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As part of the Union Customs Code (UCC) Work Programme, Member States were required to progressively migrate their national export systems to the so-called EU Automated Export System (AES). The original deadlines marked the final major milestones of the UCC IT reform, replacing legacy national export and exit systems with harmonised EU-wide processes and data models. While the majority Member States completed their AES migration on time, some countries, most notably France, was granted a one-year postponement last year. French Customs has now completed its technical deployment and is formally moving to AES. However, a significant number of traders and logistics operators have not yet been able to fully adapt their own IT systems to lodge export declarations in AES due to the unavailability of specifications and shortage of testing as well as developer capacity on both sides.

To avoid disruption to export flows as the final deadline on 15 December approaches, French Customs has published a notice setting out temporary and transitional arrangements. These allow export operations to continue during a limited period, while ensuring that all movements remain fully electronic. Importantly, the solutions do not reintroduce any paper-based procedures and are designed so that neighbouring Member States that have already migrated to AES do not bear the operational consequences of the French transition delay.

The temporary measures mainly rely on structured combinations of export and transit procedures, ensuring continuous customs supervision of goods until exit from the EU customs territory. They are strictly time-limited and aim to give operators the necessary time and space to finalise their IT adaptations and connect to AES.

CLECAT, together with its French member TLF, is in close and continuous contact with both DG TAXUD and the French customs authorities. This coordination helps ensure that information flows smoothly between EU and national levels and that practical feedback from operators is taken into account. The shared objective is to secure a pragmatic and workable transition that preserves supply chain fluidity.

This is particularly critical for France, which is one of the most important export and exit gateways of the European Union. Ports such as Calais, Dunkirk, Marseilles, Le Havre and the Channel Tunnel handle a substantial share of EU trade flows, making a stable and well-managed transition to the final phase of the UCC Work Programme essential for the wider European logistics network.

CLECAT will continue to monitor developments closely and keep members informed as France progresses towards full AES implementation.