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Policy & Compliance
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EU introduces Import Control System 2
The new Import Control System aims to create a more integrated approach to Customs risk management for goods entering EU territory or areas that have to adhere to EU Customs regulations
When the United Kingdom was part of the EU there was no requirement for UK trade to submit a safety and security declaration for goods being shipped to, or transiting, the EU. That changed post-Brexit and the system will change again over the next few years as the original Import Control System (ICS) is replaced. Ironically, BIFA was involved in many of the original discussions, via CLECAT, with the Commission leading to the introduction of concepts such as dual filing. The purpose of this article is to provide Members with an overview of ICS 2, in particular release 2 which is due to go live on 1 March 2023. For readers it is essential to remember that, due to the current Northern Ireland Protocol, the change will affect movements to both there and the rest of the EU. The new system aims to create a more integrated approach to Customs risk management for goods entering EU territory or areas that have to adhere to EU Customs regulations. ICS 2 – release 1 is now live. We will examine ICS releases 2 and 3 in this introductory article. ICS release 2 is expected to go live on 1 March 2023; it will require a full Entry Summary Declaration (ENS) for all air cargo movements to or transiting the EU. Release 1 has introduced the need to submit Pre-loading Advance Cargo Information (PLACI) via the Shared Trader Interface. The second release builds on the PLACI requirements and, in addition, Economic Operators will need to submit: • Pre-arrival entry summary declarations, • Notification of the arrival of the active means of transport upon entry into the EU, • Notification of the presentation of the goods. Release 2 impacts all air cargo operators, including freight forwarders, air carriers and express operators. Release 3 is the final release of ICS 2 and is anticipated to go live on 1 March 2024. It will bring on board Economic Operators that move goods via rail, road and maritime. We have been informally advised that the implementation period is likely to last six months. This is because it is widely believed that the road transport industry, due to its fragmented structure
and lack of both Customs expertise and appropriate IT systems, will encounter particular issues transitioning to ICS 2.
Explanation of how ICS 2 works ICS 2 consists of certain central components, which is one of the main differences to its predecessor, where the ENS had to be submitted to Customs in the first country of arrival in the EU. These main components of the system consist of: • The Shared Trader Interface, which is part of the wider system developed by the EU to accept declarations; • A Common Repository, which is a central component that requests the relevant Customs authorities to undertake the required risk assessments. In addition, national systems will be developed to accept notifications that goods have been presented; these will process and respond to risk assessments. Once these risk assessments are complete, the national Customs authority will return the responses to the EU via the Common Repository. Appropriate responses are then shared with traders via the Shared Trader Interface. For Northern Ireland, the Application Programming Interface (API) connection will be developed by HM Revenue & Customs (HMRC) to submit these notifications. Getting ready for ICS 2 Given the amount of data required and the fact that the ENS has to be submitted for goods going to and transiting the EU, the impact may be more significant than initially anticipated. There are various messages and, given the data that is required, more than one party is likely to have to submit this information under the concept of ‘dual-filing’. The supply chain players will have to decide what data they will supply and then what they expect another party to submit; it is anticipated that there will be variations between the modes. Declaration types For instance the following types of declaration will need to submitted:
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November 2022
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