As the maritime industry gears up for Import Control System 2 (ICS2) Release 3, which went live on 3rd June 2024, it is crucial for sea freight forwarders to begin preparations now if not already doing so. The EU, along with Switzerland and Norway, is implementing this advanced customs cargo safety and security program to ensure enhanced risk-based customs controls. With the deadline to request a deployment window for maritime house-filers set for 1st November 2024, forwarders must be proactive in meeting the new requirements to avoid delays and maintain control over their data.
Here's what you need to know to prepare effectively for ICS2 Release 3:
1. Understand the New Data Requirements
ICS2 introduces stringent data filing requirements for all sea freight shipments into or via the EU, Switzerland, and Norway. Forwarders must submit detailed Entry Summary Declarations (ENS) electronically, providing comprehensive information about the goods being transported. This includes:
Forwarders should ensure that their systems can handle these requirements and that their teams are trained to comply with the new standards. Submitting incorrect or inaccurate data, as well as missing data elements, can have serious consequences. This can lead to rejected declarations or customs intervention, with possible sanctions imposed for non-compliance. Consignments may be stopped or delayed at customs, resulting in enhanced security screening and further shipment delays causing frustration and financial losses for all parties involved.
2. Consider the Benefits of Multiple filing
ICS2 introduces the concept of multiple filing, where different actors in the supply chain can submit partial ENS filings. This is particularly useful for complex shipments involving multiple parties. Multi-filing offers several benefits:
Forwarders should evaluate their capabilities and consider setting up the necessary systems and processes for multiple filing to take full advantage of these benefits. Forwarders can choose between in-house technical integration, using intermediary IT service providers, or the Shared Trader Interface for multiple filing. It is important to evaluate which option best suits your operations.
3. Request a Deployment Window Before 1st November 2024
Freight forwarders who have chosen to act as maritime house filers have the possibility to start filing ENS declarations into ICS2 between 4 December 2024 and 1st April 2025. To be able to start within this timeframe, the European Commission has mandated economic operators (EOs) to request their deployment window to their National Customs Authority at least one month before the go-live date. For maritime house-filers, the deadline to request this window is 1st November 2024. Failure to request a deployment window could result in operational disruptions, as you would be required to start filing ENS data from 4 December. It is advisable to contact your National Customs Authority well in time to secure your deployment window and ensure your systems are ready for the transition.
4. Coordinate with carriers to ensure compliance
Most major ocean carriers have announced their timelines for starting to file into the ICS2 system, with many opting to begin in the latter part of 2024:
These timelines indicate that while the official go-live date for ICS2 Release 3 is 3rd June 2024, many carriers are opting for a phased approach to ensure their systems and processes are fully compliant before they begin filing. This cautious approach provides ample time for testing and adjustments to meet the stringent data submission requirements.
CLECAT notes that carriers tend to request data from house filers much earlier than the delay provided by law (which is 24 hours before loading in the port of departure for containerised cargo), to ensure they have extra time in case the data is incomplete. Freight forwarders understand the need for carriers to have some additional time to review these filings, but concerns have been raised about whether the time periods requested will be reasonable and not excessively disrupt normal business activities. To address these concerns, CLECAT will monitor these early submission requests closely since we would want to ensure the time frames requested by carriers are fair and proportionate, balancing the need for thorough data checks with the operational realities of freight forwarders.
ICS2 Release 3 represents a significant shift in how sea freight shipments are managed in Europe. By taking proactive steps requesting a deployment window and considering multiple-filing, freight forwarders can ensure a smooth transition and maintain control over their operations.
For more information, please visit the dedicated European Commission’s ICS2 Release 3 webpage.
