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Clecat joins calls for ICS2 pause

[ September 2, 2025   //   ]

The European Association of Freight forwarders, Clecat has urged the European Commission to grant a non-enforcement period from 1 September, warning of serious blockages at European land borders.

ICS2 Release 3, officially launched in April 2025, extends the requirement to file Entry Summary Declarations (ENS) to goods moving into the EU by road and rail. ENS filings provide Customs authorities with shipment details before arrival, allowing for advance risk assessment and improved border security. However, 15 member states have announced that they will grant derogations from the original 1 September date – Austria, Belgium, Croatia, Finland, France, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Poland, Romania, Slovakia and Spain.

Clecat points out that until now, most carriers have provided safety and security data via NCTS – the New Computerised Transit System, widely used in land transport. Under the new legislation, this data must be sent directly to ICS2. To avoid duplicate submissions, an update known as NCTS6 should automatically transfer data from NCTS to ICS2. However, with many member states not expected to deploy NCTS6 before 2026, carriers risk being forced to file the same data multiple times.

For example, a truck travelling from Turkey to Germany via Greece, Bulgaria, Serbia and Hungary currently files one NCTS declaration at departure. From 1 September, without NCTS6, the driver must also file ICS2 declarations upon first entry into the EU in Greece and again when re-entering in Hungary.

The misalignment between ICS2 and NCTS6 rollouts, combined with frequent ICS2 outages and the high number of filings already processed from air and maritime carriers, creates serious risks, says Clecat. Land borders, unlike seaports and airports, have far more limited physical capacity and can be congested by just a few delayed trucks. Practical challenges unique to road and rail, such as split loads, the prevalence of small carriers, and the need for a multitude of non-EU operators to register in EU systems, were clearly overlooked when assigning the same deployment timeline to all modes of transport, it says.

CLECAT says that it and other European trade associations warned of these risks months ago and on 30 May jointly called for a postponement of the ICS2 Road and Rail rollout. The Commission, citing legal constraints, instead asked member states to request individual derogations by 25 August.

In response, Clecat and others in a joint letter have urged member states to take coordinated applications to avoid further fragmentation. However, this was not possible as some Member States such as Bulgaria and Estonia, already operating NCTS6 (such as Bulgaria and Estonia) could not request derogations; others with no external borders considered themselves unaffected, or applied different interpretations, such as the Netherlands treating lorries arriving by ferry as maritime traffic.

The latest Commission communication on 22 August listed updates on derogation requests from only 12 of the 27 Member States, together with short guidance on how to deal with the patchwork of readiness. However, operators across Europe report this information is inadequate to ensure compliance by 1 September, raising fears of major disruption at land borders.

Clecat said that, with just days to go, it is clear neither trade, nor authorities are prepared for this next phase of ICS2. Furthermore, the implementation of multiple filing for rail and road should be ensured as soon as possible. It points out that current full ENS filings do not meet the operational requirements of LTL and groupage transports, nor are rail operators capable to receive and process house level filings.

Clecat has written to the Commission to provide clarity by announcing an official six-month non-enforcement period, as was granted to the air and maritime sectors under ICS2. Although such a grace period was promised for road and rail, the Commission’s latest statement not only fails to mention it; but explicitly rules out business continuity procedures and alternative filing methods after 1 September in countries without a derogation. It says the Commission should act without delay and announce a six-month grace period at EU level to prevent disruption to European supply chains.

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