Policy & Compliance
The European Union’s Import Control System 2 may have more potential to cause disruption in both the UK and the EU than was experienced with the previous iteration ICS2 brings new road and rail concerns
and take necessary precautions. And although we do not expect many UK-based forwarders and Customs agents to lodge ICS2 declarations themselves, it may be worth mentioning that XI (Northern Ireland) EORIs are recognised as EU EORIs and may be used for the purpose of lodging an ENS in the EU. A practical consideration to bear in mind. Obligatory Logistics Envelope In addition to ICS2, it is important to mention that the Obligatory Logistics Envelope (ELO) will be introduced from 1 April in France, and this is not a mere coincidence. The ELO, a system that builds on the original statutory instruments related to Brexit, is designed to hold all information about a movement, including an ICS2 MRN reference. The ELO will therefore become a tool to control all statutory requirements for imports and export into and out of France. Although neither system is required for entry into or exit from the UK, we would encourage Members to review their operations and where necessary put the right measures in place. More information can be found by scanning the QR codes here:
F rom 1 April 2025, the European Union’s Import Control System 2 (ICS2) will be implemented for rail and road movements, requiring carriers to provide pre- arrival data on goods sent to or through the EU prior to their arrival. The ICS2 requirements will apply to standard cargo but also to postal and express operators. Potential disruption ICS is not a new system and the requirement to lodge an Entry Summary Declaration (ENS) for goods travelling from the UK to the EU has been in place since the UK left the union. Its second iteration, ICS2, has also already been in use for air and maritime consignments for some time, but this release of ICS2 may have more potential to cause disruption in both the UK and the EU than was experienced with other modes. And this is not simply because ICS2 declarations require more data, some of which may be viewed as commercially sensitive and may not be readily available to the carrier. It is mostly because the carrier for road transport is a vehicle operator,
commonly not accustomed to a requirement of this kind. The experience from our own backyard (a requirement to lodge an ENS for goods imported from the EU came into force on 31 January 2025), which we cover in an article on page 8 of this issue, teaches us that hauliers are often not aware of the legal requirement to lodge an ENS. The majority do not have access to the required data and even fewer operate software that can submit information to ICS2. All this may amount to a confused operation where carriers, freight forwarders, importers, etc, do not communicate in an efficient manner and as a consequence face delays, charges and simple frustration in the supply chain. Having considered the above and the fact that ICS2 allows for multiple filing whereby other parties may lodge house-level data, we expect that a UK freight- forwarder may on occasion be involved in ICS2 safety and security declaration submission. BIFA therefore advises Members to liaise with their partners in the EU and ensure that all parties are aware of the changes from 1 April
“ BIFA therefore advises Members to liaise with their partners in the EU and ensure that all parties are aware of the changes from 1 April and take necessary precautions
European Commission – ICS2 extends to rail and road
Douane.gouv.fr
20 | March 2025
www.bifa.org
Made with FlippingBook Annual report maker