ICS2 compliance: A practical guide for cargo owners

If you manage international shipments entering or transiting through the EU, the  Import Control System 2 (ICS2) is reshaping the way goods are screened before arrival. Knowing how ICS2 works – and what’s required of you – is essential to avoid disruption, control costs, and keep your supply chain running smoothly.

In this guide, we break down the essentials of ICS2: what it is, who is affected, and the actions you need to take to stay compliant and avoid delays.

What is ICS2 – and who’s affected?

ICS2 is the EU’s advance cargo information system requiring detailed pre arrival safety and security data for all goods entering or transiting EU Member States. Customs authorities use this data to identify high‑risk shipments before they reach the border through the Entry Summary Declaration (ENS).

Replacing ICS1, ICS2 will become fully mandatory across all modes of transport – air, ocean, road, and rail – as of 1 September 2025, in line with the Union Customs Code.

ICS2 applies not only to imports but also to cargo moving through EU hubs in transit and some shipments within the customs territory under special procedures.

Why is ICS2 important?

ICS2 is designed to strengthen supply chain security while facilitating legitimate trade. For businesses, this means that ensuring accurate, timely data isn’t just a regulatory task – it’s central to avoiding delays and protecting operational continuity.

Who does what under ICS2?

ICS2 compliance relies on the coordinated actions of multiple parties in the supply chain. Each has defined responsibilities for collecting, verifying, and submitting data, and in many cases these responsibilities are shared between different actors through the “shared filing” model.

• Beneficial Cargo Owners (BCOs): Provide complete, accurate product level data including HS codes, detailed descriptions, shipper/consignee information, and EORI numbers. They are legally accountable if incorrect data results in customs errors.
• Shippers: May be the BCO or a third party; responsible for verifying all shipment data and passing it to the party filing the ENS.
• Freight Forwarders/NVOCCs: Typically submit the ENS at the house bill of lading (HBL) level for consolidated shipments and must declare the real shipper and consignee provided by the BCO.
• Carriers (Ocean, Air, Road, Rail): File the ENS at the master bill of lading (MBL) level for all cargo on board and rely on accurate data from shippers and forwarders.
• Consignees (EU Recipients): Provide valid EORI numbers and ensure they are reflected correctly on all documentation.

Under the shared filing model, different parties may each submit portions of the ENS. For example, a carrier may provide transport level information while a forwarder supplies house bill details for consolidated cargo. To make this work smoothly, cargo owners must supply accurate product level data early and ensure all filings are aligned to avoid gaps, duplication, or customs holds.

Maintaining ICS2 compliance: Key actions

1. Build strong internal data management
• Audit product master data to ensure HS codes and descriptions are accurate and consistent.
• Standardise commercial invoices and packing lists to include all ICS2‑required details.
• Use internal systems (ERP or product management tools) to centralise and verify data.
2. Manage EORI numbers
• Apply for EORI numbers for both shippers and consignees if not already obtained.
• Validate numbers regularly and integrate them into booking and documentation systems.
3. Clarify filing responsibilities
• Define whether the carrier, forwarder, or consignee is filing the ENS for each shipment.
• For house bill models, confirm the forwarder’s role and data needs.
• Establish communication protocols to confirm submissions and manage exceptions.
4. Meet filing deadlines
• For ocean freight, submit ENS data at least 24 hours before loading.
• For air cargo, comply with both pre‑loading and pre‑arrival requirements.
• Build filing timelines into operational workflows to avoid last‑minute errors.
5. Mitigate risk
• Conduct internal audits to check data accuracy and filing performance.
• Develop escalation procedures for customs queries or holds.
• Request compliance reports from partners to maintain visibility.

Using technology to support compliance

Centralising and automating data flows is one of the most effective ways to prepare for ICS2. Leveraging technology can help ensure accuracy, speed, and compliance across all shipments.

Key technology approaches:

• Centralised data management: Use ERP or supply chain systems to maintain consistent HS codes, product descriptions, and EORI numbers.
• System integration: Connect internal systems to logistics platforms or customs interfaces to reduce manual entry and errors.
• Built‑in validation: Choose tools that automatically check HS code formats, EORI numbers, and mandatory fields.
• Real‑time visibility: Platforms offering live status updates and exception alerts allow quick responses to issues.

Types of technology solutions:

• Customs filing platforms – Handle automated, system‑to‑system (STI) ENS submissions for high‑volume shipments.
• Shared trader portals – Offer web-based manual entry for smaller shipment volumes or occasional filings.
• Certified ITSPs – Provide automated validation, compliance dashboards, and audit trails for tracking and reporting.
• Automation tools – Pull shipment data directly from ERP or product information management systems to reduce duplication and errors.
• Analytics and reporting – Monitor compliance trends, identify recurring issues, and benchmark performance.

Additional considerations to support compliance:

• Pre‑submission compliance checks to flag missing or incorrect data before it reaches customs.
• API connectivity to streamline data exchange with partners and customs systems.
• User training and helpdesks to ensure teams are equipped to manage ICS2 filings.
• Data security: Use platforms with encryption, access controls, and GDPR compliance to safeguard sensitive shipment data.

ICS2 compliance checklist

• Audit HS codes and product descriptions.
• Obtain and validate shipper and consignee EORI numbers.
• Standardise documentation templates.
• Define ENS filing responsibilities with partners.
• Ensure data readiness within required timelines.
• Integrate systems to minimise manual errors.
• Establish monitoring and escalation plans.

In summary

ICS2 is more than just a new EU regulation – it’s a system designed to safeguard international trade and strengthen border security. For businesses moving goods into or through the EU, it means adjusting processes now to ensure accurate data flows long before cargo reaches the border. Getting it right helps you avoid delays, reduce costs, and maintain a seamless supply chain.

If you have any questions about the actions you need to take to comply with ICS2 and avoid delays, please reach out to our team – Divyang, Al, Mindaugas, and Sandeep – at ICS2team@maersk.com. We’ll be happy to answer any questions – or at the very least point you in the right direction if we get stuck. Alternatively, you might want to explore Maersk Customs Services for more general information.