In an urgent letter to the European Commission, IRU is calling for a six-month EU-wide enforcement grace period for the EU’s new customs import control system for goods moved by road (ICS2 release 3), warning of major disruptions at external land borders from 1 September 2025.
Road transport operators must file an Entry Summary Declaration (ENS) using ICS2 starting 1 September.
Aware of delays in Member States’ implementation, the European Commission has allowed them to postpone deployment. The result is a fragmented situation: some Member States are ready, while others have deferred.
This patchwork creates confusion for operators. Even if a company is based in a country that postponed application, it must still check from where its goods will enter the EU. According to the Commission, if entry is through a Member State already applying ICS2, the ENS must be logged in the new system.
IRU EU Advocacy Director Raluca Marian said, “From Monday, filing an ENS will become a bureaucratic puzzle for road transport operators. Derogations are logical if systems are not ready, but why this patchwork? If Europe is moving at two speeds, why not accept it, and simplify and postpone for all?”
A two-speed system exposes operators to penalties and forces difficult decisions on routing goods, while customs authorities may struggle with incomplete or missing ENS declarations. This risks long queues and severe disruptions at external borders.
“ICS2 is essential. IRU will keep supporting readiness. But without a common grace period, we risk gridlocks at borders and overwhelmed customs,” said Raluca Marian. “A six-month EU-wide enforcement grace period is the only way to ensure legal certainty and a smooth transition.”
IRU urges the Commission and all Member States to act swiftly and establish a coordinated grace period for road transport, including combined and intermodal transport involving road.