Guidance for Freight Forwarders on ICS2 Release 3: Ensuring Compliance and Control in Maritime Sector Operations

FIATA and CLECAT (the European Association for Forwarding, Transport, Logistics and Customs Services) have jointly issued an informative and timely Guidance Note for freight forwarders on the European Union’s Import Control System 2 (ICS2) Release 3 regulation impacting the maritime sector. This guidance document emphasises the importance of early action for freight forwarders globally to ensure compliance, maintain control over house-level data, to prevent disruptions and ensure compliance under the ICS2 Release 3 for the maritime sector. 

Freight forwarders acting as carriers must take proactive steps to protect their business by becoming house level filers and maintaining control over house-level data and do not rely on shipping lines for house-level filings and sharing sensitive commercial data unless necessary. Freight forwarders should prioritise formal agreements, technical readiness, and internal coordination to navigate these challenges effectively and secure compliance with ICS2 Release 3 requirements. 

The chapters of this guidance outline essential actions, technical requirements, and process-driven practices to help freight forwarders globally to navigate the ICS2 Release 3 requirements.

Key considerations for the freight forwarders include:

• Prioritising registering as house-level filers to maintain control over their house-level data by 1 November 2024.
• Ensuring data accuracy and timeliness to prevent delays, potential sanctions, and supply chain disruptions. Freight forwarders are advised to establish robust data collection processes and secure clear communication channels with shippers/clients to meet specific data requirements, including HS codes and consignee EORI numbers. Additionally, freight forwarders can refer to FIATA-GSF Guidance Note on Enhancing Data Quality and Information Exchange for the EU ICS2 regime for additional information.
• Achieving technical readiness by establishing a direct interface with ICS2, either through an in-house solution or by partnering with a certified IT service provider, to ensure system compatibility well before the April 2025 deadline.
• Establishing formal agreements with shipping lines to clarify roles in data submissions, especially under the multiple filing option. FIATA’s Bilateral Model Agreement for Multiple Filing offers a foundation for formalising responsibilities and protecting commercial data.

FIATA Members are encouraged to review this guidance, and FIATA Association Members should share this document with their respective members.

For further guidance, we invite you to check to the latest ICS2 Release 3 guidance materials available on the EU Commission's ICS2 webpage.

Click here for the ICS2 Release 3 Maritime: Best Practices for Freight Forwarders