Having to do a PN would be a PITA, but the end result would still be a huge improvement
Intra-Schengen you can land anywhere but you need PN, it’s hard to argue PN is not required in France unless it’s permanent C+I like LeBourget or Orly, for anything else you may “get trapped” into this on Spain to France let alone Switzerland to France, although, going for small airfields you rarely get into any trouble as no one is around to care or notice…I would also distinguish based pilots & based aircraft from someone touring
My understanding in France, C+I don’t get flight plans they rely on OPS or PIC to send notifications and second, EU2020/877 concession did exist before in AIP but required PN (e.g. cli-lyon declaration forms for Switzerland)
You apparently haven‘t read (EU) 2020/877.
That’s right – not read all of it, word by word, deciphering the meaning etc, as well as running EuroGA 
But looking at this politically the rearguard actions which certain countries will implement are obvious.
I think for German Zoll, the dices are casted Switzerland to Garmany is fine (except places already with customs PN), I have not seen similar blanket approval letters from French douanes or Italian, seems more like getting one-off by PN on case by case basis
boscomantico wrote:
And even if they did… the most important thing is that ALL airfields are now available for flights between Switzerland and Schengen/EU countries (all of the surrounding ones!). Having to do a PN would be a PITA, but the end result would still be a huge improvement.
This seems to be the general interpretation, and has now apparently been confirmed by German customs. What is still missing is some real life experience confirming it. I guess some of us will need to just bite the bullet and put it to the test, for example with direct flights to clearly non-customs airfields in France and Italy (with a copy of the regulation at hand). 
Testing it with Germany is possibly already happening, but just under our radar here…. maybe those doing it don’t want to broadcast the fact.
BTW, I know people with aircraft based in France the regularly fly direct between grass strips in France/Germany, France/Czech Republic, France/Italy, France/Spain. Direct flights between airfields within both Schengen and customs union only need a flight plan.
Testing it with Germany is possibly already happening, but just under our radar here…. maybe those doing it don’t want to broadcast the fact.
I would estimate that it has been „tested“ (which is really the wroong word, as German customs have long ago confirmed that it is ok) in hundreds of cases. Especially by pilots based very close to the border. These will not necessarily be forum posters.
Peter wrote:
my estimate for the total cost of 2 officers to drive say 20 miles is £1k-2k.
That seems wildly overestimated. That would be the level of costs we create in my job when driving an intensive care patient with a mobile ICU for a hundred kilometers between two hospitals, with a crew of two qualified paramedics and one intensive care physician, including all equipment (respirator, EKG, infusion pumps, oxygen bottles, medication) etc.
I was taking into account the % of the establishment cost e.g. a building with 100 officers may cost 10M/year to run, so each of them costs 100k in that. And if they do 100 visits a year then each visit costs 1k.
Obviously this type of accounting is dodgy if the 100 officers and their building would not be eliminated if the visitation scheme had ceased. In practice they will not be made redundant; they will be redeployed.
But if looking at the overall picture of running some long term police operation, it is the right way to look at it IF you are having to suddenly recruit a load of officers and give them a new office to sit in.
Peter wrote:
I was taking into account the % of the establishment cost e.g. a building with 100 officers may cost 10M/year to run, so each of them costs 100k in that. And if they do 100 visits a year then each visit costs 1k.
Ok, that way it makes sense. I was only calculating the additional cost for pay, fuel and materials.
Hello EuroGA
This huge customs issue we have in general aviation: I want to do something about it, because authorities can and will only act if they receive feedback from their citizens. An EU petition might be the way.
Everyone here is probably aware of the new customs regulation that has been in force for some time now according to which: The sole act of the goods crossing the frontier of the customs territory of the Union […when nothing to declare…] is one of the acts deemed to be a customs declaration or a re-export declaration. Refer to (EU) 2015/2446, Art. 141(1)(d) as amended by (EU) 2020/877, here on EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02015R2446-20230314 or PDF here: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02015R2446-20230314&from=EN
However, Germany is the only country that publicly honored this legal change and said the quiet part out loud: Yes, this change has occurred, you may fly directly from say Switzerland to any no-customs-airfield in Germany and you crossing the border is all there is to it. For an actual quote, check out the official statement by the German customs: https://www.zoll.de/SharedDocs/Fachmeldungen/Aktuelle-Einzelmeldungen/2022/azr_vereinfachungen_zollanmeldung_befoerderungsmittel.html
All other countries kept quiet and pilots have to trust that their destination country’s customs officers are aware of the change. Spoiler: They are not and you’ll be greeted like
The practical issue: On my last longer trip, from Aix-les-Milles to Switzerland, I tried to escalate my request to depart without customs and finally get a clear answer. After my e-mails probably landed somewhere in Paris — I got multiple cc: notifications of my e-mail traveling from one customs office to the next — I finally got the official response that Switzerland is part of Schengen and therefore I may fly direct without customs, if I fill in some form (which also contradicts the law). This was especially grotesque, because Schengen has absolutely nothing to do with customs. This legal uncertainty is toxic to general aviation.
