Freight forwarding and international logistics

• Regulation (EU) No 952/2013 — Union Customs Code and ICS2
• Regulation (EU) 2016/679 — GDPR, Article 27
• Regulation (EU) 2019/1020 for goods entering the Union
• Directive 2008/68/EC for dangerous goods

Who has to appoint one

Forwarders and logistics providers outside the Union handling shipments into the EU. Advance cargo information under ICS2 must be lodged before loading, and the party lodging it bears responsibility for its accuracy.

Thresholds and exemptions

ICS2 applies to all consignments entering the customs territory, with the obligations phased by transport mode. Postal and express consignments were the first phase.

What must appear on the label

Not a labelling obligation. What matters is the data quality of the advance filing: precise goods descriptions, HS codes and consignee details, since vague descriptions are rejected.

Marketplace fields

Carriers refuse bookings where advance filings are incomplete, and a rejected filing means the consignment cannot be loaded. This is now the main operational gate for cross-border e-commerce.

Documentation you must hold

EORI registration, customs representation mandates from clients, ICS2 filings with the required data elements, transport documents, dangerous goods documentation where applicable, and GDPR documentation for the consignee data processed.

Standards and testing

Not applicable, though data quality is machine-assessed and poor descriptions trigger holds automatically.

Language requirements

Filings in the language and format of the customs system, and client documentation in the market language.

When it applies

Advance filings before loading for air and before arrival for other modes, per the ICS2 timelines.

How long records are kept

Customs and transport records for the periods set nationally, generally three to ten years.

What happens if you do not comply

Consignment holds and refusals, penalties for inaccurate filings, and joint liability where the forwarder acts as indirect representative. Product compliance failures now also surface at the border through Article 4 checks.

Who enforces it

National customs authorities, transport regulators and data protection authorities.

Where the boundary lies

Consignee names and addresses are personal data processed at scale, and forwarders outside the Union need their own Article 27 representative. Customs and product compliance have converged: a consignment can be held because the goods lack an EU economic operator, not because the paperwork is wrong.

Questions we are asked

Who is responsible for the ICS2 filing?

The carrier is responsible for the entry summary declaration, though other parties may lodge elements. Inaccurate data is attributed to whoever lodged it.

Do forwarders need a GDPR representative?

If established outside the Union and processing consignee data of people in the EU, yes.