Mastering ICS2: A Guide to EU Import Requirements

The European Union (EU) has tightened its focus on border security in response to rising threats from terrorism and illegal trade. That’s why they implemented the advanced Import Control System 2 (ICS2)—to efficiently and safely manage the movement of goods.

ICS2 is more than just a checkpoint; it’s a vital shield. The system promotes lawful trade and significantly enhances protection by facilitating proactive risk analysis and safe import management before goods even arrive in the EU.

The clock is genuinely ticking. The deployment window for the final phase of ICS2 (Release 3) closes on 1 September 2025, with the official requirement enforcement in full effect by 31 December 2025. This tight schedule means we are in the final countdown. All economic operators, especially road and rail carriers, must be prepared now.

If you find the complexities of these EU import regulations overwhelming, you’re not alone. Don’t worry; this detailed guide is designed to cut through the confusion and make understanding and complying with the EU’s safety and security requirements straightforward.

What is Import Control System 2 (ICS2)?

Import Control System 2 (ICS2) is the European Union’s safety and security system. It requires submitting detailed information about cargo before arrival to enhance border security.   

Prior to goods entering the EU customs territory, it requires the electronic submission of detailed shipment information. This allows advanced safety assessments to identify shipments that might need additional inspection. In addition to enhancing protection against possible threats, this proactive strategy makes the importation process run more smoothly and effectively.

Import Control System 2 (ICS2) Releases

ICS2 Release Timeline Key Phases2

ICS2 is currently in its third phase. 

What was included in the ICS2 Releases 1 and 2?

The first release of ICS2 was implemented on March 15, 2021. This release was primarily for postal and express consignments travelling to or through the EU by air. It required them to complete the Entry Summary Declaration (also known as pre-loading advance cargo information, or PLACI) before being loaded onto an aircraft bound for the EU.

The second release of ICS2 came into effect on March 1, 2023. It required all air freight cargo general consignments to complete the PLACI form and the entire Entry Summary Declaration (ENS) data set before arriving in any of the EU-27 destinations as well as Northern Ireland, Norway, and Switzerland.

What is included in the ICS2 Release 3?

ICS2 Release 3, which came into effect on June 3, 2024, introduced a new process for the importers transporting goods into the EU via maritime and inland waterways, as well as road and rail.

It required them to provide a six-digit Harmonised System (HS) code and detailed description for each product before arrival through a complete Entry Summary Declaration (ENS). Additionally, it is also mandatory to submit the Economic Operators Registration and Identification (EORI) number for the shipment consignee.

Release 3 is not fully implemented on the given date; instead, it has different times for the different modes of transportation. For instance, freight forwarders moving goods via maritime and inland waterways for house-level filers must be completely aligned with the ICS2 requirements from 4 December 2024.

Read what ICS2 Release 3 says about Freight Forwarders.

The Phased Deployment of ICS2 (Release 3)

ICS2 Release 3 deployment is a mandatory, phased process for economic operators based on their transport mode. Here are the key steps and corresponding deadlines:

  • Phase 1: 3 June 2024 – 4 December 2024
    • Maritime and inland waterway carriers must begin submitting Entry Summary (ENS) filings in line with ICS2 requirements.
  • Phase 2: 4 December 2024 – 1 April 2025
    • Maritime and inland waterway house-level filers (including freight forwarders and consolidators) must comply with the new data submission obligations.
  • Phase 3 (The Final Step): 1 April 2025 – 1 September 2025
    • Road and rail carriers will be the final group to onboard. After this step, all modes of transport into the EU will be fully governed under ICS2.

But here's the twist

Important Note on Derogations (Road and Rail)

While 1 September 2025 is the official end of the deployment window for Road and Rail carriers, several EU member states have been granted a temporary national derogation (extension) by the European Commission.

For goods entering the EU through these specific countries, affected economic operators may continue to file in the legacy ICS1 system until 31 December 2025. Always check the latest EU customs circulars or consult with a specialist if you are operating in these member states to ensure you are meeting the correct obligation deadline.

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Understanding the Derogation (Extension)

Navigating the various national deadlines can be confusing, but compliance is non-negotiable. The most critical factor is the Member State’s first entry into the EU, as this determines whether you must use the new ICS2 system immediately or can utilise a temporary extension. 

