributed to this. The trans-European systems allowed for burden sharing between the
European Union and participating countries. Further harmonisation of customs IT
might reduce duplication of efforts and thereby improve cost-effectiveness in
the future, but in the short-term there remains considerable room for improving
the interoperability between existing national systems and those funded through
the programme. Moreover, the enhanced effectiveness of risk management systems
has contributed not only to the enhanced control of dangerous goods, but also
to the effective identification and collection of customs duties. This had a
direct and positive impact on protecting the EU’s financial interests. The
entirely paperless environment that now exists for handling customs
declarations has allowed the Customs Union to become more secure while carrying
out fewer of the manual controls that slow down the flow of trade. In addition to the IT systems, the networking fostered through the
joint actions was also considered crucial for several reasons, including
ensuring the consistent application of customs legislation, spreading best
practices and building the trust needed for administrations to act is if they
were one administration.
9.2.
Recommendations
On the basis of gathered evidence, the evaluators put
forward several recommendations with the view to improving the programme’s
operations. The recommendations are summarised in Figure 4 below and were
broadly accepted by the Commission. The Commission will undertake a dedicated
exercise to address the recommendations and draw up an action plan for their
implementation and follow-up, taking into consideration their character,
influence on the programme and possible timeline for their implementation (e.g.
during the life of the programme or in the forthcoming legislative cycle). The
operational findings, such as improvements to the IT systems and applications
or broader dissemination of the programme’s results, will be directly addressed
in the course of the current programme Customs 2020. Others relating to
enhancing the integration of EU and national IT systems will support future
discussions on the scope and design of the post-2020 iteration of the
programme. Figure
4: Recommendations Nr. || Recommendation || Main responsible 1 || Develop specific and measurable goals that can be achieved during the life of the programme. They should include the provisions of the Union Customs Code (to be implemented during the life of the Customs 2020 programme) in addition to the programme’s existing specific objectives. || European Commission 2 || Develop a comprehensive monitoring framework to track performance and to identify issues of concern in a timely manner. || European Commission with strong cooperation from all participating countries 3 || Streamline the platforms used for sharing documents and facilitating communication between the Commission and Member States. || European Commission 4 || Take an active approach toward the achievement of policies aimed at centralised customs clearance. From the Commission side, this could include the identification of roles and responsibilities for the actors involved and efforts to ascertain the likely costs and benefits for the Member States, European Commission and traders. || European Commission in conjunction with Member States and potentially other actors 5 || Ensure joint actions are flexible and adaptable as well as more goal-oriented and accountable. || European Commission 6 || Develop a more systematic mechanism to review longstanding joint actions periodically. || European Commission 7 || Communicate more with national administrations on the outcomes of joint actions. || European Commission in cooperation with the owners of joint actions 8 || Address technical issues and user problems of specific IT systems that inhibit their contribution to key customs processes. || European Commission 9 || Enhance the integration of EU and national IT systems || European Commission in cooperation with Member States 10 || Use potential efficiency gains to make the case for further harmonisation and integration of IT systems. The various costs and benefits of centralised IT systems at EU and national levels should be examined in greater depth. || European Commission [1] Decision No 624/2007/EC of the European Parliament and
of the Council of 23 May 2007 establishing an action programme for customs in
the Community (Customs 2013) [2] Croatia joined the European Union on the 1st
of July 2013. For the purpose of the programme’s evaluation, Croatia was
included in the Member State category, but the fact that Croatia was still a
candidate country for a big part of the programme's lifetime was considered
during the analysis. [3]
Doing Business 2013
– Regional Profile European Union (EU) - The International Bank for
Reconstruction and Development / The World Bank; report accessible on http://www.doingbusiness.org [4] Art. 6(1), 16 and 179 of
Regulation (EU) No 952/2013 laying down the Union Customs Code and Commission
Implementing Decision of 29 April 2014 establishing the Work Programme for the
Union Customs Code (2014/255/EU) [5]
The Union Customs Code entered into force on
30.10.2013 and repealed the Regulation (EC) No 450/2008 of the European
Parliament and of the Council of 23 April 2008 laying down the Community
Customs Code. Its substantive provisions will apply only from the 1st of May 2016. [6]
The Safety and
Security Amendment covered four major changes to the Customs Code embodied by
Commission Regulation (EC) No 1875/2006, Commission Regulation (EC) No
312/2009, Commission Regulation (EC) No 414/2009 and Commission Regulation
(EU) No 430/2010 [7] Evaluation carried out by PwC for DG TAXUD:
"Study on the Evaluation of the State of the Customs Union", page 10. [8] Article 17 of Decision No 624/2007/EC of the European Parliament and of the Council of
23 May 2007 establishing an action programme for customs in the Community
(Customs 2013) 7 NB: in total there were
4 861 responses to this question in the survey addressed to customs
officials. [10] NB: in total there were
2 552 responses to this question in the survey addressed to customs
officials. [11] Quality and methodology refers
to quality assurance performed on the systems by external contractors. [12] It should be noted that one official could participate
in several meetings over the life of the programme, thus the number does not
refer to unique participants. [13] http://ec.europa.eu/smart-regulation/evaluation/docs/standards_c_2002_5267_final_en.pdf