Road transport under ICS2: who is responsible for the ENS and how to avoid rejection

ICS2 is the EU's advance cargo information system. Data from the entry summary declaration, or ENS, is used by customs authorities to carry out safety and security risk analysis before goods arrive in the EU customs territory. The requirement applies to goods entering the EU or transiting through its territory from a third country. It should not be confused with ordinary intra-EU transport.

Release 3 requirements for road transport took effect on 1 April 2025. Following the deployment period and temporary derogations, the European Commission states that from 1 June 2026, every consignment entering the EU should have a valid ENS filed directly in ICS2 or, in countries using the NCTS-P6 option, complete ENS data included in a combined transit declaration.

In practice, this means that transport preparation begins well before the vehicle approaches the border. The data required for risk analysis may be held by different parties, including the carrier, freight forwarder, exporter, importer and sometimes other intermediaries.

If responsibility for collecting and submitting this information is only established after loading, there may be very little time left to fill in missing data or correct errors.

Who is responsible for filing the ENS?

As a general rule, responsibility lies with the carrier bringing the goods into the EU customs territory. This does not mean, however, that the carrier always holds all the legally required information.

When some of the information is held by another supply chain participant, such as a freight forwarder, importer or consignee, two filing models are possible:

• Single filing - one party submits a complete ENS containing all required information.
• Multiple filing - several parties submit linked parts of the ENS which together form a complete declaration.

Multiple filing requires a prior agreement defining who will submit each dataset and by when.

Simply assuming that "the customs agent will take care of it" does not provide a clear allocation of responsibilities. Before the transport begins, it should be clear who holds the required information and who is responsible for submitting it.

How does multiple filing work in practice?

Multiple filing can be useful when the carrier holds the master transport data but does not have detailed information at house consignment level or commercial data concerning the buyer and seller.

For the system to link partial filings, the parties involved must exchange the relevant identifiers in advance. The official ICS2 FAQ specifically refers to the EORI numbers of the carrier and the party submitting house-level data, as well as the transport contract number used to link the filings.

This is where one of the key operational risks arises. Each part may be submitted successfully, but if the data used to link the filings is inconsistent, the partial filings may not be linked correctly.

The person coordinating the transport therefore needs more than confirmation that the data has been sent. They should also have confirmation that the filings have been correctly accepted and linked.

Data that needs to be collected before departure

The exact fields required depend on the business model and type of filing. An operational checklist should, however, cover at least the following groups of data:

• identification of the declarant and relevant parties, including the correct EORI numbers,
• carrier and means-of-transport details,
• customs office of first entry and planned route,
• transport document and contract references used to link the data,
• consignor, consignee, buyer and seller where required,
• a precise goods description, number of packages, packaging type, weight and required commodity codes,
• information at the correct consignment level, without impermissibly combining different goods under a generic description.

The goods description should allow customs authorities to carry out a risk assessment. Terms such as "parts", "industrial goods", "accessories" or "materials" may be too general.

The information should also be consistent with the commercial invoice, packing list, transport document and customs instructions.

Five quality checks before submitting the ENS

1. Completeness check

Check whether all required fields are available for the relevant message and transport model. Technical validation does not replace an assessment of whether the information is substantively complete.

2. Cross-document consistency check

The goods description, number of packages, weight, transaction parties and reference numbers should be consistent across the invoice, packing list, CMR, transport order and ENS.

A discrepancy identified before departure is a correction. The same discrepancy identified at the border may result in a delay.

3. Linking identifier check

In multiple filing, EORI numbers and references used to link the filings must be consistent across all parties submitting data.

It is worth establishing a single format for reference numbers and reducing the risk of individual participants manually modifying them.

4. Status check

The process does not end when the message is submitted.

Its acceptance, any requests for additional information, rejection and subsequent status should be monitored. Incomplete or incorrect data may lead to additional questions, corrections or delays in the entry of the goods.

5. Timing check

The person responsible for the process should know when the complete ENS needs to be ready and allow enough time for potential corrections.

Collecting missing commercial data only when the driver is already on the way to the customs office of first entry significantly reduces the time available to respond to any issues.

ICS2 or NCTS-P6?

In some countries, ENS data for road and rail transport can be submitted together with the transit declaration in NCTS-P6.

This option depends on implementation in each country, and the status of individual countries may change. The European Commission publishes an up-to-date NCTS-P6 State of Play table.

Companies should therefore not assume that the same filing model applies at every border. Before the transport begins, it is worth checking:

• the country of first entry,
• the current ENS filing model in that country,
• whether the combined declaration contains the complete dataset,
• who is responsible for return messages and any necessary corrections.

If a country does not use the relevant NCTS-P6 option, a separate ENS in ICS2 is required.

With ICS2, the data needs to be ready before departure

ICS2 does not begin when the vehicle reaches the border. In practice, the most important part of the process takes place earlier, when the data is collected and verified and responsibility for submitting it is established.

With single filing, the complete dataset is submitted in one declaration. With multiple filing, information may come from several supply chain participants, but the different parts must be correctly linked to form a complete ENS.

From a transport planning perspective, the key elements are therefore collecting the necessary information early, clearly allocating responsibilities and checking the filing status before the vehicle reaches the border.

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This article is for informational purposes only. Requirements and arrangements concerning ICS2 and NCTS-P6 may change, so the latest rules and guidance from the European Commission and the relevant customs authorities should be verified before transport.