Tech-led customs and freight forwarding specialist, Zelir Logistics, has warned that ongoing uncertainty around implementation and enforcement of the EU’s new Import Control System 2 (ICS2) is creating unnecessary risk for UK supply chains.
ICS2 – the modernised platform for processing Entry Summary Declarations (ENS) – officially came into effect on January 1, 2026, marking the end of a transition period, and the start of enforcement action for non-compliance. However, the picture across Europe is fragmented, with member states adopting a seemingly inconsistent approach around enforcement.
According to Kent-based Zelir, this is leading to confusion, and even non-compliance in some cases.
“There’s a lot of uncertainty and mixed messaging around this roll-out. We’re getting reports that transporters who haven’t got the documents are not being stopped at the border. Some carriers don’t even know what ICS2 is, and others are not sure what the rules mean,” said Zelir Logistics Director, Joe Jeffery. “As a result, there are many carriers who haven’t implemented ICS2 yet, and when they don’t see it being enforced, it slips further down the priority list.”
‘Non-compliance not worth the risk’
However, with other changes pending, such as the deployment of ELO (the Obligatory Logistics Envelope) for passing through the Smart Border between the UK and the EU at France, Joe is concerned that non-compliance will catch up with businesses sooner rather than later.
“ELO has also been delayed, which adds to the uncertainty, but we know it’s coming, and you won’t be able to get this without ICS2. So one way or another, transporters will need to action ICS2. At the moment, we’re seeing around a 60% ICS2 compliance rate, but we’re advising our clients not to take the risk,” Jeffery (pictured, below) said. “Officially, it’s live and it’s mandatory and every truck should have one, so even though an extra cost may be incurred if paying a third party to complete the ICS2 applications, we’re trying to guide our clients on the right path. This prevents the gamble at the port as to which states will enforce and when, and means transporters will have routines in place when ELO kicks in.”
What is ICS2
ICS2 is an advanced cargo information system designed to boost security in the international transportation of goods. All operators who bring goods through the EU must provide enhanced shipment data to customs, for improved identification of high-risk consignments. The third release of ICS2, implemented on January 1st, applies to road, rail and sea. Information has to be submitted shortly before the goods arrive at the first EU customs office of entry.
Data required includes a detailed goods description, six-digit HS code, transport means and routing, and details of carrier, consignor, consignee, buyer and seller. There’s also the option for multiple filing by different parties.
Zelir Logistics helps firm with all elements of customs compliance, including creating ICS2 submissions on their behalf, and preparing for ELO.
“Of course the uncertainty isn’t helpful, as we shouldn’t have to guess when something will be implemented or enforced. Despite this, we would strongly encourage firms to build ICS2 into their routines now, both to reduce risk of enforcement and to minimise supply chain disruptions caused by the implementation of new systems as much as possible,” concluded Jeffery.
