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1^st of April marked a significant milestone on the deployment of Import Control System 2, with the end of the deployment window for maritime house-level filers, which are mandated to connect to ICS2 and submit entry summary declarations (ENS), filings for shipments they handle. This date also marks the beginning of the deployment window for road and rail transport, which will end on 1^st September 2025.

Over the last months, CLECAT has supported European freight forwarders to prepare for the implementation of ICS2 in all modes of transport, and report back on authorities, including the European Commission on potential issues and room for improvements. However, despite preparation, freight forwarders have encountered significant challenges in implementing ICS2. Technical complexities have posed considerable obstacles, particularly regarding system integration and compatibility with new ICS2 requirements. The level of support from National Authorities' Help Desks has often been insufficient or delayed, complicating efforts for timely compliance. Also, freight forwarders choosing to perform single filings with shipping lines have faced further operational difficulties, including the absence of electronic messaging systems capable of transmitting house-level data to carriers. This shortcoming has resulted in delays due to extended timelines enforced by carriers and, in some cases, operational disruptions including the refusal to load cargo.

Registering as house-level filers with National Customs Authorities (NCAs) has also been challenging for forwarders, with unclear instructions regarding deployment windows and difficulties in establishing effective communication with authorities. Further hurdles identified includes difficulty sourcing reliable technical resources and IT service providers. To help mitigate these issues, CLECAT has urged the European Commission to publish an authoritative list of IT service providers registered for ICS2, similar to the UK's HMRC practice. In some regions, such as France, forwarders face limited choices with only two customs-approved IT service providers available, and no information on potential new certified providers.

Specific concerns have emerged from forwarders engaged in Ro-Ro traffic. Operational systems are not yet fully functional, leading to inconsistencies in data submission. Moreover, ferry operators often apply maritime requirements for ICS2 data despite Ro-Ro traffic typically aligning with road freight regulations. Additionally, the absence of clear direction for Ro-Ro traffic in the Union Customs Code (UCC) Work Programme has led to varying timelines across Member States, creating significant operational inconsistencies.