Key Milestones: Understanding the ICS2 Implementation Timeline
For UK businesses involved in importing or exporting goods to the European Union, keeping up with regulatory changes has become more crucial than ever—especially in the wake of Brexit. One of the most important changes affecting global supply chains today is the introduction of the Import Control System 2 (ICS2).
This ambitious system, introduced by the European Commission, is being rolled out in multiple phases, with significant deadlines and requirements at each stage. Understanding the ICS2 implementation timeline is essential for UK traders who want to stay compliant, avoid delays, and maintain frictionless trade with EU partners.
In this article, we’ll break down the phased rollout of Import Control System 2, highlight key milestones, and offer practical guidance on how UK businesses can prepare for each phase to minimize disruption and ensure seamless operations.
What Is Import Control System 2 (ICS2)?
Import Control System 2, or ICS2, is the EU’s advanced cargo information and safety and security system, replacing the earlier ICS1. It is designed to improve customs risk management and safeguard EU citizens by collecting and analyzing pre-arrival data for goods entering the EU.
At its core, ICS2 requires businesses to submit Entry Summary Declarations (ENS) that include detailed shipment information—such as consignor, consignee, type of goods, transport details, and more—before goods physically enter the EU.
This pre-arrival data allows EU customs authorities to conduct better risk assessments and ensure that dangerous or non-compliant goods are flagged early. ICS2 supports modern supply chains with real-time visibility and data sharing, making it a crucial development in international trade.
Why ICS2 Matters for UK Businesses
Since the UK is now a third country to the EU, all UK exports to the EU are treated as international imports. This means they are fully subject to ICS2 rules. Ignoring the ICS2 requirements can result in customs delays, shipment holds, or even fines.
Whether you’re a freight forwarder, logistics company, retailer, or manufacturer, if your goods move to or through the EU, compliance with Import Control System 2 is mandatory.
ICS2 Implementation Timeline: Key Phases & Milestones
The European Commission designed ICS2 to be rolled out gradually across several years to allow businesses and customs authorities to adapt. Below is a breakdown of the phased implementation:
Phase 1: Express Carriers and Postal Operators (Launched March 15, 2021)
Scope:
Applies to postal and express carriers transporting goods by air.
Focus on shipments entering the EU requiring pre-loading and pre-arrival risk assessments.
Requirements:
Submission of pre-loading advance cargo information (PLACI).
Basic ENS data before loading cargo onto aircraft bound for the EU.
What UK Businesses Should Do:
If you use express couriers or postal services to send goods to the EU, ensure your shipping partners are ICS2 compliant.
Provide accurate product descriptions and HS codes at the time of booking to support early data submission.
Phase 2: General Air Cargo (Launched March 1, 2023 – Gradual Rollout)
Scope:
Expanded to include all air freight, including freight forwarders, logistics providers, and airlines.
Introduced more granular data requirements.
Requirements:
Full ENS filings for all air cargo shipments.
Shared responsibility among multiple actors in the supply chain (e.g., house-level and master-level data).
Key Deadlines:
March 1, 2023: Start of rollout.
Rolling deployment through 2023–2024 depending on operator readiness.
What UK Businesses Should Do:
Coordinate with your freight forwarders and air carriers to clarify who is submitting ENS data.
Update internal systems to generate and share data in formats compatible with ICS2.
Ensure your IT team understands how to connect with the Shared Trader Interface (STI).
Phase 3: Maritime, Road, and Rail (Planned for March 2025)
Scope:
Extends ICS2 requirements to sea freight, road transport, and rail shipments.
Includes logistics operators, shipping lines, and other multimodal carriers.
Requirements:
Full ENS filings similar to air cargo.
Multi-filer approach continues, requiring collaboration between supply chain actors.
What to Expect:
This phase marks the full activation of Import Control System 2 across all transport modes.
Significant impact on UK exporters using ferries, RoRo transport, and container shipping to the EU.
What UK Businesses Should Do:
Begin preparing now if you move goods via sea, rail, or road.
Update contracts and service level agreements (SLAs) with logistics partners to ensure ENS compliance.
Participate in testing and pilot programs if offered by logistics providers.
Practical Guidance for UK Businesses
To avoid disruption and maintain competitiveness, UK companies should take the following steps for each ICS2 phase:
1. Map Your Trade Flows
Understand how your goods enter the EU and through which transport modes. Identify which shipments fall under ICS2 requirements.
2. Clarify Filing Responsibilities
Determine who in your supply chain (you, your carrier, or your logistics provider) is responsible for ENS submission. Miscommunication can lead to costly delays.
3. Train Your Teams
Educate your logistics, compliance, and export departments on ICS2 filing requirements and timelines. Ensure everyone understands the role of quality data.
4. Improve Data Quality
ICS2 demands detailed and accurate data. Work on your internal data systems to ensure product descriptions, HS codes, and routing details are complete and standardized.
5. Invest in Technology
Connect to the EU’s Shared Trader Interface or ensure your logistics partners have robust APIs and automated systems for ICS2 compliance.
6. Test Early
Engage in voluntary compliance pilots or simulations offered by customs authorities or logistics companies. Early testing can smooth the transition.
Potential Risks of Non-Compliance
Failing to meet ICS2 obligations can result in:
Shipments being delayed or rejected
Additional customs scrutiny
Higher operational costs
Damage to customer relationships and brand reputation
Proactive preparation is the key to mitigating these risks.
Final Thoughts
The Import Control System 2 rollout is a significant shift in how goods are moved and cleared into the European Union. For UK businesses, it presents both a challenge and an opportunity. By understanding the ICS2 implementation timeline and preparing for each phase, companies can ensure compliance, reduce delays, and maintain strong trade relationships with the EU.
As the 2025 maritime and land transport phase approaches, now is the time to act. Investing in compliance today will pay dividends tomorrow. For tailored support and hands-on help with ICS2 compliance, we recommend working with Customs Declarations UK—experts in EU-UK trade documentation and customs clearance.
Author Profile:
(David Hawk)
David Hawk is an Expert in Customs Declarations Services having 7+ years of experience in this industry.
