FREQUENTLY ASKED QUESTIONS
Import Control System 2 (ICS2) Requirements Frequently Asked Questions (FAQs)
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How can I become a self-filer to meet ICS2 requirements?
To begin, please ensure you have an EU Economic Operators Registration and Identification (EORI) number and apply for a deployment window to customs in the country where your EORI was issued. Next, to meet the ICS2 requirements, choose how you will submit the house filings and gain access to Uniform User Management and Digital Signature System (UUM & DS) portal to access the ICS2 Single Trader Interface (STI) menu option. Please note that this will require a digital certificate recognized by the country where your EORI was issued. Inform your carriers that you will be self-filing and ensure that you have knowledge of the carriers’ EORI and master bill of lading reference and information. Finally, start testing with a solution provider such as Descartes ICS2.
If an NVOCC co-loads to another NVOCC do both NVOCCs have to file for each House Bill of Lading (HBL)?
This depends on the agreement between NVOCCs. One could load for both if the other NVOCC is willing to share details. Otherwise, both NVOCCs would have to file. In such cases, the carrier will have to quote a single supplementary filer (NVOCC A) as they can only quote one supplementary filer per master bill, and then declare NVOCC B as a supplementary filer. NVOCC B will then submit their house bill details. Supplementary filers can be at the house-level or the sub-house level.
Is "personal effects" a valid goods description?
Please refer to this guidance on acceptable goods descriptions. Here, you will see that “personal effects” is one of the unacceptable terms. This means that the type of personal effects would need to be fully described. However, if both the consignor and consignee are private persons, no Harmonized System (HS) code is required.
Which ICS2 EORI number related to the HBL must be reported?
The EORIs that can be declared on a house filing include the declarant which would normally be the carrier, house bill issuer, or person holding the consignment level data; the representative if someone else is doing the submission; and the carrier who is the person who issued the master bill. Please note that these are not tied to particular roles or locations, but the declarant would normally be the person who issued the house bill, and the supplementary declarant would be the declarant on the house filing.
EU guidance indicates that the declarant is the person lodging an Entry Summary Declaration (ENS) or ENS particulars via a partial filing, made in their own name. The declarant can also be the person in whose name an ENS or ENS particulars are lodged. The declarant is responsible for the timely filing within the deadlines and the accuracy of the content of the ENS or the partial ENS filing.
Any person can appoint a representative to create and lodge the ENS or particular ENS filing in the name and on behalf of the declarant (direct representation) or in the representative’s name but on behalf of the declarant (indirect representation). In the case of direct representation, the declarant is still responsible as if they had lodged the ENS or partial ENS filing themselves as above. The direct representative is liable regarding their client but not to the customs authorities.
The representative may be a customs broker, freight forwarder, carrier, etc. Customs may ask to see evidence of the direct representation agreement or else they will be considered indirect representatives.
The supplementary declarant or house filer is a declarant issuing a house bill that chooses to not provide the relevant ENS particulars to the carrier for filing and therefore becomes a supplementary declarant. In the context of a complete ENS composed of partial ENS filings, this is a party who is indicated in another ENS filing as expected to lodge an additional ENS filing either at the house or sub-house level. A consignee may also be required to become a supplementary declarant in order to lodge buyer and seller information if it does not wish to share that information with the carrier or the house filer.
From the perspective of the master level ENS filings, the supplementary declarant is expected to lodge only an ENS filing of type 1 house level filing (Supplementary filing type) since the carrier is supposed to have a contractual arrangement with only one party at house level. Then this party can have any type of contractual relations with the other partial ENS filers (house or sub-house) for co-loading or transportation of the goods.
EORIs can also be declared for other supply chain actors and notify parties that should have no legal impact and are just used for risk analysis.
The next anticipated release for ICS2 is Release 3. In this phase, maritime filings will be required for shipments bound for the EU with the next deployment to require filings for the rail and truck modes of transport.
How would a change of consignees, post-loading from the last port of loading, be handled?
It would depend on the timing, however an amendment to the temporary storage declaration or ultimately the import declaration would need to be filed. Once arrived, the ENS cannot be amended, or you will receive a lifecycle error from ICS2.
Are there more than 3 potential filing levels when using dual filings?
Carriers and vessel operators are seen as two different roles with the carrier being the person who issued the bill of lading. Yes, the ocean carrier could make an ENS filing, but any feeder vessels should be aware as the vessel operator is expected to issue the arrival notification either directly or via a representative.
If we are registered as a house filer as an air freight mover, do we need to separately register as a maritime house filer?
You should apply for a deployment window unless you are willing and able to send maritime house filings when your carrier goes live.
To become qualified to file ICS2, would forwarders need to have a bond similar to AMS in the United States?
No, a bond is not required to become qualified to file ICS2 as is done for the U.S. Customs & Border Protection (CBP) Automated Manifest System.
Do the requests for information (RFIs) come in the form of emails?
You would not receive RFI emails directly from customs authorities, however, the Descartes system can send email alerts based on the messages received from the ICS2 system.
Do you offer a solution that covers all filing types?
We support all filing types. For house filers or sub-house filers that want to submit their own filings, they can do so with their own agreement with us and separate access to that of the carrier. They can then submit house filings for goods carried by any carrier for whom they have the carrier and master bill details and/or where they have been declared as a supplementary filer.
Providing the carrier configures their UUM & DS settings to receive ENS registrations. They will receive notifications that a house filer has been completed even if the house filer submitted them via another means to themselves, although they will not see any declared data.
How Can Descartes Help?
With a deep understanding of Import Control System (ICS) filing requirements including the ICS2 format, Descartes can help enable ICS customs compliance as regulations change. Descartes’ adaptable, turnkey architecture and extensibility for security requirements, such as the EU ICS Filing initiative, make us unique in the industry. With many countries adopting similar regulations worldwide to screen shipments before they arrive, companies can simply add new modules as they expand.