Since 9/11 many changes have taken place in the world of trade.  There is a greater emphasis on supply chain security and compliance with customs law and practice.  Significant customs legislative changes have been introduced setting down new criteria and compliance standards for businesses trading internationally. 


In order to increase security in the international supply chain the USA and the World Customs Organisation (“WCO”) have introduced the Customs-Trade Partnership Against Terrorism (“C-TPAT”) and the Safe framework of standards respectively.  The introduction of AEO status is the ECs response to these measures.  The aim is to provide business involved in the supply chain with an internationally recognised quality mark which will indicate that their role in the international supply chain is secure and their customs controls and procedures are efficient and compliant.  Central to the new measures is the concept of AEO.

The AEO concept will allow Customs authorities in the EU to concentrate their resources on those economic operators not ready to meet minimum requirements and focus their attention on controls outside secure supply chains, i.e. on non-AEO traders.  It will not be mandatory to be approved but those not approved can expect their shipments to be delayed as they are all likely to be sent for detailed examination at each and every port through which they travel.  It is also suggested that carriers may refuse to carry goods for those not authorised.
AEO Forms



Application for AEO Certificate with Explanatory Notes Application for AEO Certificate
Self-Assessment Questionnaire Explanatory Notes for AEO Application
Explanatory Notes for Self-Assessment Questionnaire Self-Assessment Questionnaire
Explanatory Notes for Self-Assessment Questionnaire


Types of AEO Certificate

They are:

Safety and Security

Customs Simplifications

Customs Simplifications and Security and Safety.

Application for AEO status

Application must be made to your national customs administration, but when approved will have EU wide application. The system will be supported by an EU wide Customs database and each Member State administration will enter reports and monitor each AEO authorisation. It is intended that, prior to granting the authorisation, an audit will be carried out by customs to ensure compliance with the criteria. The audit may look back three years. Authorisations will be recognised for simplified customs procedures, security and safety purposes throughout the EU and by participating non-EU countries such as the US when mutual recognition is agreed. The date of introduction is 1 January 2008. We understand trader profiling will commence on 1 July 2009.

We would recommend to all traders that they prepare their systems to ensure full compliance with Customs Legislation and to be ready to secure AEO Status as soon as Customs Authorities inform trade through media releases when they will commence accepting applications.

Important Dates



 During 2007

AEO pilot projects taking place in EU Member States

1st January 2008 Legal start date for acceptance of AEO applications
12th March 2008 First AEOs due to be issued
1st July 2009 Customs profiling expected to start
31st December 2009 End of transitional period

Questions and Answers

The following questions and answers are set out to provide you with a summary of the key information available at this time. In addition, we have listed below what CEICL can do for you.

1. What is the legal basis for AEO?

The legal basis is contained in European Council Regulation 648/2005 and the implementing provisions are contained in European Commission Regulation 1875/2006.

2. What does European Council Regulation 648/2005 also introduce?

Entry and exit summary declarations;

A common EU Risk Management Framework; and

Exchange of electronic data between Member States.

The implementation date for the above is 1 July 2009.

3. Does everyone in a supply chain need an AEO?

A supply chain that includes parties that are not authorised as an AEO or parties that cannot guarantee secure safety standards will have a higher risk rating and therefore a higher possibility of customs intervention at the border than a supply chain where all parties are AEO certified.

4. When can you submit an application for AEO approval?

The legal start date for making applications for AEO is 1st January 2008. However, we understand that Irish Revenue is considering accepting applications from 1st November 2007. HMRC are currently accepting applications.

5. Who can apply for AEO approval?

Application for AEO is open to all economic operators established within the customs territory of the EU. An economic operator is defined as ‘a person who in the course of his business is involved in activities covered by customs legislation’. Application for AEO will be open to all those involved in activities in the global supply chain, i.e.: manufacturers, exporters, freight forwarders, warehouse-keepers, clearance agents, carriers and importers.

6. Where should companies submit their application?

The applications should be submitted to the authorities in the Member State where the applicant is established. The application only covers the legal entity of the applicant. There is no provision for a group of companies to hold a single authorisation. Although customs may accept a consolidated application for a group of companies, checks will be carried out to ensure that each legal entity meets the criteria for AEO. If approved, each legal entity will be issued with a separate AEO certificate. Multinational companies usually consist of a parent company and subsidiaries. If the subsidiaries are individual legal entities, AEO applications must be submitted by each of the subsidiaries wishing to get AEO approval.

