The deployment window for companies to move to Import Control System 2 (ICS2), the European Union’s (EU) initiative to enhance cross-border trade security by requiring customs declarations before goods enter the EU.

Soon, for air cargo, a pre-loading declaration must be submitted before goods are loaded onto the aircraft. For all other transport modes, including maritime, road, rail, and postal shipments, a pre-arrival declaration is required before the goods reach the EU border. ICS2 is designed to improve risk assessment and prevent illicit shipments from entering EU territory.

“For e-commerce, this measure is critical. In 2024, approximately 4.6 billion low-value consignments (worth €150 or less) entered the EU market, equating to about 12 million parcels daily and double the volume from the previous year,” parcels daily and double the volume from the previous year,” Luis Pimentel, the CEO of Feeport, stated. Feeport developed neutral SaaS platform – x7trade – which went live already in 2021 and provides ENS-ICS2 compliance as well as automated customs clearance of bulk b2c e-commerce imported into the EU from the 3rd countries. 

“This rapid increase has made it more challenging for customs authorities to inspect shipments effectively. ICS2 addresses this by enforcing stricter data requirements, ensuring transparency, and allowing customs to process shipments more efficiently.”

Ensuring the integrity of e-commerce shipments

As the volume of e-commerce imports grows, ICS2 will serve as a data-driven enforcement mechanism, ensuring that all imports are accurately declared, screened for compliance risks, and processed efficiently before entering the EU.

ICS2 strengthens supply chain transparency by providing structured data that enables customs authorities to conduct risk assessments before goods leave their country of origin. This approach allows compliant shipments to move efficiently while ensuring that high-risk consignments receive the necessary scrutiny.

“To fully realise its potential, ICS2 must be consistently applied across all transport modes and member states. If implementation remains fragmented, some entry points will become weak links, affecting the system’s overall effectiveness,” Pimentel explained. “Ensuring full and uniform enforcement will enable ICS2 to improve trade security, reduce disruptions, and create a more predictable import process.”

The function of ENS

The Entry Summary Declaration (ENS) is the initial customs filing required for all cargo entering the European Union, making it a mandatory step for e-commerce shipments as well as other types of freight. ENS contains essential details, including transport information and parcel-specific data such as the buyer, seller, and product descriptions.

Under previous customs frameworks, submitting this level of detailed data for high-volume e-commerce shipments was nearly impossible. ICS2 introduces a structured approach that allows different supply chain actors to contribute their respective parts of the ENS. Airlines, postal operators, and express couriers are typically responsible for submitting transport details, while parcel-level data can be provided by freight forwarders, customs brokers, or in some cases, e-commerce marketplaces or importers, commonly referred to as house filters.

ICS2 integrates these inputs, ensuring compliance while streamlining the customs process. The combination of house filers submitting parcel-level details and airlines submitting flight-level data results in a complete ENS filing. While the technical coordination between these actors is essential, the industry has already established clear practices to ensure that each party fulfils its role efficiently. Airlines are able to identify when house filers have submitted their portion of the ENS and proceed with the required flight-level filing accordingly. This approach is now becoming a recognised standard across the industry, with stakeholders aligning on their responsibilities to ensure smooth and compliant customs processes.

“This enhanced system strengthens customs risk assessment, improves supply chain security, and ensures that e-commerce shipments fully comply with EU import regulations. With ICS2, customs authorities gain greater visibility into shipments before they arrive, enabling more efficient processing and supporting the continued growth of cross-border trade,” Pimentel outlined.

Barriers for businesses

The primary challenge companies are expected to experience when complying with ICS2 requirements is managing high shipment volumes while ensuring data accuracy in line with EU-level requirements. Large e-commerce businesses handle tens of thousands of parcels per day, making manual submission impractical. Automation is essential, but the requirements and complexity of integration with logistics providers and customs systems vary across different regions.

Another challenge is inconsistent enforcement across EU member states. Express couriers, postal operators, and smaller freight forwarders often struggle with compliance, leading to disruptions and delays for businesses relying on multiple shipping channels.

