ICS2 IN FORCE FOR RAIL AND ROAD OPERATORS BUT FRAGMENTED ROLLOUT
From 1 September 2025, new EU customs rules took effect for goods entering the EU by road and rail. Carriers moving goods through certain Member States will now have to submit Entry Summary Declarations (ENS) through the Import Control System 2 (ICS2) before the goods arrive. This applies regardless of where the company is registered.
The countries that will apply the new rules immediately are Bulgaria, Cyprus, Czechia, Denmark, Estonia, Germany, Greece, Malta, the Netherlands, Portugal, Slovenia and Sweden. In these Member States, the old systems (ICS and NCTS P5) can no longer be used, and fallback procedures will not be accepted. Carriers who are not ready must either use the ICS2 online portal or appoint a representative to lodge the ENS on their behalf. Postal consignments are also covered by the new rules.
In some Member States that have introduced a new version of the transit system (NCTS Phase 6), the required safety and security data may be included in the transit declaration itself, removing the need to lodge an additional ENS. However, in countries where this option is not available, an ENS must always be lodged separately in ICS2. The Commission has published a table showing which countries are ready and which have requested more time. While some will enforce the rules from 1 September, others have been granted extra months – in some cases until mid-2026 – creating a patchwork of different obligations. This lack of alignment creates real challenges for operators. A single truck journey crossing several borders may require multiple ENS filings in different systems. Land borders, unlike ports or airports, have limited physical capacity, so even small delays can cause long queues and congestion.
CLECAT has raised concerns that this fragmented rollout could cause serious disruptions at EU borders. In a recent press release, CLECAT called on the Commission to introduce a six-month grace period to allow businesses more time to adapt, similar to what was granted for the air and maritime sectors. The International Road Transport Union (IRU) issued a parallel statement, warning that the inconsistent implementation creates legal uncertainty and risks major bottlenecks. Both organisations stress that without better alignment, road and rail operators face significant disruption to the flow of goods into the EU.