ICS2 and the ENS declaration

Key Takeaways

• The entry summary declaration (ENS) must already sit with European customs before a container is loaded onto a vessel bound for Europe.
• Since 1 December 2025 the ENS can only be filed through ICS2; the old ICS1 route has been permanently retired.
• For sea freight containerised cargo, the deadline is at the latest 24 hours before loading onto the vessel.
• The carrier or forwarder usually files the declaration, but a missing EORI number or an unusable goods description from the importer can still hold the shipment back.
• Under multiple filing, responsibility for incomplete data stays with the importer even when another party files the declaration.

Before your container is loaded onto a vessel bound for Europe, a declaration must already sit with European customs. That declaration is the entry summary declaration, abbreviated ENS, and since 1 December 2025 it can only be filed through ICS2.

For an importer that is not a system detail. If the ENS is rejected or filed late, your shipment is not loaded. The carrier sails and your goods stay behind, and you usually find out after the departure time has passed.

You do not normally file the declaration yourself. The carrier or forwarder does. What you do supply is the data the declaration rests on, and that is exactly where it goes wrong: a missing EORI number or a goods description without a usable code is enough to hold the shipment back.

In this article we explain what ICS2 is, who must file the ENS, which deadlines apply to sea freight, what multiple filing means for your responsibility, and what happens when a declaration is rejected.

What is ICS2 and why does it exist?

ICS2 stands for Import Control System 2. It is the European system through which customs receives advance data on all goods entering the customs territory of the Union, regardless of the mode of transport.

The purpose is safety and security analysis in advance. Customs assesses the data before the goods are on their way and can decide on that basis that a shipment may not be loaded, or that it will be inspected on arrival.

ICS2 was introduced in phases. Release 3 has been in use since 3 June 2024. For road and rail transport the ENS obligation through ICS2 has applied since April 2025, with a deferral option that expired on 1 September 2025. On 1 December 2025 the hard cutover followed: since then an ENS can only be filed through ICS2 and the old route via ICS1 has lapsed definitively.

That means a forwarder still working with the old connection can no longer file a declaration today. If your shipment unexpectedly stays behind, that is the first thing to check.

Who must file the ENS declaration?

Responsibility lies with whoever submits the data. Whoever files the entry summary declaration is responsible for the accuracy and completeness of that data.

In practice that is the carrier or the forwarder for sea freight, and for ferry transport via the Netherlands the ferry operator for goods entering the EU through the Netherlands.

There is also multiple filing. Under it, anyone holding the data other than the declarant can supply that data. It is intended for situations where the carrier does not hold all the information, for example in consolidation where the house documents sit with the forwarder.

For you as an importer, multiple filing means something important: responsibility is divided, but it does not disappear. If your supplier or your forwarder supplies incomplete data, that becomes your problem the moment the shipment does not travel.

Which deadlines apply to sea freight?

For sea freight the deadline depends on the type of cargo. These are the deadlines that most often apply to container imports through Rotterdam.

• Containerised cargo: at the latest 24 hours before the goods are loaded onto the vessel on which they will enter the customs territory of the Union
• Bulk and break bulk: at the latest 4 hours before arrival of the vessel at the first port of entry
• Short sea from certain areas: at the latest 2 hours before arrival at the first port of entry

That last deadline applies among others to shipments from Greenland, the Faroe Islands, Iceland, ports on the Baltic Sea, the North Sea, the Black Sea and the Mediterranean, Morocco, the United Kingdom excluding Northern Ireland, the Channel Islands and the Isle of Man.

Note the difference in reference point. For containers the moment of loading in the port of departure counts, for bulk and short sea the moment of arrival in Europe. For a container from Shanghai, 24 hours before loading means in practice that the data must be complete weeks before arrival in Rotterdam.

For air freight, road and rail, different deadlines apply per mode. If you use those modes, have the exact deadline confirmed by your forwarder, because the differences are large and the consequences of filing late are the same.

