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Structural Changes Awaiting Freight Forwarders and Carriers between the United Kingdom and the European Union Starting from 2026
2025 12 16
From the beginning of 2026, freight forwarders and carriers between the United Kingdom and the European Union will face structural changes. With the introduction of mandatory ICS2 ENS requirements for land transport and the French border ELO procedure, transport flows will become more regulated, and document management will be digitized. This is significant for both carriers and freight forwarders, as any discrepancies could directly disrupt the physical movement of goods.
Below is a clear and practical explanation of what these changes mean for carriers, freight forwarders, and cargo shippers.
ELO – New Mandatory Digital Document at the French Border
On January 1, 2026, a mandatory ELO (Obligatory Logistics Envelope) will come into effect at the French border. This is an electronic set of documents that all freight vehicles crossing the UK–FR border via ferry or tunnel must have. Without a valid ELO barcode, the vehicle will simply not be allowed to board the ferry or enter the Eurotunnel terminal.
The ELO integrates all the documents required by French customs:
- Import direction (UK → FR): it includes ICS2 ENS, the French import declaration, transit documents, and the ATA carnet, if applicable.
- Export direction (FR → UK): the ELO includes the export declaration, transit documents, and ATA carnet.
This process simplifies customs control and allows documents to be reviewed even before the vehicle arrives, ensuring faster and smoother movement of goods.
ICS2 ENS – Expanding the EU Security System to Land Transport
ICS2 (Import Control System 2) is the European Union-wide security and risk assessment system. Its primary goal is to ensure that detailed data is provided to customs before any cargo physically enters the EU territory. Previously, ICS2 applied to air, sea, postal, and courier shipments.
Starting from 2026, ICS2 will also apply to land transport crossing the UK–EU border via France and Ireland. This means that for each transport contract, i.e., each CMR, an ENS declaration must be submitted. Detailed cargo information—sender, receiver, full goods description, HS code, number of packages, weight, vehicle numbers, and estimated time of arrival—will become essential for crossing the border.
Without a valid ENS MRN, it will not be possible to generate either the ELO at the French border or the PBN in Ireland. This means that ICS2 will become the central logistical link on which the entire process depends.
Direction to Ireland: PBN and ICS2 Interaction
Unlike France, Ireland does not use the Smart Border system, so the ELO will not apply here. However, from 2026, Ireland’s PBN (Pre-Boarding Notification) can only be generated if a valid ICS2 ENS declaration has been provided. This means that carriers traveling between the UK and IE must ensure the timely submission of the ENS data.
Two Systems, Two Barcodes – Always
When transporting goods between the UK and the EU, carriers will need to manage two separate processes. The UK will always require a GMR, while the EU side will use the ELO (in France) or PBN (in Ireland).
This dual barcode system will remain permanent. It has been designed to make it easier to distinguish between national jurisdictions and control logic.
What About Other EU Destinations?
Currently, based on available data, other destinations such as Belgium or the Netherlands remain unchanged, as they have opted to apply the ICS2 requirements for sea transport. In this case, the shipping line will be responsible for the ENS declaration, just as it is under standard maritime ICS2 rules. Therefore, there are no changes for carriers on these routes.
On the other hand, France and Ireland have chosen to apply ICS2 requirements for land transport, which has impacted land carriers.
Why Prepare in Advance?
Experience shows that the introduction of new customs requirements often causes disruptions where the transport chain is most sensitive – at the border. ELO and ICS2 are additional but useful tools that help ensure greater transport security and control.
Bunastos intermediaries are already fully prepared for these new requirements: registering ENS declarations in the ICS2 system, generating ELO through the French “Pro Douane” portal, checking document compliance, and providing carriers with properly prepared documents. Without all the required documents, there is a risk of being denied entry to the ferry or even incurring fines.
2026 will mark a turning point for land transport between the EU and the UK. ICS2 ENS and ELO will change not only the format of document submission but also the entire border crossing process. To ensure uninterrupted cargo movement, companies must start preparing for the ENS submission and ensure technical readiness to work with ELO.