Additionally, data accuracy remains a persistent issue. Many businesses face difficulties in maintaining consistent product descriptions and HS codes, which can result in misdeclarations, penalties, and customs clearance delays.

“Starting from April 1st this year, the EU will introduce stricter requirements for goods descriptions and trader details in customs declarations,” Pimentel highlighted.

“ENS filings may now be rejected if the product description or trader’s name and address are deemed too vague or inaccurate. Terms such as “consumer goods,” “as per attached invoice,” “accessories,” or “household goods” will no longer be acceptable descriptions. To enforce this, the EU has published a stop words list, and any declaration containing these restricted terms will be automatically rejected during the ENS process.

“These stricter controls emphasise the need for precise and structured data to avoid shipment delays, additional compliance costs, and penalties. Businesses must ensure their declarations align with these updated standards, reinforcing the importance of automation and robust data management systems in the evolving customs landscape.”

Fragmented implementation

The current lack of uniform enforcement weakens ICS2’s ability to deliver its intended benefits, leading to gaps in security, unfair competition, and logistical inefficiencies. Businesses that invest heavily in compliance face a competitive disadvantage when others can operate under weaker enforcement at certain EU entry points.

From an operational perspective, fragmented implementation disrupts trade efficiency and fairness across the EU. Businesses must adapt to different customs procedures in each member state, leading to delays, unexpected compliance costs, and higher administrative burdens. This unpredictability makes it difficult for companies to plan their supply chains effectively, increasing costs for both businesses and consumers.

“The most significant risk is trade security. When some EU countries enforce ICS2 rigorously while others apply minimal scrutiny, illicit and misdeclared shipments can still enter through weaker points of entry. Once inside the EU, these goods move freely across the single market, making it difficult to track them later,” Pimentel declared

“ICS2 was designed to modernise customs processes and enhance trade security, but its success depends on full and consistent enforcement across all EU member states.”

Wider implications

ICS2 is part of a larger shift toward pre-arrival customs security and digital trade regulation. Similar approaches are being adopted in other major markets, including the United States and the United Kingdom, reflecting a global trend toward enhanced customs control and supply chain transparency.

If the EU ensures consistent ICS2 enforcement, it will create a more predictable and structured customs process that facilitates legitimate trade while allowing customs authorities to focus resources where they are most needed. This would improve efficiency, security, and trade flow across the region.

However, if ICS2 is not uniformly enforced across EU member states, the EU risks falling behind in trade competitiveness. Inconsistent enforcement creates imbalances between regions and countries, leading to uncertainty for businesses. Companies that have already invested in compliance need certainty and a level playing field, and without it, they may face operational inconsistencies depending on the country of entry.

“As customs regulations worldwide become more data-driven, businesses that invest in automation and compliance technology will be best positioned to adapt to evolving trade requirements and ensure smooth cross-border operations,” Pimentel said.

Navigating implementation

Businesses must act now rather than wait for full enforcement to create disruptions. Proactive compliance is the best strategy to avoid delays, penalties, and operational risks. Investing in automation and reliable customs compliance solutions will be essential to ensuring seamless cross-border trade in the evolving regulatory landscape.

At the same time, businesses should engage with policymakers and industry stakeholders to ensure consistent and practical enforcement across the EU. ICS2 can only succeed if it is applied uniformly, ensuring that businesses operating compliantly are not placed at a disadvantage due to gaps in enforcement.

The regulatory framework is in place, and businesses must prepare now to stay ahead. It is time for the EU to ensure that ICS2 is fully implemented, providing clarity, efficiency, and a secure foundation for the future of trade.

“Platforms like Feeport’s x7trade platform are designed to help businesses navigate the complexities of ICS2 compliance and e-commerce customs clearance,” Pimentel continued. “As a neutral, cloud-based solution, x7trade automates Entry Summary Declaration (ENS) submissions, customs data validation, and compliance monitoring, ensuring that companies meet ICS2 requirements efficiently and without disruption.

“By detecting errors in real-time and integrating seamlessly with logistics workflows, x7trade enables businesses to reduce delays and avoid compliance risks.