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Inertia of the organizational structure: Usually, in developing countries the existing risk
management units of the Customs Authority becomes responsible from the operation of the
AEO programs without any change in the organizational structure of the authority. This causes
the personnel in the risk management units to be distracted by the existing responsibilities in
addition to their new roles in AEO implementation. All of the three international best cases
introduce new units responsible from AEO implementation.
Inadequate staff: Implementation of an AEO program requires qualified staff. Moreover, as
program matures, due to the increase in the number of AEO holders, an additional need for
qualified staff working for the AEO programs arises, which is not usually the case in developing
countries.
Financial inadequacy of companies: Participating in the AEO program is costly for
companies. Therefore it may be difficult to increase the number of AEO holders due to the
insufficient number of firms that are capable of undertaking the costs of the program.
2.4 Requirements for a Successful AEO Outcome
Based on the discussion on global trends and the three best international practices, several
lessons can be withdrawn for a successful outcome during both the design and implementation
phases.
During the design phase:
1. Adopting an integrated approach:
Design of the AEO program should follow an integrated approach taking into account multiple
dimensions (legislative, organizational and operational). During the design phase, legislative
and regulatory reform is often needed, as well as possible organizational restructuring and
alignment with OGAs. In many countries, overlap is often present between Customs
Authorities and OGAs involved in border security and control of exports and imports.
Consultation and alignment with other governmental agencies during the design phase is
therefore crucial to avoid redundant and burdensome procedures in areas of overlap.
2. Involving the industry and private sector:
Including the private sector during the design phase is a must in order to avoid redundancy
and mismatch between stakeholders needs and the government that is in charge of developing
the AEO program.
3. Designing an attractive package where benefits to AEOs outnumber costs:
As concluded from the three case studies, benefits to authorized operators are numerous.
However, these benefits should be evaluated in relation to the costs borne by firms and traders
to obtain authorization. Such costs include application and procedure-related fees, but also the
costs of carrying out necessary changes in order to become eligible for authorization. The EU
case provides a good example for package design, where AEO guidelines are published and
updated by the Taxation and Customs Unit. The guidelines provide a clear demonstration of
benefits, procedures, legal texts and contact offices for agents wishing to obtain authorization.