09 January 2026

ICS2 TRANSITION FOR ROAD TRANSPORT

The deployment of the European Union’s Import Control System 2 (ICS2) has entered a critical phase for road transport. For a number of Member States, a temporary derogation had been in place from 1 September 2025 until 31 December 2025, allowing ENS declarations for road and rail traffic to be lodged using means other than ICS2. This derogation applied to Ireland, Greece, Spain, France, Italy, Lithuania, Hungary, Finland and the United Kingdom (for Northern Ireland). The derogation has now expired, meaning that from 1 January 2026 ICS2 applies fully and without exception in these countries.

A further group of Member States including Croatia, Latvia, Poland, Romania and Slovakia will follow on 1 June 2026. There is no enforcement grace period, and operators that are not ready risk border delays, disruptions to supply chains and potential penalties.  Several Member States, including Austria, Germany and Denmark, have already been applying ICS2 for road transport since September 2025.

ICS2 is intended to strengthen pre-arrival security by requiring the submission of complete and high-quality shipment data prior to entry into the EU, enabling customs authorities to carry out advance risk analysis. For road transport operators and logistics service providers, this means that each individual consignment must be covered by a separate ENS, lodged within strict timelines before arrival at the external EU border. Ensuring the timely collection and accuracy of data from all supply chain partners is therefore essential.

Following strong advocacy from CLECAT, the European Commission is now working on the development of a multiple-filing functionality for road transport under ICS2. This functionality would allow different parties in the supply chain to contribute data elements to a single ENS, better reflecting operational realities. However, this solution is only expected to become available in the second half of 2026. Until then, single filing remains mandatory.

CLECAT continues to work closely with the European Commission, national authorities and industry partners to ensure that ICS2 implementation takes account of operational constraints and does not lead to unnecessary bottlenecks at EU borders.