From 1 September 2025, the ICS2 (Import Control System 2) will become mandatory in the European Union also for road and rail transport. However, the ICS2 implementation status in the EU 2025 is not uniform – while some Member States have fully deployed ICS2, others are still benefitting from transitional derogations.

Below we present a clear overview of the current situation across the EU and Northern Ireland.

1. Countries with full ICS2 implementation from 1 September 2025

All goods entering by road or rail must be covered by an ENS declaration lodged in ICS2.

Austria, Belgium, Cyprus, Czech Republic, Germany, Denmark, Luxembourg, Malta, Netherlands, Portugal, Sweden, Slovenia.

2. Countries with ICS2 and the possibility to use NCTS P6 (opt-in)

In these countries, ENS may be lodged in ICS2 or – in certain cases – together with the transit declaration in NCTS P6.

Bulgaria, Estonia.

3. Countries with derogation until 31 December 2025

Until the end of 2025, ENS can still be lodged in ICS1 or ICS2. From 1 January 2026, ICS2 will be mandatory.

Spain, Finland, France, Greece, Hungary, Ireland, Italy, Lithuania, Northern Ireland (UK – XI).

4. Countries with extended transition until 31 May 2026

Until May 2026, these countries allow ENS in ICS1 or ICS2, and transit declarations in NCTS P5 (with safety and security data). From 1 June 2026, ICS2 (or NCTS P6 where available) will be mandatory.

Croatia, Latvia, Poland, Romania, Slovakia.

What does the ICS2 implementation status in the EU 2025 mean for operators?

  • In most Member States, ENS must be submitted in ICS2 from September 2025.
  • Some countries still allow ICS1 or NCTS P5, but only temporarily.
  • The longest derogations apply until May 2026 – after that, ICS2 will be the single system across the EU.

France – ELO Envelope postponed

Along with the postponed ICS2 deadlines, the obligation to use the ELO (Enveloppe Logistique Obligatoire) in France has also been delayed.
More details here: Mandatory Logistics Envelope (ELO) – France

👉 If you are moving goods by road or rail into the EU, you need to ensure your processes are ready for ICS2.
At Simple Duty LTD (link), we support our customers with ENS declarations, ELO, and customs procedures across the UK–EU border.

Read more about ICS2 and ENS declarations here:
🔗 ENS Declarations in ICS2

Source and Disclaimer

This overview is based on the official guidance of the European Commission:
👉 Guidance for the submission of an ENS for road and rail during the ICS2 and NCTS P6 derogation period (2025-08-29)

* At the time of drafting, discussions with some Member States were still ongoing (e.g. Bulgaria considering whether to formally request a derogation). The Commission (DG TAXUD) reserved the right to update the table.