Which data must you supply?

The ENS is a safety declaration, not an import declaration. It therefore does not ask about value or origin, but it does ask who and what, at a level of detail higher than many suppliers are used to.

• A goods description specific enough, with at least a six-digit commodity code per item
• A valid EORI number of the business consignee in the EU
• Complete details of consignor and consignee, without collective names
• Transport data, container numbers and seal numbers

Descriptions such as “goods”, “spare parts” or “samples” are not accepted. A six-digit HS code per item is the minimum, and that code has to come from your supplier or be determined by you.

If the consignee’s EORI number is missing or the commodity code is unusable, the declaration is rejected. So if you do not yet have an EORI number, that is not an administrative loose end but a blockage on your first shipment.

What happens when the ENS is rejected?

A rejected or missing ENS means the carrier may not load the goods. With container transport that is a missed sailing, and on current schedules the next opportunity is regularly a week later.

The costs that follow rarely land with the party that made the mistake. Extra storage in the port of departure, a new booking and sometimes demurrage and detention at the other end of the journey are usually for the account of the cargo interest.

Customs can also announce an inspection on arrival based on the data submitted, or in serious cases impose a do-not-load instruction. That last one is rare, but it happens, and then the declaration cannot be repaired: the shipment has to be rebuilt.

The practical lesson is that the ENS does not belong at the end of your preparation but at the start. The data your supplier provides determines whether your container travels, not your booking.

What does ICS2 mean for your import process?

Three things change practically in the way you work with suppliers and forwarders.

You need the goods data earlier. Not at dispatch but before loading, and for containers therefore well before the vessel sails. That means agreements with your supplier about when the packing list with codes is ready.

Your EORI number must be correct and active before your first shipment is on its way. An application still in progress is not a valid number.

And your forwarder must be connected to ICS2. Every company filing its own declarations completes a one-off Self Conformance Test per EORI number. Ask about that when you start with a new party.

Expert support with ICS2 and ENS declarations

ICS2 moves the moment at which customs data must be complete forward, to before loading in the port of departure. That makes supply by your supplier a critical point in your chain rather than administrative aftermath.

In practice we see that most rejections arise not from unwillingness but from incomplete goods descriptions and EORI data that is no longer current.

The Customs Company is an AEO-certified customs service provider in the Netherlands with direct connections to Dutch Customs and Portbase.

Our customs services check in advance whether your shipment data meets the ICS2 requirements, coordinate with the carrier on who files which part, and make sure the connection to the import declaration after arrival adds up.

Frequently asked questions

Q: What is the difference between an ENS declaration and an import declaration?

Ans: The ENS is a safety declaration filed in advance, before the goods are loaded or arrive. The import declaration is only made on arrival and determines the import duties and the VAT. The ENS is about who and what, the import declaration about value and origin.

Q: Must I file the ENS myself as an importer?

Ans: Usually not. For sea freight the carrier or the forwarder files the declaration, and for ferry transport via the Netherlands the ferry operator does. You do supply the data the declaration rests on, and under multiple filing another party holding data can supply it themselves.

Q: How many hours in advance must the ENS be filed?

Ans: For containerised sea cargo at the latest 24 hours before loading onto the vessel. For bulk and break bulk 4 hours before arrival applies, and for certain short sea 2 hours before arrival. Different deadlines apply per mode for air, road and rail.

Q: What happens if my shipment has no valid EORI number?

Ans: The ENS is rejected and the goods may not be loaded. The EORI number of the business consignee in the EU is mandatory data in ICS2. An application still being processed does not count, the number must be active before the shipment departs.

Q: Why was my container not loaded even though the booking was confirmed?

Ans: In many cases because the ENS was missing or was rejected. The booking with the carrier and the customs declaration are two separate processes. A confirmed booking does not mean the safety declaration was accepted, and without that acceptance the container does not travel.