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ICS2 Phase 3 Complete: All EU Transport Modes Now Require Pre-Arrival Customs Declarations

Phase 3, completed 1 June, extends the Entry Summary Declaration requirement to road and maritime freight. The rollout that started in 2021 is now fully in force.

In This Article

01What ICS2 Phase 3 changes
02What an Entry Summary Declaration requires
03Who files the ENS — carrier or brand?
04Which freight arrangements are most at risk
05How to verify your 3PL is compliant

Key Takeaways

►Phase 3 complete: all EU transport modes now covered
►Road and maritime freight now require pre-arrival ENS
►Filing responsibility sits with carrier or forwarder
►Confirm your logistics partner is filing correctly now

ICS2 Phase 3 completed on 1 June 2026, extending the EU's pre-arrival customs declaration requirement to road and maritime freight. All shipments entering the EU — by air, road or sea — now require an Entry Summary Declaration (ENS) filed before arrival. The rollout that began in 2021 is complete.

1 Jun 2026 ICS2 Phase 3 completion date — road and maritime freight now covered alongside air (Source: nShift)

The Entry Summary Declaration is filed by the carrier or freight forwarder before the shipment reaches the EU border. It provides customs authorities with advance visibility of inbound consignments: the shipper, the consignee, the goods description, and the route. For brands working with major carriers and established freight forwarders, Phase 3 creates no operational change. Their systems have been filing ENS declarations for air freight since the earlier phases, and road and maritime extension is handled at the carrier level.

The risk sits with brands using smaller or legacy freight arrangements. For these operators, it is worth a direct confirmation with the freight partner that ENS filing is in place for all EU-bound road and maritime shipments. A shipment arriving at the EU border without a prior ENS risks customs holds or rejection. The filing responsibility sits with the carrier or freight forwarder, not the brand, but the operational and commercial consequences of a hold fall on the consignment.

ICS2 is part of a broader EU customs modernization that also includes the €3 flat-rate duty from July 1 and the EU Customs Data Hub transition to full tariff-rate duties by 2028. Together, these changes give EU customs authorities more advance data on inbound shipments than at any point in the system's history. For brands building logistics infrastructure for EU expansion, compliance at every layer of this system is now a baseline requirement.

  • ICS2 Phase 3 completed 1 June 2026 — road and maritime freight now require pre-arrival ENS filing
  • All EU transport modes now covered: air (since 2021-2023 phases), road and maritime (from June 2026)
  • ENS is filed by the carrier or freight forwarder — brands should confirm their logistics partners are compliant
  • Non-compliant shipments risk customs holds or rejection at the EU border

If your freight forwarder or 3PL is handling EU-bound road or maritime shipments, ask them directly: are you filing ENS declarations for all consignments before arrival?

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The bigger picture

EU pre-arrival visibility is now universal across all modes

ICS2 represents the EU's move to full pre-arrival customs visibility across every mode of entry. It runs alongside the €3 duty regime and the Customs Data Hub transition as part of a broader EU customs modernization. Together, these changes mean EU customs authorities have more advance data on inbound shipments than at any point in the system's history — and non-compliant or incomplete declarations get flagged earlier in the process.

  • Ask your freight forwarder or 3PL for written confirmation that ENS declarations are being filed for all EU-bound road and maritime shipments
  • For any new logistics arrangements, include ICS2 Phase 3 compliance as a vendor requirement in your freight contracts
  • If you're moving to EU in-market stock, your inbound bulk shipment from the US triggers the same ENS requirement — confirm the filing process with your carrier before dispatch

ICS2 Phase 3 Completion

Road and maritime freight added to EU pre-arrival ENS requirement — completing the rollout that began with air freight in 2021

1 Jun 2026

Source: nShift / European Commission

Transport Modes Now Covered

Air (since 2021-2023), road and maritime (from June 2026) — all EU entry routes now require a pre-arrival Entry Summary Declaration

All 3

Source: European Commission ICS2

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