An ENS for Great Britain is filed in S&S GB (HMRC), and an ENS for the EU in ICS2. The direction of movement decides — not the nationality of the company or the carrier.
Contents
Among importers and exporters handling the Poland–United Kingdom route, the same question keeps coming up: "Which system do I file my ENS in — S&S GB or ICS2?" The answer depends solely on the direction of movement, and a mistake here can end in goods being delayed at the border and penalties. This article explains the difference.
What is an ENS, and why are there two systems?
An Entry Summary Declaration (ENS) is an electronic safety declaration filed before goods arrive in a given customs area — it allows the authorities to carry out a risk analysis before the cargo enters the territory.
After Brexit, the United Kingdom created its own system, independent of the EU's:
- Import into GB (e.g. from Poland to England) → the S&S GB system (Safety and Security Great Britain), run by HMRC
- Import into the EU (e.g. from the UK to Poland) → the ICS2 system (Import Control System 2), run by the European Commission
These are two separate IT platforms, two legal bases, and two sets of data. A declaration filed in the system that does not match the direction of movement does not satisfy the obligation in the right one. One exception: goods brought into Northern Ireland from Great Britain and from outside the EU are declared in ICS2 (HMRC). Since 1 June 2026 ENS data can no longer be part of a UK transit declaration (NCTS Phase 6) — the ENS is filed separately, see NCTS Phase 6 and T1 transit.
For the EU side of road freight, see ICS2 Release 3 and road transport.
Table: which system for which direction?
| Direction of movement | ENS system | Authority | Mandatory from |
|---|---|---|---|
| PL/EU → GB (import into the UK) | S&S GB | HMRC (gov.uk) | 31 January 2025 |
| GB → PL/EU (import into the EU) | ICS2 (Release 3) | European Commission / national customs authorities | 1 September 2025 (full roll-out; some countries have temporary derogations) |
S&S GB — exporting to the United Kingdom
Who files the ENS under S&S GB?
The legal obligation rests with the carrier — the operator of the means of transport bringing the goods into GB (for unaccompanied RoRo it is the ferry operator). The carrier can have a customs agency or forwarder file the declaration, but the carrier remains legally responsible for it being filed on time, while whoever files it is responsible for the accuracy of the data.
Data in the ENS
The S&S GB declaration includes mandatory, conditional and optional data. Key data: the carrier's EORI, a description of the goods and the commodity code, the consignor's and consignee's details, the route and means of transport, the place of loading, and the office of destination.
Filing deadlines before arrival
Minimum timings according to HMRC guidance:
| Mode of transport | ENS filing deadline |
|---|---|
| Road (Channel Tunnel) | 1 hour before arrival at the Eurotunnel terminal (Coquelles, France) |
| RoRo (accompanied and unaccompanied) / short sea | 2 hours before arrival |
| Rail – journey under 2 hours / over 2 hours | 1 hour / 2 hours before arrival |
| Maritime bulk or break bulk cargo | 4 hours before arrival (2 hours before arrival on short sea journeys) |
| Air, under 4 hours' flight time | At the time of departure |
| Air, over 4 hours' flight time | 4 hours before arrival |
| Container shipping (longer routes) | 24 hours before loading at the port of departure; on short sea journeys (e.g. from ports on the English Channel, the North Sea or the Baltic) 2 hours before arrival – containers included |
Where do you register?
- EORI GB (free of charge, apply on gov.uk) — HMRC requires it from businesses not established in Great Britain
- Registration for the S&S GB service (after signing in to your HMRC account — Government Gateway)
ICS2 Release 3 — import from the UK into the EU
- Release 1 (March 2021): express air and postal
- Release 2 (March 2023): air freight
- Release 3: covers road and rail transport, among others — according to the European Commission, from 1 September 2025 ICS2 is operational in all Member States for all means of transport, with temporary derogations granted to some countries
The obligation rests with the economic operator bringing the goods into the EU customs territory (usually the road carrier or their representative). Data is entered via the national customs portal (in Poland: PUESC) or a certified IT system.
The most common mistakes and how to avoid them
Mistake 1: Filing an ENS in ICS2 for PL→GB transport. ICS2 covers goods entering the EU (and Northern Ireland). Goods travelling from Poland to England require a declaration in S&S GB.
Mistake 2: Not being registered for S&S GB. Without an account in the service (and, for businesses outside GB, an EORI GB number) you cannot file an ENS in S&S GB.
Mistake 3: Confusing "import into GB" with "export from PL". From the ENS system's point of view, this is an import INTO GB — and that's what determines the system to use.
Mistake 4: Assuming a customs agent automatically files the ENS. The ENS under S&S GB is the carrier's obligation; an agency can only file it with the carrier's knowledge and consent.
How we can help
We help with PL↔UK clearance: we check whether the carrier is registered with S&S GB, file the ENS on their behalf with their consent, and coordinate ICS2 declarations for imports from the UK into Poland. Not sure which system applies to you? Get in touch. More on the declaration itself: what an ENS is and when it is required, GMR vs ENS, what happens if you do not file an ENS.
Sources
- Safety and Security import requirements: ENS — GOV.UK
- Safety and security requirements on imports and exports — GOV.UK
- Transition to ICS2 Release 3 is complete — European Commission
Frequently asked questions
Does a Polish company exporting to the UK have to register with S&S GB itself?
The obligation to file the ENS rests with the carrier, not the exporter. The exporter should make sure the carrier is registered with S&S GB (or has named who will file for them) and that the declaration will be filed on time.
Does ICS2 cover transit through the EU from the UK to a country outside the EU?
ICS2 covers goods brought into the EU customs territory, including goods in transit. Specific exceptions depend on the mode of transport and are set out in the EU ICS2 rules.
What are the consequences of not filing an ENS, or filing it late?
HMRC says enforcement is evidence-based and proportionate, but it can include goods being delayed at the border for further checks and penalties under the Customs Safety and Security (Penalty) Regulations 2019.
Do S&S GB and ICS2 replace customs clearance?
No. The ENS is a safety declaration, separate from the customs declaration. Both obligations must be met independently.
How long before arrival must an ENS for the UK be filed for RoRo and Eurotunnel?
For RoRo (accompanied and unaccompanied) and short sea journeys, at least 2 hours before arrival. For the Channel Tunnel by road, at least 1 hour before arrival at the Eurotunnel terminal in Coquelles. An ENS can be amended until arrival, but the original declaration must be filed on time.
Can ENS data be included in a UK T1 transit declaration?
No. Since 1 June 2026 (NCTS Phase 6) a UK transit declaration containing security data is rejected — the ENS is filed separately with HMRC in S&S GB. ENS data in transit concerns EU countries (ICS2).
Related guides
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