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permissions and certificates or to be subjected to post-release domestic market control of their
products following entry into free circulation.
4.2.5.2. Lessons Learned
 Existing trade facilitation measures can be obstacles in the implementation to the AEO
programs as the participation becomes limited.
 AEO certificates given to limited type of operators creates loopholes in the supply
chain in terms of security and safety.
 Requirement of ISO 27001 in the application documents increases the cost of the
certificate significantly, thereby reducing the number of AEO holders. Many countries
control the IT security within the Customs without requiring external certificates.
4.2.5.3. Needs for Further Advancement
Government Perspective
 Due to the large volumes of data collected by the government from the AEOs, added
safety and security measures need to be taken by the government in order to protect
the rights of the AEOs.
 To satisfy the needs of the private sector and to adapt to new technologies the
government should revise the AEO legislation periodically through amendments to the
current regulations or through completely new ones.
 To communicate these legislative changes to the stakeholders in a timely and efficient
manner, addition of new financial and technological resources to the AEO program
must be found.
 A new genre of personnel who are well-versed in technology and law should be
employed.
 Dissemination of the data (when and if required) in a safe and secure environment
should be broadened to all the relevant public sector institutions.
Private Sector Perspective
 Expectations of private companies from the AEO program should be harmonized
through more efficient communication that dissipates to the grass-roots of the
relevant sectors.
 The perception that evaluation process is subject to the opinion of different experts in
the headquarters of Customs Administration should be eradicated through a strict
adhering to standards and better communication.
 The misunderstandings such as exemptions from submitting to Customs product-
specific documents such as licenses, permissions and certificates or being subject to
post-release domestic market control of their products following entry into free
circulation should be clarified.
 The current 6-month period for the AEO holders to adapt the new regulations may be
too short due to possible cost, time and capacity limitations. Therefore, this
requirement should be relaxed in a reasonable manner.