ICS2 Release 3 and Road Transport: What Every Polish Carrier Needs to Know Before Entering the EU

ICS2 Release 3 and Road Transport: What Every Polish Carrier Needs to Know Before Entering the EU
Contents
  1. What is ICS2 and why did it replace ICS1?
  2. ICS2 Release 3 — what's new for road transport?
  3. Who lodges the ENS?
  4. What data does the ENS contain for road transport?
  5. How to lodge an ENS — step by step
  6. Frequently Asked Questions (FAQ)
  7. How we can help
  8. Sources

Every lorry entering the territory of the European Union from a third country — including the United Kingdom — must now be preceded by an electronic security declaration in the ICS2 system. Since 1 September 2025, this has also applied to road and rail transport (Release 3). This article is aimed at Polish carriers, freight forwarders and customs agencies handling import routes into the EU.

What is ICS2 and why did it replace ICS1?

ICS2 (Import Control System 2) is the EU's system for electronically declaring goods before they arrive in the EU. The aim: risk analysis before the cargo reaches the border.

ICS1 (since 2011) was based on a single declaration lodged by the carrier. ICS2 introduces a layered model (multiple filing): data from different participants in the supply chain.

An important distinction between directions:

DirectionSystemWho lodges itIn force since
Import into the EU (e.g. UK→PL)ICS2 (EU)Carrier / operator1 Sep 2025 (road)
Import into the UK (e.g. PL→GB)S&S GB (UK)Carrier31 Jan 2025

ICS2 is an EU system — it governs goods entering into or through the EU. For the PL→UK direction, a separate British system, S&S GB, applies. Do not confuse these two systems.

ICS2 Release 3 — what's new for road transport?

  • Release 1 (March 2021): postal and express (air) consignments
  • Release 2 (March 2023): general air cargo
  • Release 3 (2025): road and rail transport — the final stage

Release 3 introduces the requirement to lodge a full ENS (Entry Summary Declaration) for goods transported by road or rail into the EU from third countries.

StageDateDescription
Implementation window opens1 April 2025Ready operators could start lodging ENS in ICS2
Fully mandatory1 September 2025ENS mandatory for everyone — ICS1 decommissioned
Temporary derogationsuntil 31 December 2025For selected states, on application

The European Commission has confirmed that ICS2 has been fully operational since 1 September 2025 for all modes. A few states, and the UK (for Northern Ireland), obtained temporary derogations — these are exceptions, not the rule.

Who lodges the ENS?

  • The road carrier — the main party responsible on entry into the EU
  • The freight forwarder — if acting as the transport operator on behalf of the carrier
  • Postal and courier operators using road/rail transport
  • The final consignee established in the EU — in certain circumstances

In practice: the Polish carrier or their customs agent normally lodges the ENS for import routes into the EU, before arrival at the first EU customs office.

What data does the ENS contain for road transport?

  1. Goods data — description, CN/HS codes, gross mass
  2. Party data — consignor, consignee, carrier, agent
  3. Transport data — vehicle/trailer registration number, route, point of entry
  4. Container data (if applicable)
  5. Safety declaration — UN classification for dangerous goods
  6. Accompanying documents — CMR number, invoices

How to lodge an ENS — step by step

Step 1: Access through your national system connected to ICS2. In Poland: PUESC (puesc.gov.pl). An EORI number is required.

Step 2: Gather the complete goods and commercial data before loading (an ENS checklist in the transport order).

Step 3: Lodge the ENS at least 1 hour before arrival at the first EU point of entry (recommended: several hours earlier).

Step 4: The system generates an MRN (Master Reference Number). The driver should have the MRN available for inspection.

Step 5: ICS2 analyses the risk. It may issue a "Do Not Load" (DNL) message or order a physical inspection.

Frequently Asked Questions (FAQ)

Does ICS2 apply to carriers travelling from the UK to Poland? Yes. UK→PL is an import into the EU — ICS2 applies. An ENS is required before entry into EU territory.

If I travel from Poland to the UK, do I also lodge an ENS in ICS2? No. PL→UK is an import into the UK — S&S GB applies, not ICS2. Two separate systems.

What if I enter the EU without an ENS? The customs office can hold the goods and refuse clearance. A missing ENS is a breach of EU regulations.

Will a customs agency lodge the ENS on my behalf? Yes — with access to PUESC and a power of attorney. This is standard practice.

Does ICS1 still run in parallel? No. ICS1 was decommissioned on 1 September 2025. The only system for lodging an ENS into the EU is now ICS2.

How we can help

The customs agency agencjacelna.uk handles ENS declarations in ICS2 for UK–Poland import shipments. We prepare the documentation, lodge the ENS, and coordinate communication with the customs authorities. Get in touch before your first shipment covered by ICS2.

Sources

Agencja Celna UK team

Written by a customs agency registered with CDS (UK EORI), based on gov.uk, HMRC, the EU customs tariff (TARIC) and Polish law. This article is for information only — check the current rules before clearance or ask us about your situation.

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