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5 October 2025ICS2 for E-commerce Imports: What Data Must Be in the Booking (ENS) and Who Files It
In recent years, the European Union has radically reshaped the way it manages border security for goods entering its territory. With the rise of cross-border e-commerce, millions of small parcels move daily into the EU from Asia, North America, and beyond. These shipments are not just an opportunity for growth—they are also a vector for risk. Fake goods, unsafe products, tax evasion, and even potential security threats enter hidden in what appear to be “ordinary” parcels.
To address this, the EU developed the Import Control System 2 (ICS2)—a new digital framework requiring detailed data to be submitted before goods even leave the country of origin. The idea is simple: the more customs authorities know in advance, the more effectively they can stop high-risk shipments without slowing down compliant trade.
For e-commerce brands, this marks a fundamental shift. No longer is it enough to ship a package with a generic “gift” or “clothes” label. Customs now demand precise data: product descriptions, HS codes, shipper and consignee information, values, and more. Failure to provide this information results in delays, fines, or shipments being destroyed.
The central question for brands, freight forwarders, and marketplaces is: what data must be in the Entry Summary Declaration (ENS), and who is responsible for filing it?
ICS2 requires e-commerce imports into the EU to submit detailed ENS data before departure, ensuring secure and compliant trade.
OUR GOAL
To provide an A-to-Z e-commerce logistics solution that would complete Amazon fulfillment network in the European Union.
What is ICS2?
ICS2—Import Control System 2—is the EU’s advance cargo information system. It builds on the original ICS introduced in 2011, but extends both the scope and the requirements.
Purpose
The goal is to create a data-driven security layer for EU borders. Instead of inspecting shipments only after arrival, customs authorities can assess risk before goods depart from the exporting country. High-risk shipments are flagged early, while compliant goods pass smoothly.
Rollout Timeline
- ICS (2011): Focused on large freight shipments.
- ICS2 Phase 1 (2021): Applied to express carriers and postal operators for air shipments.
- ICS2 Phase 2 (2023): Extended to general air cargo.
- ICS2 Phase 3 (2024–2025): Extends requirements to maritime, rail, and road shipments. By 2025, all goods entering the EU, regardless of transport mode, must be declared under ICS2.
Scope
- Applies to all imports into the EU, including Norway, Switzerland, and Northern Ireland (linked to EU customs union).
- Affects carriers, freight forwarders, postal operators, express couriers, and indirectly every e-commerce seller shipping into the EU.
ICS2 is the EU’s new data-driven cargo security system, covering all imports by 2025 across air, sea, rail, and road.
E-commerce replaces containers with millions of small parcels—ICS2 restores visibility through structured data.
Why ICS2 Matters for E-commerce
E-commerce has been the biggest disruptor of cross-border trade in the last decade. What once moved in bulk shipments—pallets, containers, truckloads—now moves in millions of small parcels. Every day, consumers across the EU order low-value items from Asia, cosmetics from the US, or electronics from the UK. For customs, this creates a paradox: the volume of goods is exploding, but the visibility into those goods has decreased.
In the traditional model, a customs officer could examine a container manifest: “10,000 units of men’s t-shirts, HS code 6109.10, shipped from Shanghai to Rotterdam.” With e-commerce, that container may be broken into 10,000 different parcels, each with a vague description like “clothes” or “gift.” The lack of granularity makes it nearly impossible to detect fraud, unsafe goods, or tax evasion.
The Growth Challenge
- According to Eurostat, over 70% of EU consumers purchased online in 2024.
- Cross-border online sales now account for nearly a quarter of EU e-commerce.
- Postal operators handle hundreds of millions of small parcels annually from non-EU countries.
This is exactly why ICS2 exists: to close the information gap. Instead of relying on generic labels, customs demand structured, standardized data for every shipment—even low-value parcels under €150.
Risks for Brands and Platforms
For e-commerce sellers, ICS2 is not just a regulatory hurdle—it directly affects customer satisfaction and profitability.
