ICS2 Road & Rail Release 3 is Now in Operation

What You Need to Know

Truck driving on roadTruck driving on road

The landscape of EU customs and trade has undergone a significant change. As of 1 September 2025, the EU’s Import Control System 2 (ICS2) is fully operational for road and rail shipments under Release 3, marking the completion of the ICS2 rollout across all transport modes.

All goods entering or transiting the EU are now subject to the updated ICS2 rules. This means businesses are now required to submit an Entry Summary Declaration (ENS) with complete and accurate data before goods arrive at the EU border. Failure to comply can lead to significant delays, penalties, or refusal of entry for your goods.

Key Requirements of ICS2 Release 3

Road & Rail

This new phase has introduced immediate obligations that businesses and freight forwarders must now adhere to:

  1. EU Imports and Transit: All shipments by road and rail must now be pre-declared in ICS2.
  2. Movements from GB to the EU: Procedures are now in effect and vary by the specific EU Member State of entry. Businesses must closely coordinate with their hauliers and freight forwarders to ensure they are prepared for the local requirements of their entry point.
  3. Movements from GB to Northern Ireland: The legacy ICSNI system can be used until 31 December 2025. However, from 1 January 2026, the full ICS2 dataset and its rules will become mandatory for all declarations.
  4. HMRC Guidance: Businesses must now be actively liaising with their supply chain partners to avoid any disruption to their operations. Proactive preparation and clear communication are key to ongoing compliance.

Understanding ICS2 and the NCTS-P6 Link

ICS2 is closely linked to the New Computerised Transit System (NCTS-P6). This relationship is critical, as Member States have adopted one of two approaches:

  • Opt-in Countries: These countries allow the ENS data to be included directly in the transit declaration. This creates a more streamlined process, requiring only one filing. E.g., Romania has opted in.
  • Opt-out Countries: These countries require a separate ENS filing in ICS2 in addition to the transit declaration. The UK is currently an opt-out country.

Businesses must always confirm the approach of the country they are operating in to prevent duplicate or missing filings, which can now result in delays and non-compliance fines.

The ELO Brexit Smart Border System

What you need to be aware of

In addition to ICS2, freight operators using the UK-France corridor must now be aware of the ELO (Enveloppe Logistique Obligatoire) system.

  • The ELO system groups multiple customs declarations under a single barcode, which improves border security and reduces waiting times at the Brexit Smart Border.
  • While ELO has been live on a voluntary basis since April 2025, it is expected to become mandatory from 1 January 2026, aligning with ICS2.
  • Whilst the current use is still limited, operators are strongly encouraged to adopt ELO now, both for empty and full movement trucks, to ensure smoother and faster border processes. 

Key Dates to Remember

Now in effect

ICS2 Release 3 is mandatory for all road & rail shipments into/transiting the EU.

Get Ahead with ICS2
31 December 2025

Last day to use the legacy ICSNI system for GB to NI movements.

NI Movement Insights
1 January 2026

The ICS2 dataset becomes mandatory for all NI declarations, and ELO is expected to become mandatory.

Register to use ICS2

Frequently Asked Questions

It is the final stage of the EU’s Import Control System 2 rollout, which is now mandatory. It requires all road and rail shipments into or transiting the EU to file an ENS declaration before arrival.

Yes. ICS2 applies to all goods entering the EU, regardless of origin. Procedures are now in place and vary by Member State, so local rules must be checked to ensure compliance.

The legacy ICS NI (Northern Ireland) system can be used until 31 Dec 2025. However, from 1 Jan 2026, the full ICS2 rules and dataset will replace ICS NI.

Some Member States (e.g., Romania) are opt-in, allowing a single combined filing. Others (including the UK) are opt-out, which requires a separate transit declaration and a dedicated ICS2 ENS filing.

ELO is expected to become mandatory from 1 January 2026. However, its use is already highly recommended to streamline border processes and avoid potential delays.

Need expert help with ICS2 compliance?

The new rules are in effect, and maintaining a smooth supply chain requires a proactive approach.

Contact your local ALS specialist today for guidance on ENS filings, NCTS-P6, and ELO implementation. 

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