Policy & Compliance
response, the Commission is advising member states to apply a temporary non-enforcement period, giving affected operators additional time to adjust. This grace period would allow freight forwarders and other stakeholders to fine-tune their systems, complete technical integration and strengthen internal processes without the immediate risk of penalties or shipment delays. At the time of writing this article, no official announcement has been made on the grace period. BIFA will keep Members updated with the latest developments via the usual communication channels. Based on the above information, Members operating in haulier/carrier capacity or planning to submit ICS2 (house/master) information are advised to check whether they are affected. If so, ensure you are fully ready when enforcement and full compliance obligations come into force on 1 September 2025. Useful links Additional information and support are available via the following links: • EU - TAXUD ICS2 Website: https://taxation- customs.ec.europa.eu/customs/ customs-security/import- control-system-2_en includes the process of application, set- up and self-conformance testing • Guidance on how to make ICS2 declarations: https://www.gov.uk/guidance/ make-an-entry-summary- declaration-using-the-import-c ontrol-system-2 • TSS – ICS2 Webinar: https://www.nicustomstradeaca demy.co.uk/video/introducing- changes-to-the-entry-summar y-declaration-due-to-ics2/ Further questions relating to ICS2 can be sent to the ICS Helpdesk: ics.helpdesk@hmrc.gov.uk Northern Ireland related enquiries can be sent to the NI stakeholder engagement team: nistakeholderengagementteam@h mrc.gov.uk
Belfast docks where from 1 September all Entry Summary Declarations for goods must be submitted through ICS2
relatively straightforward via the UK Government Gateway, ICS2 requires traders to register via the EU’s Customs Trader Portal, complete a technical setup, and undergo self-conformance testing before filing is permitted. This makes the ICS2 implementation process more resource intensive. Core data Both systems require similar core data, such as six-digit commodity codes, consignor/consignee details, gross mass and transport references, but ICS2 demands additional data elements and EORI numbers, particularly where multiple parties are involved in the filing process. Freight forwarders might encounter potential operational and commercial challenges with ICS2 implementation. The main cause may stem from potential uncertainty over filing responsibilities between carriers, forwarders and other actors in the supply chain, particularly with the introduction of multiple filing where both master-level and house-level data may be submitted separately. We are also aware of certain forwarders’ desire to submit their own house-level information to protect sensitive commercial data. However, we are noticing a growing trend where Members are instructed by the carriers to submit that information.
Another challenge freight forwarders may have to prepare for is the introduction of the French Obligatory Logistics Envelope (ELO) system, which will become mandatory in alignment with the full implementation of ICS2 on 1 September 2025. Under the ELO system, French Customs will require that an ICS2 reference number is declared and linked to each shipment before arrival. This means that freight forwarders operating through French ports must ensure their ICS2 filings are completed accurately and in good time, and that the reference number is correctly associated with the ELO envelope. Failure to comply could result in customs delays, port congestion, or even refusal of entry. The combined implementation of ICS2 and ELO adds operational complexity, particularly for those using multiple filing, and highlights the need for robust internal coordination and early alignment with both ICS2 and French customs procedures. Grace period? We are hearing comments from the EU that the European Commission is aware of the operational complexity and challenges associated with the implementation of ICS2, particularly for maritime and road carriers and house-level filers. In
“ Another challenge freight forwarders may have to prepare for is the introduction of the French Obligatory Logistics Envelope (ELO) system
August 2025 | 19
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