ICS2, ISF 10+2 & ACAS — pre-arrival security filings explained (2026)
A container stranded at Ningbo before it ever sails
Everything looked ready: goods produced, bill of lading drafted, container booked on a sailing from Ningbo to Rotterdam. Then, 24 hours before the loading cut-off, the ocean carrier refuses the box — the Entry Summary Declaration (ENS) was never validated in the EU's ICS2 system. The container stays on the dock, you miss the sailing, and you wait a week for the next vessel.
Advance cargo security filings — ICS2 in the EU, ISF 10+2 and ACAS in the US, S&S GB in the UK — are not about duties or taxes. They let customs analyze the security risk of a shipment before it enters the territory, and for containerized ocean, before it even loads. This guide maps who files what, by when, so a shipment isn't left behind at origin.
EU: ICS2 and the ENS
ICS2 (Import Control System 2) runs on the Union Customs Code (Regulation 952/2013) and its Implementing Act 2015/2447. Its core is the ENS — a dataset filed before arrival describing the consignment for a safety and security risk analysis. It is separate from the customs import declaration that assesses duty and VAT; the two coexist.
Two things to remember: the ENS is filed before arrival (and for containerized ocean, before loading at the foreign port), and it requires a valid EORI for the EU consignee plus a precise description with a 6-digit HS code.
Filing deadlines by transport mode
ENS deadlines follow Article 105 of Implementing Act 2015/2447. They drive the whole upstream timeline:
| Mode | Minimum ENS lodging time | Note |
|---|---|---|
| Deep-sea containerized | 24 h before loading at origin port | "24-hour rule" |
| Deep-sea bulk / break-bulk | 4 h before arrival | IA art. 105 |
| Short-sea shipping | 2 h before arrival | IA art. 105 |
| Air — minimum dataset (PLACI) | At the latest before loading | Pre-loading |
| Air — flights > 4 h | 4 h before arrival (full set) | IA art. 105 |
| Air — short flights (< 4 h) | At latest by actual departure | IA art. 105 |
| Rail | 2 h before arrival | IA art. 105 |
| Road | 1 h before arrival | IA art. 105 |
Key point: containerized ocean is the tightest, because the clock runs to loading abroad, not arrival. An incomplete ENS at the 24-hour cut-off means the box does not sail.
US: ISF 10+2 and ACAS
The US mirror of ICS2 splits by mode. For ocean freight, the Importer Security Filing (ISF 10+2) requires 10 data elements from the importer of record plus 2 from the carrier, filed at least 24 hours before the vessel loads at the foreign port. Late or inaccurate ISF filings expose the importer to liquidated damages of up to $5,000 per violation from CBP.
For air freight, ACAS (Air Cargo Advance Screening) is the US pre-loading equivalent of ICS2's PLACI: a minimum dataset transmitted before the aircraft is loaded, with the same possible outcomes — clear, request for information, or a hold that prevents loading. Our US import guide covers the ISF, customs bond and broker mechanics in detail.
Multiple filing and Do-Not-Load
ICS2 breaks the single-filer model of the old ICS1. The carrier files master-level data (master bill of lading / master air waybill); a groupage operator, NVOCC or forwarder can file house-level data (the real shipper-to-consignee consignment) directly. This avoids the carrier having to guess the contents of a consolidation — but it creates a chain dependency: if the house filer doesn't transmit, or sends data inconsistent with the master, the ENS is incomplete.
For air, the pre-loading dataset (PLACI) lets customs issue one of three responses: green light, a referral (request for more information), or a Do-Not-Load (DNL) — a formal ban on loading the parcel. A DNL is not a fine you pay later; the parcel simply does not board.
ICS2 rollout: R1, R2, R3
ICS2 deployed in waves, mode by mode: Release 1 on 15 March 2021 (air express and postal, pre-loading dataset); Release 2 on 1 March 2023 (all air cargo, full ENS); and Release 3 for maritime and inland waterways from 3 June 2024 (carriers), 4 December 2024 (house-level filers), and road and rail from 1 April 2025. As of 2026, every mode entering the EU is covered — no flow still enjoys a transitional exemption.
UK and India: the other advance filings
After Brexit, Great Britain runs its own Safety & Security GB (S&S GB) service, separate from ICS2; entry summary declarations are now required for goods arriving in GB. India uses the Sea Cargo Manifest and Transhipment Regulations (SCMTR), which move manifest filing upstream via ICEGATE with advance timelines before arrival. The principle is universal: file accurate cargo data early, or lose the shipment window.
