ICS2 Release 3
– A Game Changer for Road & Rail Freight 

The countdown is over: on September 1st 2025, the European Union launched the next phase of its Import Control System 2 (ICS2). From this date, all road and rail carriers moving goods into or through the EU are required to submit pre-arrival data before crossing the border. 

What Challenges Will Carriers Face Under ICS2 Release 3?

With stricter data requirements and a new single EU interface, rail and road carriers must navigate several challenges, including:   

  • Managing Complex Data Requirements – Gathering precise and complete shipment data is now more critical than ever. 

  • Ensuring System Compatibility – Existing IT systems must integrate with the new EU interface to ensure smooth data transmission.

  • Avoiding Delays and Penalties – Non-compliance can result in shipment delays, fines, or even refusal of entry into the EU.

  • Coordinating with Multiple Stakeholders – Since the data may come from various parties it is important to coordinate with the various stakeholders and share data with recipients in the EU so it can be used during the import process.

  • Increased Operational Costs – With new compliance requirements, businesses may experience a rise in administrative and technological costs associated with updating systems and training personnel.   

What will happen if you are not ready in time?   

Goods will be stopped at the EU Customs borders 

The goods in question will not be cleared by the customs authorities 

Inadequate declarations may be rejected or face intervention with possible sanctions

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However, HMRC has now confirmed that several Member States, including Ireland, France, Spain, and others, will continue to accept both ICS and ICS2 declarations for road traffic until 31 December 2025 under the ICS2 Release 3 derogation. From January 1st 202, only ICS2 Entry extension: Belgium, Germany, and Netherlands, for example, have required ICS2 declarations since September 1st 2025. That means if your goods first enter the EU via a non-derogation country, ICS2 rules already apply. 

Deployment Window

ICS2 Release 3 went live on 1st September 2025, but not every EU Country applied for a derogation. Some will still accept both ICS and ICS2 declaration until 31st December 2025, while others require ICS2 right now. If your goods enter through a country without derogation, an ICS2 ENS is already mandatory. One wrong border crossing could result in rejected entries, costly delays, and serious compliance risks.   

1st of September 2025

ICS2 Release 3 went live

31st of December 2025

Derogation period ends - From 1st on January 2026, ICS2 will be the only valid system to use across the EU.

For full details, including country-specific derogations, see the European Commission guidance on ENS submission during the ICS2/NCTS P derogation period. 

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What steps should carriers take to prepare for ICS2 Release 3? 

To ensure smooth compliance with ICS2 Release 3, rail and road carriers should:

  • Evaluate Current Data Management Systems – Identify any gaps in your existing customs declaration process.

  • Train Staff on the New Requirements – Ensure all relevant personnel understand the changes and how to use the new system effectively.

  • Test and optimise processes - Run controlled tests of your systems and data submissions to uncover issues early and refine your workflows. The official deployment window for ICS2 Release 3 ran from 1st April – 1st September 2025, and carriers must request their preferred slot at least one month before their planned go-live. Although some Member States have extended the use of ICS until 31st December 2025 under the derogation, this should not be seen as a reason to delay. Using the deployment window to actively test and fine-tune operations will reduce the risk of disruptions and ensure a smooth transition when ICS2 becomes the only option from 1st January 2026. 

  • Engage with a Trusted Customs Partner – Work with established providers like Descartes to ensure a seamless transition and long-term compliance.

  • Obtain an Economic Operators Registration and Identification (EORI) number: Register with the customs authority of an EU Member state to receive an EORI number.

  • Implement a Cloud-based Customs Solution – Choose a software provider that offers full integration with ICS2 and can handle the new data requirements.

Talk to one of our experts about implementing a cloud-based customs solution today.

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