Member State of first entrySystem to use for filing safety and security data (ENS)
AT AustriaFrom 1/09/2025, ICS2
BE BelgiumFrom 1/09/2025, ICS2
BG BulgariaFrom 1/09/2025, ICS2 or, where applicable, NCTS-P6
CY CyprusFrom 1/09/2025, ICS2
CZ CzechiaFrom 1/09/2025, ICS2
DE GermanyFrom 1/09/2025, ICS2
DK DenmarkFrom 1/09/2025, ICS2
EE EstoniaFrom 1/09/2025, ICS2 or, where applicable, NCTS-P6
FR FranceUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
GR GreeceUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
IE IrelandUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
IT ItalyUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
HU HungaryUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
FI FinlandUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
ES SpainUntil 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
XI The U.K. (Northern Ireland)Until 31/12/2025, ICS1 or ICS2 — From 1/1/2026, ICS2
LV LatviaAt the latest until 31 May 2026, ICS1 or ICS2 and NCTS-P5 — From 1/6/2026, ICS2 or, where applicable, NCTS-P6
LU LuxembourgFrom 1/09/2025, ICS2

Unsure which filing system applies to your route?

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How can I prepare my business for ICS2?

To complete and submit the safety and security declaration to the ICS2, you will need the following information for each product in the shipment:

  • Accurate goods description: Each item in the shipment must have an accurate and complete description, including composition, nature, and intended use.
  • EORI number: It is compulsory to obtain an EORI number from customs authorities of any EU state if your business is involved in customs activities within the EU.
  • Harmonised System (HS) code: You must provide a minimum of 6-digit HS code for each product to help customs authorities determine taxes and duties.
  • Information on the parties involved: You must provide information about the buyer, seller, consignee, and consignor.
  • Get your ELO reference: Ensure readiness for the Obligatory Logistics Envelope (ELO), which becomes mandatory by 1 September 2025, for all shipments that pass through the French border. An online service called ELO was created to combine all of the data about the customs and cargo procedures needed to cross the smart border into a single barcode. The goal of this system is to expedite processing times and guarantee safer customs procedures for both import and export flows.

In addition to gathering the aforementioned information, you can get your business ready for ICS2 by:

  • Upgrading the IT infrastructure of your business to make sure that it connects directly with the ICS2. With this, you can run self-conformance tests to check how communication between systems works.
  • Updating your business processes to make sure they comply with ICS2 requirements.
  • Clarify the responsibilities of your business and who is going to submit the ENS dataset.
  • Requesting customs authorities for a deployment window if needed to ensure you connect with ICS2 completely.

Challenges associated with ICS2

Businesses involved in importing goods to the EU face the following challenges:

Technical and regulatory challenges

Customs authorities, importers/exporters, and freight forwarding companies come across many technical and regulatory challenges associated with integrating ICS2.

From a technical standpoint, establishing an IT infrastructure that can effectively manage and secure a vast amount of data is a challenging task. Advanced and reliable technological solutions are required to ensure data accessibility, confidentiality, and integrity, especially in the area of cybersecurity.

From a regulatory perspective, one of the biggest challenges is getting different member states to harmonise their customs procedures. Every EU country is required to incorporate the ICS2 directives into its local regulatory requirements, which can cause delays and inconsistencies. Moreover, economic operators have to adopt new procedures to show compliance with the new regulations.

Who Exactly is Affected by ICS2?

Industries Impacted by ICS2

Still wondering if this affects you? If you’re thinking, “This sounds like a freight forwarder’s problem, not mine,” think again. Anyone shipping goods into or through the EU will feel the impact, as your logistics partners rely on you to provide the accurate, complete information (like 6-digit HS codes and Consignee EORI) for the declarations they file on your behalf.

The most significant change under ICS2 is the shared responsibility for providing accurate safety and security data. This system moves far beyond placing the burden solely on the carrier; it affects every key player in the supply chain.

If your business is involved in moving goods into the EU, you are considered an Economic Operator (EO) and must comply. The requirement to file a complete Entry Summary (ENS) declaration is often distributed among multiple parties in a supply chain, known as multiple filing.

Type of Economic Operator Primary Role and ICS2 Relevance
Carrier (Air, Maritime, Rail, Road) The party that physically transports the goods. They hold the ultimate legal responsibility for the transport-level ENS filing.
Customs Broker / Freight Forwarder A specialised agent who handles customs declarations and logistics. They are often the “House-Level Filer” responsible for submitting detailed cargo data.
Importer The party that brings goods into a customs territory (often the consignee). They are legally responsible for the goods upon import and must ensure the required import data is provided.
Exporter The party that sends goods out of a customs territory (often the consignor or seller). They are crucial for providing accurate product information and HS codes for the ENS.
Authorized Economic Operator (AEO) A specially certified, highly trusted trader who enjoys benefits like fewer customs checks and simplified procedures. AEOs still must comply with ICS2 data requirements.