Two worked cases
Case 1: apparel container China → Rotterdam (ocean)
Ningbo → Rotterdam · 1 × 40' HC · ~18,000 lb
Loading cut-off: Tuesday 18:00 local
ENS due: Monday 18:00 (24 h before)
Consignee EORI supplied late, Tuesday morning
Result: ENS not validated in time → box not loaded
Cost: ~7 days to next sailing + possible demurrage
The lesson: for ocean, the ENS is a condition of departure, not an arrival formality. See our guide to checking the bill of lading, where the same data must line up.
Case 2: air express parcel India → Frankfurt (air)
Delhi → Frankfurt · express · 17 lb
PLACI description filed: "gifts"
Customs response: referral — description too vague
Fix: "cotton bed linen — HS 6302"
Result: cleared after re-filing, one flight missed
A compliant description on the first filing would have saved the missed flight. Documentary precision — packing list, invoice, exact HS code — is the real ICS2 and ACAS lever.
Plan the full landed cost, not just the filing
Security filings gate departure; the TRADE-COST calculator estimates duty, VAT and arrival charges. Prepare both ends of the chain.
Run calculation →Conclusion: security is decided before departure
Advance filings move the customs constraint upstream: an incomplete ENS or ISF is not an arrival penalty but a container that never sails. The defense is three habits — supply a valid EORI (or US importer of record) and a precise HS-coded description; lodge the house-level data within the mode's deadline; and for high-volume flows, pursue AEO or C-TPAT status to ease the risk analysis. For the UK side that runs alongside S&S GB, see our post-Brexit UK import guide.
Frequently asked questions
What is the difference between ICS2 and ISF 10+2?+
Both are advance security filings, but for different customs territories. ICS2 is the EU system: it requires an Entry Summary Declaration (ENS) before goods reach — or for containerized ocean, before they load toward — the EU. ISF 10+2 (Importer Security Filing) is the US equivalent for ocean freight: 10 data elements from the importer plus 2 from the carrier, filed at least 24 hours before the vessel loads at the foreign port. They are separate filings in separate systems; a shipper moving goods to both the EU and the US must comply with each independently.
Who is legally responsible for filing the ENS under ICS2?+
The carrier that brings goods into the EU customs territory (the ocean, air, road or rail carrier) holds the legal obligation. But ICS2 uses a 'multiple filing' model: the carrier files master-level data (the main transport contract), while a freight forwarder, NVOCC or house-level filer can lodge house-level data (the actual shipper-to-consignee consignment) directly. The EU importer is almost never the direct filer, but must supply their EORI and a precise goods description upstream, or the filing is rejected.
Can a vague description like "general cargo" pass an ENS or ISF?+
No. Under both ICS2 and ISF, the goods description must be precise enough for a security risk analysis — 'women's cotton knit tops', 'lithium-ion batteries for laptops', not 'textiles' or 'electronics'. ICS2 also requires the 6-digit HS code in the ENS dataset for most flows. A vague description triggers a referral (request for more information) at best, and for air freight a 'Do Not Load' message at worst. ISF errors carry liquidated damages of up to $5,000 per violation from US CBP.
What happens if the filing is late or missing?+
For containerized ocean freight, both the EU 24-hour ENS rule and the US ISF 24-hour rule mean the carrier will not load the container without a validated filing — the cargo stays on the dock at origin. For air, a missing pre-loading dataset can produce a Do-Not-Load, physically preventing the parcel from boarding. These are not deferred fines you settle later; they are upstream blocks that strand goods before they ever leave the origin country.
Does the UK still require a safety and security declaration after Brexit?+
Yes. Great Britain runs its own Safety & Security GB (S&S GB) service, separate from the EU's ICS2. The waiver that temporarily suspended entry summary declarations for imports into GB ended, and S&S declarations are now required for goods arriving in Great Britain. If you import into both GB and the EU, you file into two different systems. See our post-Brexit UK import guide for the customs (CDS) side that runs alongside the security filing.
Marie Fontaine
Marie leads customs research at TRADE-COST. She spent eight years in tariff classification and post-clearance audits before joining the product team to turn customs expertise into software.
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