ENS Multiple Filing: Why ICS2 is a Shared Responsibility

In an increasingly globalized world, cross-border trade is both crucial and complex. Ensuring smooth flows of
e-commerce goods while maintaining security and compliance is a top priority for EU customs authorities, and that’s where the Import Control System 2 (ICS2) comes in.

ICS2 is the EU’s advanced cargo information system, designed to enhance supply chain security and streamline procedures. It requires all Economic Operators (EOs) importing goods into or transiting through the EU to submit Entry Summary Declarations (ENS) before goods are loaded. This ensures customs authorities can conduct pre-loading risk analysis to enhance security in the supply chain.
 
But what many overlook is how ICS2 creates interdependence between carriers and house filers in e-commerce. Accurate and coordinated data from both is key to avoiding delays and keeping the supply chain moving.

Master-Level and House-Level ENS Filing in e-commerce

Under ICS2, the ENS can be filed in parts by different actors:

• Master-level filing: Submitted by the carrier, covering the transport-level data for the full consignment.

• House-level filing: Submitted by freight forwarders, postal operators or couriers, providing the detailed information about each individual shipment
  (e.g., e-commerce parcels).

For customs to clear a shipment, both master and house-level data must be accurate and submitted on time.

What Happens to Carriers if House Filers Fail?

When house filers (freight forwarders, postal operators, express couriers) don’t submit their part of the ENS correctly or on time, it puts carriers in a difficult position.

1.     ENS Filing Becomes Incomplete
- Without correct house-level data, the ENS submission is incomplete.
- Customs cannot complete their risk assessment.

2. Goods or Entire Flight May Be Blocked
   - The movement of cargo may be held up at origin or even mid-transit.
   - Carriers face delays, storage fees and unhappy customers.
   
   

3. Carrier Bears Financial & Reputational Risk
   - Carriers may incur penalties, additional inspections, or tighter future scrutiny.
   - Service reliability suffers.
   
   

4. Strained Partnerships
   - Carriers may stop accepting freight from unreliable house filers.
   - Pressure on house filers to improve and comply with ICS2.

What Happens to House Filers if They  Fail?

When house filers don’t meet ICS2 requirements, they risk their business as well:

1. Loss of Trust from Airlines
   - Airlines may refuse to uplift cargo from house filers with a poor compliance record.
   - Reliable carriers prioritize shippers who help them remain compliant.
   
   

2. Operational Disruption
   - Shipments can be held at origin or rejected at EU borders.
   - Delivery timelines break down, and customers are dissatisfied.
   
   

3. Loss of Business
   - Carriers and clients may move their business to more reliable partners.
   
   

4. Increased Customs Scrutiny
   - Non-compliant shipments are flagged for inspection more often, adding time and cost.
   
   

5. Financial Penalties
   - In some jurisdictions, fines can be imposed directly on filers for repeated non-compliance.

Why Compliance Matters More Than Ever

ICS2 has raised the bar for customs compliance, especially in e-commerce, where volumes are high and timelines are tight.

It brings:

• Stricter compliance standards, requiring accurate product descriptions, consignee details, and timely submissions.

• Earlier data submission, before goods are loaded.

• Multiple ENS filings, dividing responsibility between carriers and house filers.

• Potential sanctions, including fines, delays, and increased audits for non-compliance.

ICS2 with x7trade

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