French Customs has published updated guidance on how road hauliers must file Entry Summary Declarations (ENS) under the EU’s Import Control System 2 (ICS2) when crossing the UK–France “Smart Border.” The note confirms that the use of the Enveloppe Logistique Obligatoire (ELO) will not become mandatory until early 2026, extending the transition period originally set to end this year.
The French Customs Directorate (DGDDI) says the update aims to simplify the transition to ICS2 for freight moving between the UK and the EU by ferry or rail. Although the ELO requirement has been delayed, operators are urged to adapt their systems now, as the new filing rules under ICS2 already apply.
What changes under ICS2
ICS2 for road and rail freight has been operational since April 2025, but not all EU countries have enforced it yet. Under the new system, hauliers, freight forwarders or customs representatives must file an Entry Summary Declaration (ENS) containing detailed safety and security data ( such as consignor, consignee, HS code and goods description) before the vehicle reaches the EU border, typically at least one hour in advance.
France has extended its transition period for ICS2 until 31 December 2025, with full enforcement expected to begin in early 2026.
In practice, the new system means that every operator crossing from the UK into France must file an ENS through the EU’s ICS2 portal and include the vehicle registration and, for ferry transport, an IMO number corresponding to one of the vessels on the route.
French Customs recognises that the exact ferry may not be known at the time of filing; therefore, a “workaround” allows hauliers to enter any IMO from an approved list to ensure the declaration is accepted.
How the ELO system fits in
The ELO is a digital “logistics envelope” that groups all customs references, including the ENS Master Reference Number (MRN), import or export declarations, and any sanitary or phytosanitary documents, into a single barcode. This barcode must be presented by the driver at the ferry or Eurotunnel check-in. Scanning it links the shipment to customs systems and automatically triggers risk analysis and lane assignment (green or orange).
Once the ELO becomes mandatory in 2026, any truck or trailer arriving at a French port without a valid barcode will likely be refused boarding or sent for manual inspection.
Responsibilities and penalties
According to the DGDDI, the ENS must always be submitted before the vehicle reaches the port, and the haulier or their representative is responsible for ensuring that the information is complete and accurate. Failure to lodge an ENS can result in goods being held, delayed, or refused entry.
While the customs note does not specify fine amounts, France’s Customs Code allows penalties between €300 and €3,700 for incomplete or missing declarations, in addition to potential confiscation of goods. More often, however, the consequences are operational: missed ferry slots, demurrage charges, and delays in delivery.
Northern Ireland exemption
The French guidance confirms that shipments coming directly from Northern Ireland remain exempt from the ENS obligation, reflecting the continued application of the Windsor Framework.
Prepare early despite postponement
Although the full enforcement of ELO has been postponed until 2026, French Customs makes clear that the ICS2 system is already live and all operators must now file ENS declarations electronically.
Hauliers are therefore advised to:
- ensure that their ENS filings are submitted via ICS2 before each UK–EU crossing,
- work with customs agents or digital platforms capable of integrating ELO barcodes, and
- train drivers to present the ELO barcode (once implemented) at ticketing.
The update, French Customs stresses, is intended to “secure and simplify” the border process. But for operators, it means a growing digital workload, one that will soon become compulsory for every truck crossing from the UK into the EU.
ICS2 and France’s Smart Border: what applies and when
The rollout of the EU’s Import Control System 2 (ICS2) and France’s Smart Border system is taking place in several stages. This timeline explains what hauliers can, must, and will have to do at each phase.
April 2025: ICS2 operational for road and rail
ICS2 becomes technically live for all non-EU goods entering the Union by road, rail, or unaccompanied trailer.
Hauliers can already file Entry Summary Declarations (ENS) in ICS2 before goods arrive at the EU border.
1 September 2025: official EU start date for ICS2
The European Commission sets this as the date when ICS2 should become mandatory for all road and rail freight entering the EU.
However, Member States may request a transition period until 31 December 2025.
7 October 2025: France confirms transition period
French Customs (DGDDI) publishes an updated note confirming that France will use the transition period until 31 December 2025.
During this time, hauliers can and should file ENS declarations in ICS2, but enforcement is not yet strict and penalties are suspended to allow adaptation.
Early 2026: ELO becomes mandatory
France’s Enveloppe Logistique Obligatoire (ELO – the Smart Border’s digital envelope linking ENS, import, export and transit declarations) will become mandatory for all trucks and trailers crossing from the UK.
From this point, hauliers must file ENS declarations in ICS2 before arrival and present a valid ELO barcode at the ferry or rail terminal.
