01 October 2021


On 30 September, CLECAT attended the 59th plenary meeting of the Trade Contact Group (TCG), organised by the European Commission’s DG TAXUD. The TCG provides a platform for consultation by the EU Commission with representatives from the private sector on developments in customs and trade which have a direct impact on international logistical processes. The meeting was dedicated to hearing from TCG members about their key messages for consideration in the context of the ongoing evaluation of the implementation of the UCC and possible future revision.

With regards to the implementation of the UCC, CLECAT stressed that a key challenge remained the lack of proper and harmonised implementation of the legal framework across the EU. CLECAT mentioned that this is especially the case for some of the major simplifications provided by the UCC, where some countries are unable or reluctant to deliver implement as originally intended. While the efforts of the Commission to provide additional guidance to Member States on various aspects of the legislation were greatly appreciated, CLECAT noted that there were still instances where Member States’ approaches diverged but guidance on implementation was missing. A particular example was the new definition of exporter, where more clarification was still needed, including official replies from the Commission to CLECAT’s questions.

CLECAT also expressed concerns over the IT planning of Member States, as several Member States have delayed their implementation to the very end of the deadlines. That would leave very limited time for the private sector to implement and adapt to the new IT systems and will greatly influence operations in trade and transport. In this respect, CLECAT noted that related operational impacts were not always duly considered by national administrations and further stressed the need for more realistic planning that provides certainty and predictability for trade, as well enough time for testing and deployment.

The meeting also held an extensive discussion regarding the management of the Authorised Economic Operator (AEO) status across the EU. CLECAT expressed concerns over the diverging implementation, both in terms of requirements and benefits awarded to AEOs, and the existing tilted balance in favour of the former. Many TCG members, including CLECAT, shared negative experiences related to the high costs for becoming and maintaining the AEO status which do not always match the practical benefits granted to compliant businesses. The meeting highlighted the importance of balancing the requirements for AEO with tangible and real benefits, in order to keep the programme relevant and attractive. The Commission welcomed the feedback from TCG members and invited them to share concrete proposals for desired improvements of the AEO programme.

Additionally, the TCG meeting further highlighted the need for innovative mechanism that help the legislation to more quickly and adequately respond to future developments and emergencies like the COVID-19 pandemic, as well as the increased role of non-customs tasks, such as product safety, IPR, environmental protection, that needs to be appropriately reflected in the UCC framework.