Is your shipment data strong enough for EU security screening?

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Using technology for ICS2 compliance

A strong technological foundation is necessary to meet the demanding requirements of ICS2.

System for data management

To properly gather, store, and send the enormous volume of data needed for ICS2 compliance, businesses must put in place reliable data management systems.

These systems facilitate effective data retrieval and reporting while guaranteeing data security, consistency, and accuracy.

Data exchange platforms

For businesses and customs authorities to communicate seamlessly, it is essential to use safe and effective data exchange platforms.

These platforms make it possible for data to be transmitted electronically, guaranteeing timely submission and lowering the possibility of mistakes during manual data entry.

ICS2 compliance software

Making an investment in specialised ICS2 compliance software, such as the one offered by iCustoms, can greatly expedite the procedure.

This software can create precise ENS declarations, automate data entry, and check data against ICS2 specifications, boosting efficiency.

ICS2 system benefits

Benefits of ICS2
  • Improved protection for EU: ICS2 is crucial for protecting the internal market of the European Union, which increases the safety of the customers. This system identifies risky and non-compliant goods by implementing preventative controls.
  • Promoting legitimate trade: Thanks to its robust security measures, ICS2 performs effective risk management, facilitating the smooth flow of legitimate trade.
  • Early identification of risks: Using advanced risk analysis techniques, the ICS2 enables customs authorities of the EU to detect potential safety issues ahead of time.
  • Enhanced cooperation: ICS2 facilitates the rapid exchange of information between various customs authorities, enhancing collaboration between states for effective EU-wide risk analysis.

Applicability of ICS2

Import Control System 2 (ICS2) is applicable for all shipments moving from non-EU countries to EU countries or transiting through EU member states, as well as Northern Ireland, Switzerland, and Norway.

ICS2 Release 3: Preparation for the deadline of 1 september, 2025

ICS2 Preparation Checklist

Maritime and Inland Waterways House Level Filers: Are you ready for the upcoming changes to ICS2?

Take the following actions to guarantee a seamless transition and prevent business interruptions:

  • Assess the compatibility of your current software and IT infrastructure with ICS2 & ELO
  • Familiarise yourself with the new data requirements, collect the necessary information, and verify its accuracy.
  • Provide your staff with information on the new ICS2 requirements and procedures.
  • Take into account utilising ICS2 compliance software, such as iCS2 by iCustoms, that can automate the tasks associated with safety and security declarations.

Achieve ICS2 Compliance with iCustoms: Your All-in-One Solution

Don’t let the ICS2 Final Countdown create chaos in your logistics operations. iCustoms is a complete, streamlined compliance solution designed to make mandatory EU imports and safety filings simple. 

We are committed to helping your business navigate this complex regulation by offering the following critical benefits:

Feature Benefit to Your Business Alignment with ICS2
Automated Data Entry Cut manual work and eliminate errors with AI-powered data extraction from your shipping and commercial documents. Ensures accuracy and completeness for ENS filings, with full API support for F15 and F50 across both ocean and road shipments.
Rapid ICS2 Filing Submit complete Entry Summary (ENS) declarations in under 2 minutes, avoiding costly border delays. Guarantees timely submissions required for EU pre-arrival risk analysis.
ELO Support Automatically generate the mandatory Enveloppe Logistique Obligatoire (ELO) forms to meet France’s national requirements. Supports Member State-specific obligations (like France) during the ICS2 transition.
Smart API Integrations Streamline workflows with API-based contact management, allowing easy reuse of shipper and consignee details for faster filings. Includes F15 and F50 filing submission directly from the application and provides access to the official ENS EU technical completion matrix documentation for smooth client integration.

Conclusion:

The European Union’s Import Control System 2 (ICS2) marks a fundamental shift in how supply chain security is managed, moving from pre-arrival to pre-loading risk analysis for all goods entering or transiting the EU. For economic operators across the air, maritime, rail, and road sectors, compliance is not merely a bureaucratic hurdle but a critical necessity for maintaining operational continuity.

Ultimately, ICS2 is designed to facilitate legitimate trade by targeting high-risk cargo more effectively. By treating these new requirements as an opportunity to enhance your internal processes and strengthen supply chain partnerships, your business can ensure a smoother, more secure flow of goods into the European market for years to come.

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