ICS2 phase 3 — what does this mean for importers?
Since 1 March 2025, rail and road transport also fall under ICS2. What does phase 3 mean concretely for importers and how do you prevent Holds at the border?
ICS2 (Import Control System 2) is the European pre-arrival system through which import data is reported to EU customs already before arrival. With phase 3, effective 1 March 2025, this now applies to rail and road transport — on top of phase 1 (post/express air, since 15 March 2023) and phase 2 (all air freight, since 1 March 2024). For importers this means: complete data — including 6-digit HS code and clear goods description — must be available well before arrival, otherwise a Hold follows.
What exactly is ICS2?
ICS2 is the successor to the old ICS (Import Control System) and falls under the Union Customs Code (UCC, Regulation 952/2013) and the associated implementing regulation 2015/2447. The system is designed to improve risk analysis before entry — before loading in air and before arrival in other modalities — and to support the fight against smuggling, terrorism and illegal trade.
The basis is the Entry Summary Declaration (ENS): an electronic pre-arrival declaration with goods data, route, carrier, consignee and risk characteristics. This ENS is centrally processed in the Shared Trader Interface (STI) of the EU Commission and distributed in real time to the relevant national customs authorities.
The three phases
| Phase | Date | Modality |
|---|---|---|
| Phase 1 | 15 March 2023 | Post and express air |
| Phase 2 | 1 March 2024 | All other air freight |
| Phase 3 | 1 March 2025 | Sea, rail, road and inland waterways |
Phase 3 was originally planned for 2024 but was rolled out in tranches:
- Maritime carriers: 3 June 2024
- House-level filers in sea freight: 4 December 2024
- Rail and road transport: 1 April 2025 (adjusted date)
- Inland waterways: 1 September 2025
Since 1 September 2025, all goods flow into the EU is therefore covered by ICS2.
What must you provide as importer?
ICS2 requires a complete set of data fields, and that’s where the practical challenge lies. The most important:
- HS-6 code (Harmonised System at 6 digits minimum, EU Combined Nomenclature at 8 digits preferred).
- Goods description in clear trade terms — no vague terms like “general merchandise”, “samples”, “FAK”, “spare parts” without specification.
- EORI numbers of consignor, consignee, and possibly loader/unloader.
- Value and weight per shipment line.
- Addresses (no PO boxes allowed anymore).
- House Air Waybill / House Bill of Lading number for consolidation shipments.
- Transport details: flight number, ship, train route, license plate.
Vague descriptions are flagged immediately by the EU risk system. An ENS with “auto parts” is refused or leads to a Do-Not-Load (DNL) or Do-Not-Unload instruction.
A good description is not marketing copy. Write “rubber gaskets for car engine, 50 mm diameter” instead of “auto parts”.
How does it work in practice?
For air freight
The carrier (the airline) is legally responsible for filing the Master ENS. For consolidation shipments the freight forwarder (house declarant) files the House ENS.
Timeline:
- Master ENS filed by carrier before loading on flights to the EU.
- House ENS by forwarder once goods are booked.
- Risk assessment by EU customs in real time; outcome: green (no action), orange (additional inspection on arrival), red (Do Not Load).
- Arrival and presentation: without completed ICS2 notification, the shipment cannot enter.
For road transport
For road transport (since 1 April 2025) the carrier-declarant is responsible, often the international road carrier. The ENS must be filed before arrival at the EU external border — in practice at least 1 hour before passage.
For sea freight
24-hour rule: ENS at least 24 hours before loading at the port of departure for deep sea. For short-sea (within Europe, shorter than 24h sailing time) shorter terms apply, sometimes only 2 hours before arrival.
The role of the EORI number and data integrations
ICS2 requires that all parties in the chain have an EORI number (see our explanation on applying for an EORI). The Dutch importer must share their EORI in time with the foreign supplier and with the carrier or forwarder.
In addition, ICS2 integrates with:
- AGS Import: for the final import declaration after entry.
- NCTS: if the shipment continues under T1 after arrival.
- EMCS: for excise goods.
- Single Window CHED database: for food and plants (see also our CVO checklist article).
Common mistakes
1. Untimely delivery of data to carrier
The importer thinks: “the forwarder will handle it”. But the carrier must file the ENS before loading — sometimes 24+ hours earlier. With delay in invoice, packing list or HS code, a Do Not Load follows, and the shipment stays behind. Deliver data 48 hours before planned loading.
2. Vague goods description
Unchanged the biggest problem in the entire ICS2 chain. The EU risk system automatically flags descriptions that are too generic. Categories that always require extra detail: machine parts, chemicals, textiles, electronics, food products.
3. No or incorrect EORI
A customer without EORI or with an invalid number cannot be listed as consignee in an ENS. Importers who import incidentally often forget to apply for or pass on their EORI.
4. PO boxes as address
Since phase 2, PO box addresses are no longer allowed for consignor or consignee. A real establishment address is mandatory.
5. Underestimating house declaration
For consolidation shipments the House ENS must also be filed separately. Forwarders without STI access must work via a hub declarant — otherwise gaps arise.
6. Missing or incorrect HS codes
A 6-digit code is mandatory; many sales invoices only state a 4-digit code or none at all. Import an up-to-date HS table into your ERP and validate before shipping.
What to do with a Hold or DNL?
- Do-Not-Load: contact the carrier; file modified or supplemented ENS before new loading window.
- Hold on arrival: wait for instruction from Customs. Often an additional dataset request or physical inspection follows.
- Additional costs: storage in customs warehouse during investigation (€10–€50 per day), demurrage on containers, delayed delivery to customers.
In practice we see that well-prepared importers have less than 0.5% Holds, while unprepared companies exceed 5%.
What should you arrange now?
- Audit your master data: HS codes 6+ digits per article, clear descriptions, correct EORI of customers in all countries.
- Make agreements with carriers and forwarders: who delivers what, and when? Lay this down in SLAs.
- Train your purchasing and order department: they send the data to foreign suppliers. Bad input = bad ENS.
- Monitor your open shipments: proactively monitor for DNL or Hold notifications.
Get started
ICS2 is not a temporary peak but the new norm. Companies with their data well in order experience no delays. The rest pay structurally more for storage, demurrage and missed deadlines.
DouaneDoc helps you with ICS2 screening, data audits and filing House-ENS where needed. See our import declaration service or request a quote. For pharma importers we have a specific article on Pharma & ICS2 with attention to the cold chain.
Direct contact: 088 088 2407 or sales@aircargo.nl.