In a completely different endeavor I learned about EU petitions. EU petitions are often only signed by very few people or even just one person. It is IMO very easy to draw the attention of the EU to a topic if a petition is signed by just a few dozen persons as it will already stand out. It seems that the issue at hand is mostly about information distribution. If we could get the EU to remind its national authorities of the law and prompt them to issue public statements like the German customs did, this might be all we need to achieve legal certainty.
EU Petitions Web Portal: https://www.europarl.europa.eu/petitions/en/home
What would a petition even achieve? From their FAQ:
What action is taken in the case of admissible petitions?
If your petition fulfils the admissibility requirements, it will be declared admissible by the Committee on Petitions, which will then decide what type of action should be taken according to Article 227 of the Parliament’s Rules of Procedure.Depending on the circumstances, the Committee on Petitions may proceed in one or several of the following ways:
- ask the European Commission to conduct a preliminary investigation on your petition and provide information regarding compliance with relevant EU legislation;
- refer your petition to other European Parliament committees for information or further action (a committee might, for example, take account of a petition in its legislative activities) or to another EU institution, body or agency;
- ask the national authorities for information or clarifications in relation to the issues raised in your petition;
- in some exceptional cases, prepare and submit reports or resolutions to be voted on by the European Parliament in plenary, or conduct a fact-finding visit to the country or region concerned and issue a report containing its observations and recommendations;
- suggest an alternative means of redress, such as SOLVIT. When your rights as a citizen or as a business have been breached by public authorities in another Member State, the Committee on Petitions can recommend that you contact SOLVIT – an online service provided by the national administration in each EU country. The Committee on Petitions does not forward petitions directly to SOLVIT as it should be your choice whether or not to make use of this option; take any other action considered appropriate to try to resolve an issue or deliver a suitable response to your petition;
- place your petition on the Committee’s agenda and discuss it in a meeting to which you will be invited.
Whatever is decided, the Committee on Petitions will inform you as soon as possible in writing after the decision has been made.
Any person may sign a petition, but only EU residents or citizens may submit a petition. Unfortunately, I just ran into this problem and can’t submit it myself. If you are an EU resident or citizen and would like to help out, I would very much appreciate your help. Let’s draw it up and submit it together (or submit it via a GA association with its offices in an EU member state) — let me know in the thread or by private message and I’ll set up a chat, Discord or whatever is needed. Ideas and inputs are always welcome.
The practical issue: On my last longer trip, from Aix-les-Milles to Switzerland, I tried to escalate my request to depart without customs and finally get a clear answer. After my e-mails probably landed somewhere in Paris — I got multiple cc: notifications of my e-mail traveling from one customs office to the next — I finally got the official response that Switzerland is part of Schengen and therefore I may fly direct without customs, if I fill in some form (which also contradicts the law). This was especially grotesque, because Schengen has absolutely nothing to do with customs. This legal uncertainty is toxic to general aviation.
Customs do immigration in France and that is exactly what the law say: intra-Schengen flights are allowed from all French airports subject to “no marchandise” (Art9 of law 2017), PN is always obligatoire, it’s even mandatory and get checked in some big airports
French law already allow flights from Switzerland to any airfield subject to sending PN 24h in advance and flight plan and “nothing to declare”, this has been the case since 2017 well before EU 2020/877 AFAIK, the main problem is who are you are sending to? if no info is listed in AIP…
Germany allow flights from Switzerland to all German airfields now but I understand you still need to send notice and forms (correct me if I am wrong), anyway, I would be very careful in their big Type A & Type B airports with permanent or temporary Zoll around, I am sure they want notification for an arrival from Switzerland
