Experts call for live trials of EU EES ahead of November launch

Industry experts used the two-day Seatrade Cruise Med conference in Malaga last week to call for cruise lines and ports to get prepared, especially through live trials and a close liaison with local stakeholders.

Field tests conducted by Copenhagen Malmo Port (CMP) and TUI Cruises, among others,  inspire hope that the integration of EES can run smoothly if preparations are made.

A test run at Copenhagen illustrated existing infrastructure will mostly be sufficient without the need for extra space in terminal buildings.

However there are concerns about major differences between EU member states in their approach to implementation approaches of EES

While for example Denmark, Germany and Spain appear to be taking a pragmatic stance, cruise industry representatives present in Malaga last week voiced concern about a rather different approach apparently chosen by Portugal.

EES from November, ETIAS due to follow next year

The Entry/Exit System (EES) is an automated IT system for registering non-EU nationals travelling for a short stay (with a 'short stay' meaning up to 90 days within any 180-day period), each time they cross the external borders of any of the European countries using the system.

According to a self-description provided by the European Union, EES will electronically register the time and place of entry and exit of third-country (non-EU) nationals, and calculate the duration of their authorised stay.

It will replace the obligation to stamp the passports of third-country nationals which is applicable to all Member States. The system has been designed to enhance border security and monitor overstayers across Europe, whilst preserving the openness and mobility that defines the region.

It will apply to all non-EU nationals, regardless of whether they require a visa for short stays in Europe or not - though with certain exceptions, in particular for civilian air and sea crew members in the performance of their duties.

Closely linked to the EES is the European Travel Information and Authorization System (ETIAS), a visa waiver program for non-EU citizens entering the Schengen Area. While the EES will be applied as from this November (though with certain opportunities for member states to delay this date up to a maximum of six months), ETIAS is expected to come into force during the first half of 2025.

Both of the new systems will impact most non-EU citizens travelling to the EU for short stays, including British nationals. There has been much debate in recent months as to the impacts on cruise travel. Meanwhile it is clear that EES will be applied whenever a ship conducts its last call within the Schengen area before leaving it - and, in the opposite direction, upon the first call within the Schengen region. Cruise itineraries starting and ending at a Schengen port and exclusively calling Schengen ports underway will not be affected.

 Lessons learnt from live trials at Copenhagen…

A conference session dedicated to EES and led by Luis de Carvalho, commercial director of Copenhagen Malmo Port (CMP) during Seatrade Cruise Med highlighted experiences related to EES so far and shared important lessons for the cruise industry.

de Carvalho outlined, CMP has done extensive preparation work already, among others through the analysis of 304 itineraries visiting Copenhagen. Together with Rigspolitiet (the Danish Immigration) the relevance of EES for these exemplary itineraries was investigated.

In a second step, a suitable layout / traffic pattern in the existing terminals was defined for both disembarking and embarking passengers, and this layout was tested in live trials. During these trials Rigspolitiet conducted tests of so-called 'Smart Suitcases' which it has developed for inspections. The suitcases contain all necessary equipment for EES inspections which are used by the Border Police officers, no extra control booths or control cabins needed to be set up, and the existing terminal space (albeit with a slightly alternated layout to guide passengers through) turned out to be sufficient.

It also turned out that the inspection time per passenger needed by the Border Police was rather limited and much below the two minutes initially feared. de Carvalho outlined the very positive results of the tests conducted and the great benefit of a close liaison established with the Danish Border Police - which has itself been preparing for the start of EES since 2018.

… and at Kiel

Also the German Port of Kiel has seen an EES field test conducted, in this case at the initiative of TUI Cruises involving Mein Schiff 1. Christina Hübscher, port & ground operations project manager at TUI Cruises, outlined, a dedicated call saw the complete inspection of all non-German nationalities simulated - approximately 200 passengers each upon disembarkation and embarkation.

As in Copenhagen, the test run went well, though with several important lessons learned. In particular, it turned out good signage is of utmost importance to separate passengers who are subject to an EES inspection, and it also showed that efficient security measures are essential to ensure that those passengers who are subject to an EES inspection actually go through it. The test conducted at Kiel was designed together with all relevant local stakeholders, and it was conducted as a simulation - meaning that it could have been stopped at any time in case of need, although it went so smooth that such an 'emergency stop' was not necessary.

Hübscher said the debriefing of the trial run at Kiel is still pending but shared it will probably focus on the particular difficulty of separating guests - and opportunities to further optimise signage in that context.

 Open questions for crew handling

While the EES implementation appears rather manageable as far as passengers are concerned, crew handling continues to pose a few open questions - not least as a great number of the crew serving onboard cruise vessels calling EU ports will be subject to EES inspections (in the case of TUI Cruises, for example, 83% of the crew fall under the scope of EES/ETIAS, against just a one percent share of the passengers).

Timothy Herrmann, in charge of government affairs at MSC Crew Services (Italia),  went into this issue, once again stressing first and foremost that EES was just a digitalisation of the existing system and that thus, on a practical level, the current system should not change.

Herrmann outlined: Essentially, a harmonisation of the stamping of Schengen Visa in and out at ports will be required - which means 'digital stamping' as EES has been implemented. At present it often happens that visa’s of embarking crew members are stamped in at the airport but never stamped out at the port of embarkation.

Under the EES regime this could easily lead to overstaying. Also disembarkations in ports outside the Schengen area may result in a visa never being closed, again with the consequence of overstaying. To address these challenges, Herrmann called for more multi entry visas to be issued, highlighting at the same time that an approach needs to be found to ensure a harmonised and consequent (in future digital and no longer physical) stamping in/stamping out in ports. He also stressed the importance of liaising with stakeholders to address the existing challenges.

Different approaches by EU member states

While preparations for EES are advanced in several EU countries, one cruise line representative highlighted EES application in Portugal could turn into a ‘nightmare’ if it proceeded as currently planned. The Seatrade Cruise Med expert panel concluded with a call on EU member states to take a harmonized approach to EES/ETIAS - and to exchange information and experiences already gained.