From 1 September 2025, the EU’s Import Control System 2 (ICS2) Release 3 became mandatory for all means of transport, including road and rail in many Member States. This means that economic operators moving goods into the EU by truck or train must now submit an Entry Summary Declaration (ENS) at the first point of entry. 

However, the rollout is not uniform. Several Member States have requested temporary derogations, permitting the continued use of older systems (ICS1 or NCTS P5) or hybrid configurations until 31 December 2025, with a limited number extending their transition period to mid-2026.  

Implementation Status Across Member States 

• No derogation: A number of Member States switched fully to ICS2 on 1 September 2025. For goods entering via these countries, ENS must now be filed directly in ICS2. 

• NCTS P6 (opt-in): Some countries allow ENS data to be included in the transit declaration lodged via NCTS P6. This gives operators the option of filing ENS either separately in ICS2 or combined with transit. 

• Derogations until the end of 2025: Several Member States still accept ICS1 or NCTS P5 filings until 31 December 2025. From 1 January 2026, ICS2 becomes mandatory. 

• Derogations until mid-2026: A smaller group of Member States will accept older systems until 31 May 2026. From 1 June 2026, they must switch to ICS2 (or NCTS P6 where applicable). 

Derogation Period Table & Implementation Deadlines:

Why This Matters 

For businesses moving goods across multiple EU borders, this patchwork approach adds complexity. The rules you need to follow depend entirely on the Member State of first entry. 

• Enter through a state with no derogation: ENS must go into ICS2. 

• Enter through a state with derogation: you may still use older systems for a limited time. 

• Re-enter the EU after transiting through a non-EU country: a new ENS must be filed at the re-entry point. 

Failure to meet the correct filing requirements can mean delays, penalties or goods held at the border.

 How to Prepare 

1. Map your entry routes: know exactly which Member States your goods pass through. 

2. Check the system in use: each Member State has its own implementation timeline. 

3. Ensure data readiness: accurate, complete data (product descriptions, HS codes, consignee info) is essential. 

4. Don’t wait for deadlines: even if derogations apply, moving to ICS2 early helps avoid last-minute complications. 

How x7trade Helps 

x7trade is designed to simplify this complexity. Our platform automates ICS2 ENS filing, whether through direct ICS2 submissions or multiple filing scenarios. 

Knowing your routes, filing responsibilities, and the system in play is critical to staying compliant and avoiding costly delays. 

Automation ensures that compliance isn’t a bottleneck. With x7trade, you can navigate ICS2 confidently and keep your cross-border operations running smoothly.  
 
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