7. What impact will the AEO have on businesses?

The AEO programme is a worldwide initiative to secure the ‘Global Supply Chain’ in accordance with criteria agreed at World Customs Organisation level. Negotiations are continuing at global level to agree mutual recognition;

As trade is vital to economic development, introduction of the AEO must not undermine legitimate trade flows and steps must be taken to facilitate legitimate trade in every way possible; and

While it is the intention that legitimate movement of goods by non-AEO’s should not be impacted, this cannot be guaranteed, particularly since profiles will be introduced with a particular focus towards trading by non-AEO’s

8. What are the benefits of AEO status?

It is the intention that AEO’s will be recognised worldwide as safe, secure and compliant business partners in international trade;

AEO’s should get a lower risk score in risk analysis systems through profiling resulting in fewer physical and document based controls;

AEO’s should get priority treatment if selected for control;

Possibility to request a specific place for any control procedures;

If physical controls are to be conducted AEO’s can expect priority treatment;

Mutual recognition of AEO programmes under Joint Customs Co-operation Agreements should result in faster clearance of their goods through third country customs;

Reduced data sets (information requirements) for entry and exit summary declarations – only required for AEO safety and security; and

AEO’s should expect to be in a stronger position to benefit from simplified procedures.

As a consequence of increasing their safety and security standards, traders should gain from indirect benefits such as:

Reduced theft and losses;

Fewer delayed shipments;

Improved planning;

Improved customer loyalty;

Improved employee commitment reduced security and safety incidents;

Reduced crime and vandalism;

Reduced problems through recognition of employees; and

Improved security and communication between supply chain partners.

9. How many data elements are in the reduced AEO data-set compared to the non-AEO (standard) data-set for summary declarations?

Entry into the Community Standard data set

Reduced data set for AEO’s



Exit from the Community Standard data set

Reduced data set for AEO’s



10. How long will administrations have to process applications?

Administrations will have 120 days from the date of receipt to process applications. However, during a transitional period of 24 months starting from 1 January 2008 the period for processing applications may be extended to 300 days.

11. How long will the authorisation be valid for?

There is no expiry date on authorisations. An AEO is legally obliged to inform the competent customs authority of significant events that could affect the authorisation. Authorisations will also be subject to review if any of the following occur:

Major changes to relevant Community legislation; and

Reasonable indication that the relevant conditions and criteria are no longer being met by the AEO.

12. Who will carry out the evaluation of applications?

It is intended that the evaluation of an application will be carried out by Revenue personnel.

13. What are the criteria to be satisfied by applicants applying for AEO status?

There are four basic requirements, which must be satisfied, and they are as follows:

An appropriate record of compliance with customs requirements;

A satisfactory system of managing commercial and, where appropriate, transport records which allows appropriate customs controls;

Proven financial solvency; and

Appropriate security and safety standards.

14. Is the AEO evaluation an audit?

The evaluation of the AEO application is not intended to constitute a regular customs audit. However, part of the evaluation process is conducted by audit.

15. How long will the evaluation process take?

This will vary depending on the size of the company and the type of business. The Revenue Commissioners are currently undertaking pilot exercises with a number of businesses and this may help to determine how long the process will take. AEO Pilot schemes in Ireland have shown that the auditing process may take up to 100 working hours. These hours are divided between in-office work and on-site visits. It is expected that the number of hours will decrease as experience increases. The number of hours required to carry out an AEO audit will vary according to a number of factors including:

The size and complexity of the business;

Advance preparation and records available;

Existing information and authorisations held by customs; and

The need, where necessary, to consult with other governmental authorities.

If your business makes appropriate preparations in advance it should ensure a smooth, speedy and efficient evaluation process.


– We will carry out an assessment of your operation(s) to identify any weaknesses which may impact the key criteria for obtaining AEO approval.

– We will provide advice and assistance to bring your operations and procedures into line with best practice and therefore ready to enter the AEO approval process.

– We will prepare and submit the necessary application(s) on your behalf.

– We will liaise with the customs authorities on your behalf while the approval process is under way.

– We will then provide ongoing support to ensure that your business maintains the criteria critical to protecting your AEO status.