Current Legislation

Understanding the regulatory framework and technical infrastructure

EU Institutional Triangle

European Commission: EU's Executive Branch with monopoly on initiating legislation

European Parliament: 720 MEPs, directly elected, serving as co-legislator

Council of the EU: Gathering of Member States, co-legislating with Parliament

Ordinary Legislative Procedure

The reform follows standard EU legislative process with multiple input opportunities during EC preparatory work, proposal phase, and EP/Council work streams.

Member State Considerations

📊

Support for Customs Data Hub streamlining for AEOs

Several Member States favor leveraging the Customs Data Hub to simplify processes for Authorized Economic Operators (AEOs), reducing duplication and speeding up cross-border clearances.

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Concerns about complexity and timing of threshold changes

Some Member States worry that removing or changing thresholds could create implementation challenges and operational strain if done too quickly or without transitional measures.

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Advocacy for SME consideration and phased implementation approaches

Member States often ask for special treatment for SMEs — suggesting phased rollouts, thresholds for SMEs, or additional support to avoid disproportionate compliance costs.

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Emphasis on synchronizing EU IT projects with national systems

Coordination between EU-level IT initiatives and national IT systems is a priority to prevent integration problems and ensure data flows smoothly between platforms.

Customs IT Systems Deployment Status

System Overview

The Union Customs Code mandates 17 trans-European systems. Major deployments in 2025 include ICS2 Release 3 completion, AES extension, and NCTS Phase 6 preparation.

ICS2 Release 3 Status

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📌 Fully Operational: September 1, 2025

🚚 All transport modes (air, maritime, road, rail, inland waterway)
📝 Entry Summary Declarations (ENS) mandatory
⏳ Some Member States granted temporary derogations
📂 Multiple filing capabilities by end 2025
🔍 Enhanced pre-arrival risk assessment

NCTS Phase 5 & 6

⚙️

📌 Phase 5: Successfully deployed January 21, 2025

⏳ Phase 6: Deployment window March–September 2025

🔢 Four-level declaration structure (vs. two in Phase 4)
🔗 Combined transit and ENS declarations
📝 Enhanced Entry Summary Declaration alignment
✅ Optional implementation (opt-in approach)

Automated Export System (AES)

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⏳ Extended transition: Until December 14, 2025

🌍 22 Member States operational (as of January 2025)
🇦🇹 Austria latest deployment (January 26, 2025)
📦 Centralised clearance at export functionality
🔄 EMCS and NCTS interface harmonisation
📝 Pre-lodged declarations capability

Centralised Clearance Import (CCI)

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⏳ Phased Implementation: Ongoing development

⚙️ Phase 1: Core functionalities
📦 Phase 2: Full scope including simplified declarations
🛃 Temporary admission procedures integration
🍷 Excise goods and CAP measures coverage

Current Legislation

EU Institutional Triangle

Ordinary Legislative Procedure

Member State Considerations

Customs IT Systems Deployment Status

ICS2 Release 3 Status

NCTS Phase 5 & 6

Automated Export System (AES)

Centralised Clearance Import (CCI)

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