ICS2 Phase 3: What Importers & Exporters Need to Know Before the September 2025 Deadline

At Future Forwarding, we make it our mission to keep our clients informed about upcoming regulatory changes that may impact the flow of goods through global supply chains. Whether you are seeking advice on customs concerns, airfreight procedures, ocean freight management, road freight strategies, imports handling, exports processes, or navigating ICS2 regulations, we are here to help.

The Import Control System (ICS), and more recently ICS2 (Import Control System 2), is an EU-wide customs pre-arrival security program. It aims to collect data about goods entering the EU before they arrive, for safety and security risk analysis. ICS2 is being rolled out in phases, each focusing on different types of operators and transportation modes.

Phase 1 – Air Express and Postal Pre-loading (March 2021)

Who it affects: Express carriers and designated postal operators (under UPU regulations) transporting goods by air into the EU.

What’s required: Submitting a minimum dataset called Pre-loading Advance Cargo Information (PLACI) before loading at the airport of departure.

Why: To enable early security risk assessment before goods are loaded onto the aircraft bound for the EU.

Phase 2 – Air Cargo and General Air Transport (March 2023)

Who it affects: All air cargo general transport operators, freight forwarders, logistics providers, and postal operators (beyond PLACI)

What is required?

  • A complete Entry Summary Declaration (ENS) dataset, including detailed information from multiple supply chain actors.
  • Ensures a multi-filer approach, where different parties provide segments of the ENS.

Why: Allows customs to assess risks more comprehensively across the full air supply chain.

What’s Changing in Phase 3?

Phase 3 – Maritime, Road, Rail, and Remaining Postal Flows (Starting March 2024 and ongoing into 2025)

Phase 3 marks the final rollout of ICS2 and comes into force in September 2025. It extends mandatory requirements to various sectors, including airfreight, sea freight, rail, and road freight carriers, reflecting the comprehensive scope of freight management and its linkage to customs regulation.

Who it affects: Operators in sea, inland waterways, rail, and road transport, including remaining postal and express shipments not yet covered.

What is required?

  • Filing ENS for all modes of transport, including deep sea, short sea, and land modes.
  • Alignment with new business rules and data requirements under ICS2..

Rollout Schedule: Gradual onboarding from March 2024 through to 1st October 2025, with deadlines depending on the operator type and Member State readiness.

Why It Matters for Your Business

If you’re importing into or transshipping through the EU, ICS2 compliance will be essential. Incomplete or late filings can result in significant issues involving customs delays or freight blockages risking exports and imports.

  • Delays at customs
  • Shipments being held or rejected
  • Fines and potential reputational damage

How Future Forwarding Can Help

Our team is already working with clients to ensure readiness for ICS2 Phase 3, covering all aspects, from customs to various freight types such as airfreight, ocean freight, and road freight. We offer:

  • Guidance on data accuracy and ENS requirements
  • Pre-shipment compliance checks
  • System integration support for timely data submission

We’ll make sure your business stays ahead of the curve so you don’t face disruptions or penalties.

If you’d like to speak with our team about ICS2 or review your compliance strategy, get in touch with us today.

Update: 20 May 2025

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