What is the ENS, and Why Does It Matter?

The Entry Summary Declaration (ENS) is a cornerstone of the EU’s Import Control System 2 (ICS2), a customs pre-arrival security and safety program designed to protect the single market from risks like hazardous materials or prohibited goods. For bulk liquid shippers, this is particularly significant—whether you’re transporting flammable liquids in isotanks or sensitive commodities in flexitanks, the ENS ensures EU customs authorities have advance visibility into your cargo before it reaches their borders.

Originally introduced in 2011, the ENS requirements have evolved under ICS2 to enhance security and streamline trade. The latest phase, Release 3, rolled out in 2024 and extends to maritime, inland waterway, road, and rail transport. 

Key Updates to ENS Filing Requirements in 2025

As of early 2025, the ENS landscape continues to shift, with full implementation of ICS2 Release 3 now in effect for maritime and inland waterways (since June 3, 2024) and road and rail transport compliance kicking in on April 1, 2025. Here’s what’s new in Q2 and how it impacts bulk liquid transport:

1. Expanded Scope Across Transport Modes
   Previously focused on air and sea, ICS2 Release 3 now mandates ENS filings for all goods entering the EU, including those moved by road and rail. For bulk liquid shippers using flexitanks on trucks or trains after ocean transport, this adds a layer of complexity. You’ll need to ensure ENS data is filed not just for the maritime portion but also for any subsequent land transport within the EU.
2. Tighter Deadlines for Maritime Shipments
   For containerized cargo like flexitanks or isotanks shipped by sea, the ENS must be submitted at least 24 hours before loading at the port of origin. This timeline aligns with our operational planning at FGN, but it emphasizes the importance of early coordination between shippers, carriers, and forwarders. Missing this window can delay loading or result in penalties.
3. Detailed Data Requirements
   The ENS now demands a comprehensive dataset, including:
   • Shipper and consignee details (with EORI numbers where available)
   • Notify party information (mandatory for “to order” bills of lading)
   • A 6-digit HS code for each commodity line—critical for classifying liquids like chemicals or oils
   • Detailed cargo descriptions, weight, and container numbers
   • Payment method codes for transport charges
     For bulk liquids, precision is key. Vague descriptions like “liquid cargo” won’t cut it—customs expects specifics, such as “vegetable oil in flexitank” or “sulfuric acid in isotank,” to assess risks accurately.
4. House-Level Filing Responsibility
   While ocean carriers file the Master Bill of Lading ENS, forwarders such as FGN are responsible for submitting House Bill of Lading data for individual shipments. This dual-filing system ensures granular oversight, particularly for consolidated shipments where multiple liquids might share a container.
5. EORI Numbers: A Must-Have
   An Economic Operators Registration and Identification (EORI) number is now mandatory for all parties involved—shippers, consignees, and forwarders. 

How This Impacts Bulk Liquid Transport

For those of us in the bulk liquid business, these updates bring both challenges and opportunities. Bulk liquids often involve hazardous materials or temperature-sensitive goods, making compliance with security protocols non-negotiable. The 24-hour pre-loading ENS deadline for maritime shipments means we need your shipment details—HS codes, container numbers, and safety data—well in advance. Delays in providing this information could push your cargo to the next vessel, impacting delivery schedules.

On the other side, the enhanced visibility offered by ICS2 can expedite customs clearance for compliant shipments. At FGN, we’ve fine-tuned our processes to handle these requirements efficiently, ensuring your isotanks of industrial chemicals or flexitanks of wine arrive on time and hassle-free.

Practical Tips for Compliance

To help you navigate these changes, here are some actionable steps:

• Start Early: Share shipment details with us as soon as possible to meet the 24-hour maritime deadline. 
• Verify HS Codes: Double-check your 6-digit HS codes—misclassification can trigger customs holds, especially for hazardous liquids.
• Secure an EORI Number: If you don’t have one, apply now through an EU customs authority.
• Partner with Experts: Lean on FGN’s expertise in bulk liquid logistics. We’ll handle the ENS filings, coordinate with carriers, and keep you compliant.

Looking Ahead

The new ENS requirements are here to stay, and as ICS2 Release 3 fully rolls out, staying proactive is of the utmost importance. At FGN Global Logistics, we’re committed to simplifying this process for you, whether you’re shipping a single isotank or a full flexitank consignment. Have questions about how these rules affect your next shipment? Contact our team today—we’re here to keep your liquids moving safely and efficiently across borders.