It is not our habit to share an entire summary with our supporters, due to the often very technical approach of the topics. However, given the many changes coming our way in the coming years, the main points of this summit were hotter than ever. It has to be said that all member states are struggling with the many changes that need to be operational against very strict deadlines. It is not only the member states that have to be ready, all software suppliers also have to adapt their systems, but above all the entire trade has to make the transition to the new systems.
The source of all changes lies within the UCC (Union Customs Code). In order to meet the requirements of this UCC, a new data model - the so-called EUCDM (EU Customs Data Model) - has to be used as a basis for all customs procedures. Obviously, Stream Software is making every effort to comply with all new requirements, this within the set timeframes, for the three member states where we operate.
After a short introduction, we had the opportunity to follow a very interesting session with some TAXUD invitees, in panel discussion with Spanish customs as well as TARIC (one of our Spanish colleagues). The main topic was the laundry list of changes in almost all European (AES, NCTS, EMCS,...) as well as national (import, PNTS,...) systems.
Sophie De Coster opened the debate. Ms. De Coster is in charge of DG Taxud Unit B1 (Processes & Data, Customer Relationship & Planning). The legal context of the changes is discussed in detail. As reported earlier, the UCC is at the basis of all changes. The initial completion date for the national projects was December 2022. However, reality tells us that this was an unachievable map for each member state. TAXUD requested transparency from member states around the progress already made. Through so-called derogations, exceptional and individual postponements can be granted, if the case of the member states is conclusive. Very recently, the Netherlands requested a postponement regarding the roll-out of DMS. Through a derogation, the Netherlands has requested a postponement (new target is end 2023) for the implementation of DMS imports. Belgium also had to ask for a postponement for IDMS, the replacement for PLDA import.
There is also good news to report, of course. For example, Germany is now live with NCTS Phase 5 and AES. Spanish customs has also successfully completed AES and NCTS Phase 5, however, the session revealed that this has had an impact on the development of other systems. Spain has also requested a delay for certain procedures. There is also an additional risk associated with MS (Member States) not meeting the deadline, especially regarding European systems. If one MS fails to meet a target, it has an impact on connecting all the others.
Next speaker was Kanto Petri, responsible for T€S (Trans-European Systems, in particular AES & NCTS). Ms. Petri gave detailed input around the MS test results regarding NCTS and AES. Specifically for the countries in our market segment in September 2022, the Netherlands noted a success rate of 75% on the tests for AES, however they have not yet started for NCTS P5. Belgium noted a score of 50% on both systems. Finally, Luxembourg has not yet started on AES, yet they scored a very solid 73% for NCTS P5. Luxembourg should be operational for NCTS P5 in Q4 2022, and by mid-2023 the entire trade should have made the transition.
Of crucial importance to software vendors - besides the MIGs (Message Implementation Guides) - are the various test systems. Without a solid test system, it is extremely difficult to make progress in the development of a new module or application. We must conclude that many test systems - with respect to the planned target dates - are available late, and at times are of insufficient quality. Just testing a happy flow is not enough; everyone knows that within customs flows exceptions are at least as important.
Finally, the head of the IT department of the Spanish customs brought his experiences around the development of AES and NCTS P5. As stated earlier, they have been forerunners within the Union, and the systems are operational. The trade has been granted a transition period with a realistic deadline (+6 months) to get the systems connected compliantly. Spanish Customs works with an in-house development team. This allowed them to focus on getting the new procedures operational, but due to the limited size of the team, other developments had to be given a lower priority.
Day two featured a panel discussion on the long-term future of European Customs systems. The panel - in addition to moderator Maite Miret (ETN) - included Kris de Jongh (Head TAXUD Unit of Customs), Nerrea Rodriguez (ES Customs Director) and Vidar Gundersen (ex-Chief Customs Officer KGH, current Consultant at Maersk).
First topic touched upon was the Wise Persons Group report. This Wise Persons Group (WPG) was established in September 2021, to reflect on the future of the customs union, and propose guidelines that should be achieved in the medium and long term (2030/2040). The ten guidelines include the topics below:
1. Re-launch UCC
2. Data paradigm change.
3. Foster Authorities' Cooperation.
4. EU Customs Agency
5. System-based approach
6. Framework of responsibility & trust
7. eCommerce exemption thresholds
8. Green (skilled) Customs
9. Feed European Customs
10. Revenue gap report
If we may highlight one topic of the WPG, we take System-Based Approach (SBA), a systematics that Stream Software also strongly believes in. This is a new audit system whereby audits are based on systems, rather than transactional returns. The audit trail and control mechanisms already woven into our application could already provide a very strong basis for this.
Kris de Jongh elaborates further on the impact of ICS2. This is by far the largest project ever carried out at EU level, a real game changer for TAXUD. On day one of this summit, Jerome Loriq (Product Owner Champ) had already given an extensive presentation on their experiences within the development of ICS2. Champ specializes in air cargo, working for air carriers and ground handlers, among others. Despite their advanced developments, there were still quite a few uncertainties surrounding ICS2. Also at Stream Software it is not yet clear what role our customers (brokers and freight forwarders) will have to take within this new procedure. A new test system would be coming soon. One new, not unimportant detail we certainly don't want to keep from you. The specified deadline of 01/03/2023 (air freight) and 01/04/2024 (ocean freight) is this for the member states. There is a transition period of three months for carriers, six months for trade. ICS1 will remain available until everyone has switched to the new procedure.
EurTradeNet is the European alliance of customs related service providers or CRSPs. It is a unique knowledge network that pools local expertise in information processing services and communication solutions to ensure the most effective implementation of eCustoms across Europe.
We would also like to thank Maite Miret and her team for the flawless organization. Stream Software experienced the info sessions and panel discussions during the summit in Segovia as very interesting, especially in these turbulent times with numerous legal changes.