- Delays at the Border
If ENS (Entry Summary Declaration) data is missing or incorrect, shipments are flagged and held. A consumer expecting a package in 3–4 days may end up waiting weeks. In e-commerce, that’s enough to lose a customer for life. - Fines and Seizures
Non-compliance can lead to financial penalties or outright seizure of goods. A shipment with undeclared batteries, mislabeled pharmaceuticals, or counterfeit items can be destroyed. - Marketplace Sanctions
Marketplaces like Amazon, eBay, or AliExpress require sellers to comply with customs rules. A history of non-compliant shipments can result in suspension. - VAT and Tax Risks
ICS2 is tied to VAT reforms such as IOSS (Import One-Stop Shop). Sellers that fail to declare VAT correctly risk double taxation: once at checkout and again at delivery.
Why Small Mistakes Hurt
A D2C cosmetics brand shipping from Korea to Germany may think describing an item as “beauty product” is sufficient. Under ICS2, this is not enough—the description must specify “facial cream, 50ml, non-hazardous.” If data is incomplete, the shipment is stopped. Multiply this error across hundreds of daily orders, and the brand risks systemic disruption of its EU business.
The Competitive Advantage of Compliance
While many small sellers see ICS2 as a burden, savvy brands view it as a competitive advantage. Compliant shipments move faster through customs, experience fewer delays, and create more reliable customer experiences. In a crowded market, speed and reliability are differentiators.
For large platforms, compliance also becomes a trust signal. A marketplace that guarantees ICS2-compliant shipping attracts both consumers (who enjoy smoother deliveries) and regulators (who view the platform as a responsible partner).
SLA Expectations
B2C SLAs
Consumers expect near-instant gratification. Marketplaces like Amazon Prime have conditioned shoppers to demand:
- Same-day or next-day delivery.
- Precise delivery windows.
- Transparent tracking with SMS/email updates.
Failing these SLAs risks poor reviews, abandoned carts, and lost loyalty.
B2B SLAs
Business buyers prioritize reliability over speed. They care about:
- Consistent lead times (2–5 days).
- Delivery accuracy (full, correct order).
- Compliance (delivery at dock, with paperwork, within agreed slot).
A B2B order arriving late by one day may disrupt production schedules, costing millions. The stakes are higher, but the SLA definition is different.
ICS2 requires structured ENS data for every parcel. FLEX automates compliance, preventing delays and penalties.
What Data Must Be in the Booking (ENS)
At the heart of ICS2 lies a simple but strict requirement: every shipment entering the EU must be declared in advance with precise data through an Entry Summary Declaration (ENS). Unlike older systems, where vague or partial data was tolerated, ICS2 demands a structured dataset that customs authorities can use to assess risks before goods even depart.
For e-commerce brands, this means that the days of writing “gift” or “clothes” on a shipping label are over. The EU now expects detail, standardization, and accuracy. Missing or incorrect data doesn’t just cause inconvenience—it can lead to delays, penalties, and sometimes even destruction of goods.
Core Data Elements Required
The EU has defined a set of mandatory elements for the ENS. These include:
- HS Code (Harmonized System Code)
- A six-digit classification that identifies the type of goods.
- Example: instead of “clothes,” the correct HS code might be 6109.10 for cotton T-shirts.
- Why it matters: Customs authorities use HS codes to determine risk, tariffs, and whether products are restricted.
- A six-digit classification that identifies the type of goods.
- Detailed Item Description
- Generic descriptions like “shoes,” “cosmetics,” or “electronics” are insufficient.
- The description must specify the nature, material, and form of the product.
- Example:
- ❌ Bad: “Clothes”
- ✅ Good: “Women’s cotton T-shirt, short-sleeve, size M”
- ❌ Bad: “Clothes”
- Example in electronics:
- ❌ Bad: “Phone accessory”
- ✅ Good: “Smartphone case, plastic, designed for iPhone 14”
- ❌ Bad: “Phone accessory”
- Generic descriptions like “shoes,” “cosmetics,” or “electronics” are insufficient.
- Shipper Information
- Full name, address, and contact details of the exporter.
- Customs use this to validate origin and monitor high-risk shippers.
- Full name, address, and contact details of the exporter.
- Consignee Information
- Full name and address of the recipient (the EU buyer).
- Must match the delivery address provided in the order.
- Full name and address of the recipient (the EU buyer).
- Value of Goods
- Declared in euros (or convertible currency).
- Needed for risk analysis and tax calculation.
- Declared in euros (or convertible currency).
- Quantity and Weight
- Number of units and net weight of goods.
- Ensures shipments align with reality—10 “phones” cannot weigh 200 grams.
- Number of units and net weight of goods.
