ICS2 Is Here: What Every European Shipper Needs to Know

The EU has been quietly rolling out one of its most ambitious customs modernisation projects: the Import Control System 2, or ICS2. If you import goods into Europe — by air, sea, road, or rail — this system changes how and when you need to provide advance cargo information to customs authorities.

It’s not optional. And depending on your transport mode, the deadlines are either already past or fast approaching.

What you’ll learn:

• What is ICS2?
• The rollout timeline
• Who needs to do what?
• What data is required?
• Consequences of non-compliance
• The role of your TMS

What is ICS2?

ICS2 replaces the original Import Control System (ICS1) and is part of the EU’s Union Customs Code framework. In plain terms, it’s the system through which advance cargo information — called an Entry Summary Declaration (ENS) — must be submitted to EU customs before goods arrive in or transit through the EU.

The key differences from the old system:

• Multiple filing: Under ICS1, only the carrier filed the ENS. Under ICS2, different supply chain actors can submit partial filings based on the data they hold. Your freight forwarder might file house-level details while the carrier files the master-level transport information.
• More granular data: ICS2 requires data at the commodity and item level, not just at the consignment level. That means more detailed goods descriptions, HS codes, and buyer/seller information.
• Pre-loading requirements: For air cargo, a minimum dataset must be filed before the goods are loaded onto the aircraft — not just before arrival. This is called PLACI (Pre-Loading Advance Cargo Information).
• All transport modes covered: ICS1 had patchy implementation across modes. ICS2 covers air, maritime, inland waterways, road, and rail.

The rollout timeline

ICS2 has been rolling out in three releases over several years:

Release 1 — Air postal and express (completed)

Deployment ran from March to October 2021. Postal operators and express carriers in air transport now submit pre-loading data as standard.

Release 2 — All air cargo (completed)

Deployment started March 2023 and completed by October 2023. All general air cargo is now fully covered — complete ENS filings with the new data requirements are mandatory.

Release 3 — Maritime, inland waterways, road, and rail

This is the big one. It’s rolling out in three steps:

As of September 2025, ICS2 covers all transport modes entering or transiting the EU. Some Member States received individual derogation periods for road and rail, but the direction is clear: full compliance is expected.

Who needs to do what?

The filing obligations depend on your role in the supply chain:

Carriers have the primary legal obligation to lodge a complete ENS. If you’re the party physically bringing goods into the EU customs territory, this is your responsibility.

Freight forwarders often hold information that the carrier doesn’t — particularly house-level details like the actual buyer, seller, and detailed goods descriptions. Under ICS2’s multiple filing model, forwarders can (and often must) file their own partial ENS to complement the carrier’s filing.

Shippers and importers may also need to file directly if they hold required data that hasn’t been shared with the carrier or forwarder. At a minimum, you need to ensure accurate and complete data flows to whoever is filing on your behalf.

Customs brokers can file on behalf of any of the above, but someone still needs to provide them with accurate data.

All parties need an EORI number (Economic Operators Registration and Identification) from an EU Member State’s customs authority.

What data is required?

The ENS data requirements vary by transport mode, but the core elements include:

• Goods description at commodity level (minimum 6-digit HS code)
• Consignor and consignee details with full identification
• Buyer and seller information at house level
• Transport document references linking master and house-level filings
• Weight, package count, and routing information
• Transport mode-specific data (vessel name, flight number, vehicle registration, etc.)

The critical point for shippers: your data quality matters. If the HS codes are wrong, the goods descriptions are vague, or the party information is incomplete, the ENS filing will either be rejected or flagged for additional screening. Both outcomes mean delays.

Under ICS2’s data quality hierarchy, customs authorities expect specific, accurate goods descriptions — not catch-all phrases like “general merchandise” or “various goods.” If you’ve been getting away with that under the old system, those days are numbered.

Consequences of non-compliance

The consequences are practical and immediate:

• Rejected ENS declarations — incomplete or inaccurate filings get bounced
• Do-not-load (DNL) instructions — for air cargo, customs can issue an instruction to prevent goods from being loaded onto the aircraft
• Cargo holds at the border — goods may be held for inspection upon arrival
• Forced screening — increased physical inspections if your data quality is poor
• Administrative penalties — set at Member State level, so they vary across the EU

The most costly consequence isn’t the fine — it’s the delay. A shipment held at the border for additional screening can disrupt your entire supply chain, disappoint your customers, and damage your reputation with your carriers.

The role of your TMS

A TMS sits at the centre of your shipment data. It’s the system that knows what you’re shipping, where it’s going, which carrier is moving it, and what documentation is attached. That makes it a natural enabler for ICS2 compliance:

Data centralisation: Your TMS aggregates the shipment data — goods descriptions, HS codes, weights, party information, routing — that feeds into ENS filings. If this data is accurate in your TMS, it can flow accurately to customs.

Automated submission: A TMS can integrate with ICS2 via the EU’s Shared Trader Interface (STI), or route data through IT Service Providers (ITSPs) who handle the technical submission. This automates what would otherwise be a manual filing process.

Multiple filing coordination: Under ICS2’s model, different parties file different data elements. Your TMS can help manage which data goes to which filer, ensuring that master-level and house-level filings link up correctly.

Data quality control: A TMS can validate completeness and accuracy before data leaves your system. Catching a missing HS code or an incomplete consignee address before filing is far cheaper than dealing with a border delay after.

Multi-modal coverage: If you ship by air, sea, road, and rail — each with its own ICS2 deadlines and data requirements — a single TMS provides one point of compliance across all modes.

What you should do now

1. Confirm your filing responsibilities — Understand whether you need to file directly or whether your carrier/forwarder covers your obligations. Get this in writing.

2. Clean up your product data — Accurate HS codes, proper goods descriptions, and complete party information are non-negotiable. If your master data is messy, fix it now.

3. Check your carrier agreements — Make sure your contracts with carriers and forwarders clearly define who files what under ICS2’s multiple filing model.

4. Review your TMS integration — Can your TMS feed data into the ICS2 system, either directly or through an ITSP? If not, this needs to be on your implementation roadmap.

5. Get an EORI number — If you don’t have one, apply through your national customs authority. You’ll need it for any direct filing obligations.

ICS2 isn’t a future problem — it’s a current reality for air and maritime, and road and rail are now live. The shippers who treat this as a data quality exercise, rather than just a compliance checkbox, will find that the investment pays off in smoother border crossings, fewer delays, and better carrier relationships.

Johan de Grijff, Commercial Director

published on: 10-4-2024

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