As 2025 marks the final rollout of the Union Customs Code Work Programme, European trade prepares for the culmination of a decade-long customs digitalisation project. CLECAT, the European Association of Freight Forwarders and Customs Agents reflects on the programme's state of play and the challenges that remain in its final year.
The Union Customs Code Work Programme (UCC WP) is a strategic initiative by the European Commission aimed at modernising and harmonising IT systems that enable traders to interact uniformly with customs authorities across all Member States (MSs).
The 17 key digital projects of the UCC Work Programme are divided into central systems (developed and operated by the EU Commission), decentralized trans-European systems (jointly developed and operated at EU and national levels), and national systems (developed and operated solely by Member States). These systems are being deployed over a now 10-year period, during which Member States directly coordinate trade onboarding. Originally established in April 2014, the UCC Work Programme has undergone several updates to reflect ongoing developments. The latest revision was adopted on 15 December 2023, mandating that all systems are fully operational by 31 December 2025.
The UCC systems are used by customs authorities, while traders develop their own IT systems to connect to these. Once a system becomes operational on the authorities’ side, trader onboarding begins, establishing links either directly with a central European, or a Member State Customs system.
Customs authorities control all goods entering, transiting, or leaving the EU using information submitted by traders through these connected systems. To ensure customs officers across all 27 Member States understand what is presented, trader systems convert commercial data, such as invoices, transport documents, and proofs of origin into a standard customs data-code format.
This is how the Customs Union, one of the EU's greatest economic achievements, ensures uniform cargo processing regardless of whether goods arrive through the Port of Antwerp or a Serbian land border. The same customs processes apply across all Member States whether handled by Belgian, Croatian, or any of the other 25 national customs authorities. The ultimate aim of the UCC Work Programme is to achieve full harmonisation, not only of customs processes but also of the IT systems employed by EU customs authorities.
Yes and no. While most systems have been successfully deployed, several Member States have already indicated they will miss the December 2025 deadline for certain systems.
Delays in achieving uniform implementation require traders to adjust their systems to each Member State's readiness, running legacy systems alongside new ones, adding layers of administrative and operational complexity.
Traders for example must ensure that cargo moving to, across, or out of the EU is supported by either paper-based documentation for the legacy systems, digital declarations for the new ones, or sometimes both, depending on the Member States’ readiness en-route. Similarly, all Member States authorities must remain able to handle both paper-based and digital forms of cargo data, and the Commission must maintain the connectivity between old and new systems with central components, until all Member States are ready to fully transition.
Most likely, outdated planning. Labelling it poor planning might be unfair, given that designing IT projects a decade in advance was already a formidable challenge in 2014 - especially since a 10-year rollout was never initially envisioned. A lack of financial and human resources both at Commission and Member State levels, combined with huge shifts in political priorities, new legal requirements, COVID and geopolitical events have also significantly affected the Programme’s progress.
From a trader’s perspective, the UCC Work Programme has brought significant work, investment, waiting, and, above all, constant adaptation. While there are undeniable advantages of customs digitalisation, these are increasingly overshadowed by ever newer challenges.
For businesses that depend on precise process planning, the situation can be frustratingly unpredictable. They grapple with regular system outages, unclear responsibility and support frameworks between centralised and national components, and inconsistent interpretations stemming from the lack of common guidance frameworks. Fragmentation of implementation is also worsening as Member States scramble to compensate for every faltering new launch with nationally tailored workarounds to maintain business continuity.
The prolonged and unexpectedly disjointed rollout of the UCC Work Programme has left traders frustrated, questioning whether its promise of harmonisation and efficiency will ever truly be realised, especially with the Commission already announcing significant cuts to their allocated budgets.
The verdict is still out on whether the UCC Work Programme is a success story, but one thing is clear: it must be completed, lessons must be learned and future progress must build on its foundations. As the largest undertaking of its kind by the European Commission, it represents a monumental development project and a unique coordinated effort on both the legislative and operational fronts. Despite all the difficulties, trade remains committed to supporting all further initiatives that aim to harmonise and streamline trade practices.
CLECAT brings together European logistics service providers, who today handle over 90% of the cargo entering or leaving the EU. These operators and their trading partners depend on a reliable and modern customs IT environment to operate effectively, while customs authorities rely on their ability to provide professional and accurate data on the goods they move.
With now over 300 different regulations being enforced by EU Customs, a competitive EU Customs IT system is essential to maintaining overall European competitiveness, product safety, security and environmental priorities. CLECAT argues that the completion, correction of the UCC Work Programme and the next development steps for EU Customs systems therefore must not be hindered by budgetary or HR constraints at either the EU or Member State level. On the contrary, this area should be a top priority for decision makers.
Meanwhile, trader systems are already far ahead of those used by authorities. While European legislators deliberate how to combat unsafe or undervalued goods entering the market, CLECAT members already use cutting-edge AI technology to filter and block such products. While lawmakers ponder how to improve border-crossing efficiency, European Logistics Service Providers employ advanced technologies to organise, move, and load goods at speeds and accuracy never seen before.
Looking forward and beyond the Work Programme, the EU must take a more collaborative approach, learning from trade and designing processes based on market practices - not the other way around. EU legislation must start reflecting real-world business operations more, rather than forcing European traders to adapt their processes to outdated, overregulated systems.
The longer the delay, the more outdated the entire Customs IT system structure becomes, and the current European legislative framework isn’t exactly designed for rapid change. When it comes to common customs IT systems, "firefighting" and "playing catch-up" are the best tools the European Commission has today, despite managing and maintaining one of the world's largest and most complex common IT networks and economic databases.
The UCC Work Programme is just one example where possible success is muted by slow (over)regulation, unclear competency boundaries, and a tiny, but unavoidable pinch of political infighting between Council and Commission.
We already see subtle hints that the newly mandated legislators are contemplating updating the EU Treaty. While the Draghi report admits that ‘Strengthening the EU requires Treaty changes’ it also says that this is ‘not a precondition for Europe to move forward: much can be done with targeted adjustments’.
With its complicated legislative processes, the EU risks remaining trapped in a reactive cycle, particularly in areas regulated at the EU level, such as Customs. CLECAT believes that the EU must equip itself to act with the decisiveness and agility of its global competitors, functioning as a cohesive entity. European traders can no longer afford to wait decades for regulatory frameworks that bolster their competitiveness. Whether this takes the form of a new EU-level Customs Authority or a treaty enhancing the Commission’s capacity for swifter decision-making remains to be determined – hopefully already in 2025.
This article was originally published by CLECAT.
