ICS2 for Logistics and Road Transport Operators: A Practical Guide to ENS Filing and EU Compliance

Summary: The EU’s Import Control System 2 (ICS2) requires road and rail operators to submit Entry Summary Declarations (ENS) before goods enter or transit the EU. Fully mandatory from 1 September 2025, ICS2 introduces stricter data requirements to enable pre-arrival risk analysis and smoother border controls.

Import Control System 2 for Logistics and Road Transport Operators

To comply with EU safety and security regulations, logistics companies and transport operators must provide advance cargo data when moving goods into or through the European Union. The Import Control System 2 (ICS2) is a central element of the EU’s customs risk management framework and applies across all transport modes, including road and rail.

ICS2 shifts customs controls upstream by requiring compliance before physical arrival at the EU border. For operators, this represents both a regulatory obligation and an operational change.

Understanding Import Control System 2 (ICS2)

What Is ICS2?

ICS2 is the EU’s advance cargo information system designed to strengthen supply chain security. It collects and analyses shipment data prior to arrival or transit, enabling customs authorities to identify risks earlier in the transport journey.

The Role of the Entry Summary Declaration (ENS)

The Entry Summary Declaration (ENS) is the core data submission under ICS2. It supports pre-arrival risk analysis and allows customs authorities to:

  • Identify high-risk consignments early
  • Apply targeted and proportionate controls
  • Improve supply chain visibility
  • Reduce unnecessary inspections for compliant trade

ICS2 replaces fragmented national systems with a harmonised EU-wide approach.

Who Must Comply with ICS2?

Affected Economic Operators

ICS2 obligations apply to a broad range of actors involved in moving goods into or through the EU, including:

  • Road and rail hauliers
  • Logistics service providers
  • Freight forwarders
  • Postal operators and express carriers
  • In certain scenarios, EU-based final consignees

Responsibility for ENS filing depends on the transport model and contractual arrangements, but compliance accountability remains critical across the supply chain.

ICS2 Requirements for Road and Rail Transport

Mandatory ENS Filing

For road and rail transport, ENS filing is mandatory for:

  • Goods entering the EU
  • Transit movements across EU territory
  • Multimodal shipments involving road or rail

Key Data Requirements

A compliant ENS must include:

  • Accurate consignor and consignee details
  • Precise goods descriptions (generic terms are not permitted)
  • Minimum six-digit HS commodity codes
  • Transport references, routing, and carrier details

Examples of unacceptable descriptions include “general cargo” or “spare parts”. Detailed and specific descriptions are required for effective risk profiling.

ICS2 Implementation Timeline for Road and Rail

Phased Rollout

During the transition, implementation practices may vary by Member State. Operators moving goods across multiple EU borders should monitor national customs guidance closely.

How ICS2 Changes Cross-Border Compliance

From Reactive to Preventive Controls

ICS2 introduces a preventive compliance model. Risk assessment is completed while goods are still en route, rather than after arrival.

Impact on Operational Performance

For logistics and fleet managers, this creates a direct link between:

  • Back-office data quality
  • ENS submission timing
  • Border crossing predictability

Incomplete or inaccurate data can lead to rejection, intervention, or delays before clearance can proceed.

ENS Filing Models: Present and Future

Current Single Filing Requirement

At present, road and rail operators must submit ENS data using a single filing model, where one party provides the complete dataset.

Future Multiple Filing Solution

A multiple filing solution for road transport—allowing different parties to submit partial data for one ENS—is expected in mid-2026. Until then, operators must ensure internal and upstream data coordination.

Organisational and Technical Readiness

Systems and IT Integration

To comply with ICS2, operators must:

  • Hold a valid EORI number
  • Use an ENS-capable IT system
  • Complete mandatory self-conformance testing

ENS submissions can be made via the Shared Trader Portal (STP) or the Shared Trader Interface (STI).

People and Process Readiness

Beyond systems, compliance requires:

  • Staff training on ICS2 data requirements
  • Clear processes for collecting accurate data from customers
  • Internal validation controls to reduce rejection risks

Many compliance issues arise from incomplete or poor-quality upstream data rather than system failures.

The Business Value of Digital ICS2 Compliance

Although ICS2 is a regulatory requirement, effective implementation can deliver operational benefits, including:

  • Reduced ENS rejection rates
  • Faster customs risk assessment
  • Improved predictability of cross-border movements
  • Lower administrative overhead
  • Stronger compliance governance

Embedding ENS processes into transport management workflows helps align compliance with daily operations.

Key Takeaways for Logistics and Transport Operators

ICS2 is reshaping European customs by combining security, automation, and data transparency. For road and rail operators, compliance is no longer a border activity, it is a pre-arrival, data-driven process embedded within logistics operations.

Organisations that invest in data accuracy, system readiness, and organisational preparedness are better positioned to maintain efficient EU cross-border flows while meeting evolving safety and security obligations.