- Transport Information
- Carrier, flight number, departure, and arrival airports for air shipments.
- This allows authorities to pre-screen based on routing.
- Carrier, flight number, departure, and arrival airports for air shipments.
- IOSS Number (if applicable)
- For shipments under €150, sellers registered for IOSS (Import One Stop Shop) must include their IOSS number.
- This ensures VAT is prepaid and prevents customers from being double-charged at delivery.
- For shipments under €150, sellers registered for IOSS (Import One Stop Shop) must include their IOSS number.
Good vs. Bad Example
Scenario: A Polish cosmetics brand shipping facial cream to Germany
- ❌ Incorrect ENS Filing:
- Item: “Cosmetics”
- Value: €20
- Weight: 200g
- HS Code: Not provided
- Item: “Cosmetics”
- Result: Shipment flagged, delayed 7 days in customs, buyer complains and cancels future orders.
- ✅ Correct ENS Filing:
- Item: “Facial cream, moisturizing, 50ml, non-hazardous”
- HS Code: 3304.99
- Value: €20
- Weight: 200g
- IOSS: Valid number provided
- Item: “Facial cream, moisturizing, 50ml, non-hazardous”
- Result: Shipment clears automatically through ICS2, delivered within 3 days, customer satisfied.
Why Accuracy Matters
Customs authorities no longer accept “catch-all” categories. A shipment described as “electronics” could mean anything from a harmless phone charger to a dangerous lithium battery. With ICS2, vague data is a red flag. The system automatically compares item descriptions, HS codes, and values to detect inconsistencies.
Example: If a parcel is declared as “T-shirt” but the HS code refers to “footwear,” the system flags it as suspicious. Similarly, if a declared weight is unrealistic (e.g., “100 phones” weighing only 1kg), the shipment is held for inspection.
The Burden for E-commerce Sellers
For large logistics providers and multinational retailers, complying with these requirements is manageable—they already use advanced systems to generate standardized data. But for small D2C brands or marketplace sellers, especially from Asia, the challenge is significant:
- Time-consuming: Every product requires proper HS code assignment.
- Knowledge gap: Many small sellers don’t understand EU customs rules.
- Scaling problem: 1,000 parcels = 1,000 ENS filings. Without automation, errors are inevitable.
This is where 3PLs like FLEX become critical. By integrating seller order data directly into customs systems, FLEX can automatically generate compliant ENS filings, reducing the burden on sellers and ensuring shipments move smoothly.
Case Example: Wrong Description, Big Impact
A Chinese seller shipped hundreds of “gadgets” to Spain without HS codes. Customs flagged them as suspicious, suspecting lithium batteries. Result:
- Shipments delayed for 3 weeks.
- Hundreds of orders canceled.
- Seller account suspended on the marketplace.
In contrast, a similar seller working with a compliant 3PL filed “Bluetooth wireless earphones, lithium battery enclosed, HS Code 8518.30” with full weight/value. Shipments passed seamlessly.
Who Files the ENS?
The Entry Summary Declaration (ENS) is not just about what data needs to be provided—it’s equally about who is legally responsible for filing it. Under ICS2, responsibility lies with the party that brings goods into the EU customs territory. But in practice, the picture is more complex, because e-commerce shipments pass through multiple stakeholders: carriers, freight forwarders, postal operators, express couriers, and sometimes even the sellers themselves.
Core Principle: The Carrier Files
At the most basic level, the carrier transporting goods into the EU—whether an airline, shipping line, or road haulier—is responsible for ensuring an ENS is filed.
- For air cargo, this typically means the airline.
- For maritime shipments, the shipping line.
- For parcels, the express courier (e.g., DHL, UPS, FedEx) or the designated postal operator.
Carriers, however, rely heavily on shippers and intermediaries to provide accurate data. If the seller sends vague information (“electronics, 2kg”), the carrier cannot generate a compliant ENS.
Role of Express Couriers and Postal Operators
For small e-commerce parcels, the practical responsibility often falls on express couriers and postal networks.
- Express couriers (DHL, UPS, FedEx): They integrate directly with ICS2 systems and file ENS automatically based on the data they receive from sellers. However, they require sellers to provide structured electronic data at the time of booking. If the data is missing or wrong, the courier files an incomplete ENS, and the shipment gets blocked.
