The European Union's Import Control System 2 (ICS2) is now fully operational for all air cargo entering the EU, including shipments from Turkey. ICS2 requires advance electronic cargo declarations to be submitted before goods depart for the EU — a significant change from previous practice that has major implications for Turkish exporters, freight forwarders, and airlines. Non-compliance can result in shipments being held at EU airports, causing costly delays and potential loss of business.
What Is ICS2 and Why Was It Introduced?
ICS2 is the EU's new advance cargo information system, replacing the original Import Control System (ICS1) that has been in place since 2011. It was developed as part of the EU's Union Customs Code (UCC) modernization program and is designed to enhance security screening of goods entering the EU, improve risk assessment capabilities, and facilitate legitimate trade.
The primary security objective of ICS2 is to enable EU customs authorities to identify high-risk shipments before they arrive in the EU, rather than after. By requiring advance electronic declarations with detailed cargo information, customs authorities can apply risk-based screening and intervene before dangerous or prohibited goods reach EU territory.
ICS2 was rolled out in three phases. Phase 1 (March 2021) covered express courier and postal shipments. Phase 2 (March 2023) extended the requirement to all air cargo. Phase 3 (March 2024) extended it to maritime, road, and rail cargo. All three phases are now fully operational.
What ICS2 Requires: The Entry Summary Declaration (ENS)
The core requirement of ICS2 is the Entry Summary Declaration (ENS). The ENS must be submitted electronically to the EU customs authority of the first point of entry before the goods depart from the origin country. For air cargo from Turkey, this means the ENS must be submitted before the aircraft departs from the Turkish airport.
ICS2 Submission Deadlines for Air Cargo
- Flights of 4 hours or less: ENS must be submitted at least 30 minutes before departure
- Flights of more than 4 hours: ENS must be submitted at least 4 hours before arrival at the first EU airport
- Express courier shipments: ENS must be submitted before loading on the aircraft
- Amendment of ENS: Possible up to the point of departure, subject to risk assessment
What Information Must Be Included in the ENS?
The ICS2 ENS requires significantly more detailed cargo information than the previous ICS1 system. Key data elements include:
- Goods description: A specific, accurate description of the goods — generic descriptions like "general cargo" or "merchandise" are not acceptable
- HS code: At least the 6-digit HS code for each commodity
- Gross weight: Accurate gross weight for each consignment
- Number of packages: Accurate package count and type
- Consignor details: Full name and address of the shipper in Turkey
- Consignee details: Full name and address of the recipient in the EU
- Notify party: If different from the consignee
- Place of loading: The Turkish airport of departure
- Conveyance reference: Flight number and date
- Container/ULD numbers: If applicable
"ICS2 is not just a compliance exercise — it's a fundamental change in how EU customs authorities manage risk. Turkish exporters who provide accurate, detailed cargo information will experience faster clearance. Those who don't will face delays."
Who Is Responsible for Filing the ENS?
Under ICS2, the responsibility for filing the ENS lies with the carrier (airline) or, in some cases, the freight forwarder acting as the carrier's agent. However, the accuracy of the ENS depends entirely on the information provided by the shipper. If the shipper provides inaccurate or incomplete information, the ENS will be incorrect, and the shipment may be held for examination at the EU point of entry.
In practice, this means that Turkish exporters must ensure they provide their freight forwarder with complete and accurate cargo information well in advance of the shipment departure. The freight forwarder will use this information to prepare the ENS and submit it to the airline for filing with EU customs.
ICS2 and the House Airway Bill (HAWB)
One of the most significant changes introduced by ICS2 is the requirement for house-level data in the ENS. Under ICS1, only master airway bill (MAWB) data was required. Under ICS2, the ENS must include data at the house airway bill (HAWB) level — meaning each individual consignment within a consolidated shipment must be declared separately.
This has significant implications for freight forwarders who consolidate multiple small shipments into a single master airway bill. Each house shipment must be individually declared in the ENS, with accurate consignor, consignee, and goods information for each. Freight forwarders who are not set up to handle house-level ICS2 filings are a compliance risk for their clients.
Consequences of Non-Compliance
The consequences of ICS2 non-compliance can be severe:
- Do Not Load (DNL) order: EU customs can issue a DNL order preventing the shipment from being loaded on the aircraft if the ENS is not filed or contains serious errors
- Hold for examination: Shipments that arrive without a valid ENS or with significant discrepancies will be held for physical examination, causing delays of 24–72 hours or more
- Fines and penalties: EU member states can impose fines on carriers and freight forwarders for systematic non-compliance
- Reputational damage: Repeated compliance failures can result in increased scrutiny of all shipments from a particular shipper or forwarder
Practical Steps for Turkish Exporters
To ensure your shipments to the EU comply with ICS2 requirements, take the following steps:
- Ensure your freight forwarder is ICS2-compliant and capable of filing house-level ENS data
- Provide complete and accurate cargo information — including specific goods descriptions and HS codes — well in advance of the shipment departure
- Ensure your commercial invoice and packing list contain all the information required for the ENS
- Book shipments with sufficient lead time to allow for ENS filing before the applicable deadline
- Establish a process for quickly providing additional information if EU customs requests clarification
How Turkey Air Cargo Handles ICS2 Compliance
Our customs compliance team is fully trained on ICS2 requirements and our systems are integrated with the EU's ICS2 platform. We file ENS declarations for all EU-bound shipments as a standard part of our service, and our pre-shipment document review process catches potential ICS2 compliance issues before they cause delays. If you're concerned about ICS2 compliance for your EU shipments, contact our team for a free compliance review.
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