EU ICS2 Release 3 for Maritime: Prepare for Compliance! 

Attention, maritime and inland waterways house-level filers! 

The European Union’s (EU) Import Control System 2 (ICS2) is transforming the way pre-arrival customs data is handled for goods entering the EU. From 1 March 2024, maritime and inland waterway carriers, freight forwarders, and house-level filers must comply with new Entry Summary Declaration (ENS) data requirements to ensure the smooth clearance of shipments.

By mandating the submission of accurate and complete ENS data prior to arrival, ICS2 enables customs authorities to better assess the risks associated with incoming goods, thereby improving the EU's ability to prevent and combat customs offenses and ultimately ensuring a safer and more secure trade environment. 

If you are responsible for submitting house-level shipment data for goods moving via sea or inland waterways to the EU, it is essential to ensure your operations align with the new ICS2 requirements to avoid disruptions at EU borders. 

Key steps to ensure compliance: 

• Update Your Business Processes: Align with ICS2’s data submission requirements. 
• Submit timely and accurate ENS data: Incorrect or missing information could result in delays, penalties, or goods being stopped at the border. Have conversations with your clients at the earliest possible opportunity to ensure that you receive the required information under the house-level filing data set in a timely manner. 

Failure to comply may result in cargo delays, penalties, or cargo not being cleared for entry into the EU. 

Multiple Filing  

Multiple filing provides the possibility for more than one partial ENS filing to be submitted by different actors in the supply chain. Freight forwarders can therefore file house-level information directly with the authorities, which complements the master-level data submitted later on. As an example, ocean carriers would submit an ENS composed of master-level data, while freight forwarders would file another ENS with house-level data linked to the corresponding ENS with master-level data.

There are a number of advantages of multiple filing, such as preventing delays for customs, and alleviating supply chain disruptions by submitting filings at the earliest possible time. Most importantly, multiple filing allows to safeguard commercially sensitive information from other parties.  

There are instances where carriers mandate that freight forwarders issuing house bills of lading file house-level data themselves or through an IT service provider. In such cases, multiple filing is not merely an option for freight forwarders, but a requirement to maintain their business relationship with ocean carriers.  

The FIATA Bilateral Model Agreement for Multiple Filing developed for the ICS2 Release 2 for air could provide a template to clarify the roles and responsibilities of each party, notably in case of disruptions or technical issues. Work is currently ongoing to develop a dedicated version tailored specifically for Release 3 for maritime. 
 

👉 Useful links for further guidance: 

• ICS2 Factsheet for maritime – A detailed overview of maritime-specific requirements. 
• The EU eLearning Module for maritime – Step-by-step training to support compliance. 
• Factsheet on Multiple filing - Multiple filing of an entry summary declaration (ENS). 
• FIATA-CLECAT ICS2 Maritime Guidance – Best practices for freight forwarders handling maritime shipments, developed by FIATA and the European Association for Forwarding, Transport, Logistics and Customs Services (CLECAT). 

Take action now to prevent trade disruptions—prepare for ICS2 today!