The transport and logistics sector, particularly for operations involving France, stands on the brink of significant change. From 1 September 2025, France will introduce new, stricter customs procedures aimed at streamlining operations and enhancing cargo security. While these updates are designed to optimise clearance processes, they also impose new responsibilities and challenges for all stakeholders – from carriers and freight forwarders to logistics operators.
The most significant changes involve the mandatory Entry Summary Declaration (ENS) under the ICS2 (Import Control System 2) framework and its strict integration with the new tool: ELO (Enveloppe Logistique Obligatoire). Non-compliance will result in denied ferry boarding and major delays in deliveries. This in-depth guide explores these changes, their implications, and practical steps businesses should take to ensure smooth operations after 1 September 2025.
What Is ICS2 and Why Does It Matter?
ICS2, the Import Control System 2, is an advanced EU platform designed to improve the security and customs oversight of goods entering the EU. Replacing ICS1, it allows customs authorities to perform enhanced risk assessments before goods arrive on EU territory.
Key ICS2 milestones:
- Phase 1 (October 2021): Postal and express consignments by air.
- Phase 2 (March 2023): Air carriers.
- Phase 3 (April 2025): Road, rail, maritime carriers, including unaccompanied trailers on ferries.
- Phase 3.2 (September 2025): Full implementation for all modes of transport in France, with mandatory ENS-ELO linkage.
From 1 April 2025, all road and rail carriers transporting goods into the EU must submit an ENS in ICS2. From 1 September 2025, France will introduce additional, stricter requirements.
ENS Under ICS2: What Will Change?
The ENS (Entry Summary Declaration) is an electronic document detailing goods entering the EU. From 1 September 2025, for all shipments to France, the ENS must comply fully with ICS2 requirements.
Key changes:
- More detailed data: At least a six-digit HS code, precise goods descriptions, and full details of all parties involved (seller, consignor, consignee, carrier, forwarder).
- Earlier submission: ENS must be filed well in advance of goods arrival (before loading or departure for road and rail transport).
- MRN issuance: Each ENS generates a unique MRN (Movement Reference Number), which must be embedded in the ELO.
- Carrier responsibility: While carriers can authorise customs agents to submit ENS, legal responsibility remains with the carrier.
- Exemptions: Goods coming directly from Northern Ireland are exempt from ENS requirements.
Consequences of missing or incorrect ENS:
- Cargo detention at the border until corrected.
- Significant delays due to resubmission and verification.
- Additional costs for storage, demurrage, or administrative penalties.
ELO (Enveloppe Logistique Obligatoire): France’s New Digital Tool
ELO, or Mandatory Logistics Envelope, is a new French digital system consolidating all required customs documents into a single package represented by a unique barcode. It becomes mandatory for all vehicles (loaded or empty) entering France via RoRo ports (Calais, Dunkirk, Le Havre, etc.) or Eurotunnel from 1 September 2025.
What does ELO include?
- ENS (Entry Summary Declaration): The MRN generated by ICS2 is embedded in the ELO.
- Customs documentation: Export, import, and transit MRNs.
- Cargo and vehicle data: Including phytosanitary/veterinary certificates when applicable.
- Vehicle registration link: The ELO barcode ties to the truck’s registration plate.
How does it work?
- The driver must present the ELO barcode (printed or digital) at the border.
- Scanning the ELO triggers verification of all declarations (including ENS).
- If accepted, clearance is granted without additional questioning.
Key benefits:
- Faster clearance and reduced time at terminals.
- Fewer errors thanks to automatic data verification.
- Better shipment tracking with online access to movement history.
Important notes:
- ELO does not replace the UK GMR (Goods Movement Reference). Both must be generated separately.
- ELO is mandatory for transit goods passing through France.
- ELO is valid for 30 days, but must be updated if data changes.
Key Rules from 1 September 2025
For all shipments to France:
- ENS under ICS2 is mandatory for all modes of transport.
- MRN from ENS must be embedded in ELO.
- No ELO, no boarding: Ferry and Eurotunnel operators will deny entry to vehicles without valid ELO.
Preparing Your Business: A Practical Roadmap
- Training & Education:
- Train staff on ICS2 and ELO procedures.
- Prepare clear driver instructions for ELO barcode use at terminals.
- Process Review:
- Map your current customs documentation workflows.
- Assign clear responsibilities for ENS submission and ELO generation.
- Develop contingency plans for rejected ENS/ELO.
- IT Integration:
- Ensure your TMS/WMS can handle ICS2-compliant data.
- Integrate with Prodouane (French customs portal) for ELO creation.
- Verify that your company has a valid EU EORI number.
- Partner Coordination:
- Communicate with shippers: Ensure they provide complete data (HS codes, goods descriptions) in advance.
- Work with customs agents experienced in ICS2 and ELO.
- Align with carriers/forwarders on roles and information flows.
- Testing & Optimisation:
- Use the pre-implementation testing phase to identify issues.
- Monitor clearance times and adjust processes as needed.
Impact on Supply Chain Stakeholders
Road Carriers:
- Primary responsibility for compliance.
- Risk of denied boarding and delays without valid ELO.
- Need to equip drivers with ELO barcodes and training.
Forwarders & Customs Agents:
- Key role in ENS submissions and ELO generation.
- Increased workload and need for system integration with Prodouane.
Importers & Exporters:
- Must provide complete and accurate data (HS codes, goods descriptions) early.
- Should anticipate additional costs for new customs procedures.
Ferry Operators & Terminals:
- Responsible for enforcing ELO compliance at boarding.
- Need to maintain infrastructure for fast barcode scanning.
Conclusion
From 1 September 2025, France’s customs clearance process will undergo a digital transformation with the mandatory ENS-ELO framework. Carriers, forwarders, importers, and exporters must adapt to avoid costly delays and disruptions.
Multica Logistics is ready to guide your business through these changes. We provide end-to-end customs and logistics support, including ENS submissions, ELO generation, and compliance advisory.
Contact us today to ensure your operations remain smooth, compliant, and competitive in the post-September 2025 landscape.