- Postal operators: National postal services (e.g., China Post, USPS, Royal Mail) also handle ENS filings. With millions of parcels daily, they depend on electronic advance data (EAD) provided by the origin country. This is where delays often occur, because many postal systems still struggle with standardization.
Role of Freight Forwarders and 3PLs
For bulk e-commerce shipments or consolidated flows, freight forwarders and 3PLs like FLEX take on ENS responsibilities.
- Freight forwarders: When consolidating shipments from multiple sellers, forwarders act as the "declarant" for ENS. They file the data for the consolidated cargo before it leaves the origin.
- 3PLs: Providers like FLEX integrate directly with both seller systems and carrier APIs. They ensure the data is accurate, complete, and submitted on time. This is crucial for smaller brands that lack in-house customs expertise.
Role of Sellers and Marketplaces
In certain cases, the seller—or even the marketplace—may be responsible for providing or validating data.
- Marketplace-driven models: Platforms like Amazon and Zalando often require sellers to upload detailed product information (HS codes, item descriptions, IOSS numbers) into their seller portals. The marketplace then transmits this data to carriers, who file ENS.
- D2C sellers: Direct sellers using their own logistics providers must ensure that order data is clean and detailed. While they may not file the ENS themselves, they are the source of truth for product descriptions, values, and VAT numbers.
Shared Responsibility in Practice
The ENS process is a chain of accountability:
- Seller / Marketplace provides accurate product and order data.
- 3PL / Freight forwarder consolidates, validates, and transmits the data.
- Carrier / Postal operator submits the ENS to EU customs before departure.
If one link in the chain fails, the entire shipment is at risk. Customs do not care whether the error was caused by the seller, the forwarder, or the carrier—they simply block the shipment until corrected.
What Happens if No One Files?
Failure to file an ENS is not a minor oversight. Under ICS2, shipments without ENS data:
- Cannot legally enter EU customs territory.
- Are held at the first point of arrival (airport, port, border).
- May be returned to the sender or destroyed if non-compliance persists.
- Can trigger penalties for the carrier, leading to additional fees charged back to the shipper.
Example 1: Marketplace Seller in Asia
A small electronics seller on AliExpress shipped 300 parcels to France. The seller assumed that “the courier will handle everything.” Unfortunately, they provided incomplete product descriptions. DHL filed ENS using the incomplete data, and French customs flagged the shipment. Result:
- Parcels delayed for 10 days.
- Dozens of cancellations from frustrated customers.
- Seller faced extra fees from DHL for correction filings.
Example 2: D2C Brand with 3PL Support
A mid-sized fashion brand in the US partnered with FLEX to ship into Germany. The brand provided clean order data (HS codes, product descriptions, IOSS). FLEX validated the information, generated ENS filings via its customs integration, and transmitted everything before departure. Result:
- Zero customs delays.
- Smooth delivery within 72 hours.
- The brand gained a competitive edge over slower rivals.
The Takeaway
Legally, the carrier is responsible for ENS filing. But operationally, everyone in the chain must cooperate: sellers must provide detailed product data, 3PLs and forwarders must validate it, and carriers must transmit it correctly. In e-commerce, where speed is everything, this shared responsibility model makes compliance both a challenge and an opportunity.
ICS2 is more than just another customs regulation—it is the new backbone of EU border security and compliance. For e-commerce, it transforms how goods cross into the single market. Sellers, carriers, and logistics providers can no longer rely on vague product descriptions or outdated paperwork. Instead, every shipment requires precise, structured, and validated data before it even leaves the country of origin.
This shift creates both challenges and opportunities. Brands that fail to adapt face delays, fines, and reputational damage. But brands that embrace ICS2 can turn compliance into a competitive advantage: faster clearance, fewer shipment disruptions, and greater customer trust.
The responsibility for compliance does not sit with one party alone—it is a shared chain of accountability. Sellers must provide clean product data, carriers must file ENS correctly, and logistics partners must ensure the process is seamless. Any weak link can break the chain.
FLEX Logistik positions itself as the partner that connects these dots. With automated ENS filing, integration across carriers, and deep customs expertise, FLEX helps e-commerce brands focus on growth while staying compliant with complex EU regulations.
In the end, ICS2 is not just about security—it’s about creating a smarter, faster, and more reliable e-commerce ecosystem. Those who prepare now will thrive. Those who ignore it risk being left behind at the border.
