While full compliance with the European Union’s Import Control System 2 (ICS2) Release 3 was scheduled to take effect on September 1, some member states will postpone enforcement, according to Trade Tech, Inc., which provides an online international trade management and compliance platform.

ICS2 Release 3, launched in April 2025, extended the requirement to file Entry Summary Declarations (ENS) to goods moving into the EU by road and rail. ENS filings provide Customs authorities with shipment details before arrival, allowing for advance risk assessment and improved border security. Postponement, under the Derogation Mechanism, allows national Customs authorities to delay enforcement in their country, giving companies additional time to prepare.

These countries have confirmed that they will grant derogations (postponements): Austria, Belgium, Croatia, Finland, France, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Poland, Romania, Slovakia and Spain.

The postponements are expected to be in effect, in most cases, until the end of 2025. These extensions are temporary, and full compliance will be mandatory once they expire.

The following countries have confirmed that they will not grant derogations (postponements). ICS2 ENS filings will be required from September1 for these markets: Bulgaria, Cyprus, Czechia, Denmark, Estonia, Germany, Greece, Malta, Netherlands. Portugal, Slovenia and Sweden.

“ICS2 Release 3 is an important step in strengthening supply chain security in Europe. The decision to allow postponements has created different timelines across the EU, which can be challenging for participants to navigate,” said Bryn Heimbeck, president and co-founder of Trade Tech.