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Import Control System 2 (ICS2): Requirements & Compliance for EU Shipping

If you’re involved in shipping to the EU from China or any other region, understanding the Import Control System 2 (ICS2) is essential. With full implementation across all modes of transport, ICS2 has become the cornerstone of EU customs pre-arrival security requirements.

In this post, we’ll walk through Import Control System 2, explaining what it is and why it matters for EU-bound shipments. We’ll also cover key compliance requirements, common challenges, and practical steps to prepare your shipments for smooth customs processing.

What is Import Control System 2 (ICS2)?

Import Control System 2 is the EU’s pre-arrival cargo information and risk assessment system. It is designed to enhance customs security while ensuring that legitimate trade continues to move efficiently.

As of 1 September 2025, ICS2 replaces the older ICS. It requires the submission of complete safety and security data through an Entry Summary Declaration (ENS) before goods arrive in the EU customs territory.

The system applies to all transport modes, including air, ocean, road, and rail, and covers imports, transit cargo, and certain movements under special customs procedures.

Additionally, the ICS2 system is also fully mandatory across the EU, including Northern Ireland, Norway, and Switzerland, in accordance with the Union Customs Code.

Why ICS2 matters for your shipments

Import Control System 2 is significant for ensuring supply chain security, minimizing disruptions, and maintaining operational continuity when shipping to the EU.

Key Impact Why It Matters
Shipment clearance delays Incomplete or inaccurate ENS data can trigger customs holds or "do not load" instructions, disrupting delivery schedules.
Increased costs Delays may result in detention, demurrage, inspections, or administrative penalties for non-compliance.
Shared compliance responsibilities ICS2 allows multiple parties to file ENS data, making coordination between shippers, forwarders, and carriers essential.
Higher data accuracy standards Detailed goods descriptions, HS codes, and valid EORI numbers must be provided at source to avoid rejections.

ICS2 requirements: ENS data and compliance

To comply with Import Control System 2, you need a clear understanding of which data to submit and when.

Core ENS data elements

At a minimum, an Entry Summary Declaration under ICS2 must include:

  • Accurate goods description — clear and specific wording, not vague terms.
  • 6-digit Harmonized System (HS) codes for each item.
  • Economic Operators Registration and Identification (EORI) number of the consignee (if applicable).
  • Shipper and consignee details, including full addresses.
  • Buyer and seller data (or supplementary declarant EORI for multiple filings).

For many freight forwarders shipping from China, providing this level of detail requires coordination across customer, carrier, and customs broker systems well in advance of the shipment’s departure.

When to submit ENS Data

  • For air shipments: Submit ENS data before loading, typically linked to flight departure.
  • For sea, road, rail, and inland waterways: ENS must be lodged before arrival at the first EU customs point of entry.

Late or incomplete ENS filings often prevent cargo from loading or trigger customs holds at the border, leading to avoidable delays and additional costs.

ICS2 and customs: practical compliance insights

ICS2 customs compliance goes beyond ticking boxes. It plays a direct role in keeping your supply chain moving without unnecessary delays.

Multi-party ENS filing

The ENS filing structure depends on your contractual setup:

  • Single filing: One designated party submits the complete ENS data.
  • Shared filing: The carrier, freight forwarder, and consignee each submit specific parts of the ENS.

Selecting the right filing model is critical. Poor role allocation often leads to data inconsistencies or filing rejections, especially in consolidated or house-bill shipments.

Who is responsible under ICS2?

ICS2 compliance depends on clear role allocation across the supply chain. When shipping to the EU, each party involved collects, verifies, and submits specific safety and security data.

Beneficial Cargo Owners (BCOs):

BCOs supply accurate, product-level information, including detailed goods descriptions, HS codes, shipper and consignee details, and valid EORI numbers. Because this data forms the foundation of the ENS, BCOs remain legally responsible for errors that result in customs issues or noncompliance.

Shippers:

Shippers, whether acting as the BCO or a third party, verify shipment data and provide complete and accurate information to the party responsible for filing the ENS.

Freight forwarders and NVOCCs:

Freight forwarders and NVOCCs typically handle ICS2 filings at the house bill (HBL) level, especially for consolidated cargo. They must declare the true shipper and consignee as provided by the BCO and ensure data consistency across all filings.

Cargo carriers:

Carriers submit ENS data at the master bill (MBL) level for all cargo on board. Their filings rely heavily on the accuracy and timeliness of information received from shippers and forwarders.

Consignees (EU importers or recipients):

Consignees provide valid EORI numbers and ensure these details appear correctly across all transport and customs documentation.

In the ICS2 shared filing model, various parties contribute different sections of the Entry Summary Declaration. For instance, carriers provide transport and routing information, while forwarders submit details at the house level for shipments.

To avoid gaps, duplication, or customs holds, cargo owners must supply complete product data early and ensure that all parties align their filings. In practice, effective coordination is a core requirement of ICS2 compliance in shipping to the EU.

ICS2 in shipping to the EU: Best practices

To keep ICS2 in shipping to the EU compliant and efficient, follow these proven best practices:

Start early

Submit your ENS data well prior to shipping instruction cut-offs to avoid last-minute errors or delays.

Standardize your data

Use consistent HS codes and verified shipper, consignee, and EORI information across all systems.

Use the right technology

Automate ENS filings through approved solutions such as the EU’s Shared Trader Interface (STI) or reliable customs software.

Train your team

Ensure operations staff and logistics partners understand ICS2 requirements, roles, and submission timelines.

Collaborate with partners

Coordinate closely with carriers, customs brokers, and shippers to ensure accurate and timely information sharing.

Final thoughts

The transition to Import Control System 2 (ICS2) marks a major shift in how the EU manages customs pre-arrival security. With the right preparation, accurate data, and compliance support, you can minimize risk, avoid delays, and ensure your cargo moves smoothly across borders.

Our team works closely with shippers and carriers to support compliance, align documentation, and maintain clear, timely communication throughout the shipping process.

Contact us today to discuss your shipment and get expert guidance on ICS2 compliance for your EU-bound cargo.

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