Update on Import Control System 2 (ICS2) mandatory Partial Filing Requirements

20 Jul 2026

With reference to our communication dated 19 May concerning ICS2 Partial Filing Rijeka and Koper | Maersk, we wish to reaffirm that the EU ICS2 regulations are now operational at the ports of Rijeka, Ploce (Croatia) and Koper (Slovenia).

Customers are requested to ensure full compliance with the applicable Full and Partial Filing requirements under the EU ICS2 framework. Non-compliance may result in additional costs and potential shipment disruptions.

For comprehensive filing guidelines, Click Here

During the coming weeks, port authorities throughout Europe will progressively enable their Risk Management Systems (RMS) to validate the completeness of Entry Summary Declaration (ENS) filings submitted by economic operators, in accordance with the ICS2 layered filing framework.

Cost Implications

The Merchant, who is responsible for all requirements of customs, port and other authorities, including the subsequent partial filing to the EU ICS2 system, will be liable for all costs, duties, taxes, fines, imposts, expenses or losses incurred or suffered by the Maersk due to any ICS2 deficiency-related HOLD, including but not limited to the following:

1. If the container is blocked by customs authority at the final discharge port:

• Storage/Demurrage, Detention/Combined Detention charges in accordance with Maersk tariff and discharge port.
• Additional yard move charges in accordance with Maersk tariff or the applicable terminal tariff where such charges are exceptionally billed to the carrier by the terminal.

2. If the container is blocked by customs authority at the transshipment port

• Combined Detention charges shall apply in accordance with the applicable Maersk import tariff from the planned loading date of the subsequent vessel until the cargo has been loaded on board.
• Transshipment/Import storage charges in accordance with the applicable tariff, calculated from the planned loading date of the subsequent vessel until the cargo has been loaded on board.
• Additional yard move charges shall be payable in accordance with the Maersk Container Shifting Origin tariff or, where applicable, the terminal's tariff where such charges are exceptionally passed on to the carrier by the terminal. Charges apply per container for each yard move event arising from one or more loading postponements.

Total amount due at transshipment port/s (reference to item 2. Above) will be billed under charge name “Manifest Pendencies or Amendments” (PAM): This service covers additional costs to carrier due to shipper’s failure to submit information or amendments requested after certain deadlines. Additional costs include out of pocket operational expenses incurred by carrier such as re-nomination, shifting, port storage, administrative charges, manifest amendment, etc. Any consequential expenses incurred. are not covered under PAM and those costs will have to be invoiced separately as allowed per tariff or contract.

For short sea services, cargo may be retained on board – at Carrier’s option - pending receipt of the required EU ICS2 partial filing. Any costs arising from such retention shall be borne by the Merchant.

Customer Action Required

To avoid disruptions, we strongly request you to:

• Ensure timely submission of HBL or Buyer and Seller data to STI for partial filing cases at least 24 hours prior vessel arrival at compliance load port
• Align with your filing party (forwarder/BCO) to ensure compliance before cargo cut-off

Keynote: These measures are part of the EU-wide ICS2 compliance framework, and similar enforcement may be extended to other ports.

Should you have any questions, please feel free to reach out to your customer service representative.

We appreciate your business and look forward to continuing our work together.