ICS2 hemp shipping EU 2025 is entering a new era. With the European Union’s Import Control System 2 (ICS2) Release 3 becoming mandatory for road and rail shipments on September 1, 2025, exporters of CBD and industrial hemp to Europe face some of the biggest regulatory shifts in years. If you’re an operator, compliance officer, or brand manager in the sector, this guidance will help you navigate new pitfalls—from house‑level data entry to heightened seizure risks for cannabinoid-labeled goods.
What Is ICS2 Release 3—and Why Does It Matter?
ICS2 is the EU’s advanced customs security program for goods entering or transiting the union. Release 3 requires that Entry Summary Declarations (ENS) be filed at the house bill level for all transport modes—not just air, but, as of September 2025, also road and rail. This means:
- You must supply detailed shipment-level data before transport reaches the EU, for each individual package or pallet.
- ENS filings must now include precise product descriptions, six-digit Harmonized System (HS) codes for every SKU, and (where applicable) value-added tax details.
- Shipments without robust data may be flagged, delayed, refused entry, or—for sensitive commodities—subjected to Do Not Load (DNL) outcomes and seizure.
Recent guidance from FIATA, global carriers, and EU customs agencies underscores the seriousness: incomplete or inaccurate filings sharply increase the odds of enforcement, audits, and product confiscation.
Critical Compliance Points: House‑Level ENS and Data Quality
House‑Level ENS Filing
For every shipment, especially by road and rail:
- File an Entry Summary Declaration that breaks down parcels to the house bill or consignment-noted package.
- Who Files? Often the forwarder or customs broker, but exporters must provide fully accurate product detail.
ENS must reflect:
- Precise HS codes: Six-digit minimum (use eight digits if available).
- Clear product descriptions: Avoid vague terms like "plant extract" or "hemp products." State, for example, “hemp seed oil for cosmetics” or "CBD isolate, non-narcotic, for food supplements as permitted.”
- IOSS/VOEC registration: E-commerce shipments must link to valid VAT import numbers, especially post-Brexit and for B2C trade.
For best practice tips, see: UPS ICS2 Requirements Overview and NCBFAA Compliance Webinar.
Proper HS Codes and Descriptions for Industrial Hemp and CBD Products
EU border officials are now trained to identify incomplete or misleading entries. Here’s what is accepted—and what’s risky:
Common HS Codes for Non-Narcotic Hemp
- 1207.99 — Hemp seeds (not for sowing)
- 1211.90 — Plants and parts of plants (including hemp flowers/leaves for non-narcotic use)
- 1515.90 — Hemp seed oil and fractions
- 1302.19 — Vegetable saps and extracts (incl. hemp extract, provided THC is below threshold)
- 3004.90 — Medicaments (if product is sold as a medicine and registered accordingly)
- 3304.99 — Beauty or skincare products (cosmetics containing hemp/CBD)
- 2106.90 — Food preparations (CBD/other supplements, as national laws allow)
Product Descriptions—What Regulators Want to See
- For hemp textiles: “Woven fabric of true hemp, untreated”
- For cosmetics: “Face cream containing hemp seed oil, THC free”
- For supplements: “Food supplement, isolated CBD, THC <0.2%” (if permitted in destination country)
- Avoid “CBD” where not explicitly permitted for that product type; use "non-narcotic hemp extract" unless otherwise authorized.
Member State Red Flags: CBD Food, Oils, and Local Bans
The European Food Safety Authority (EFSA) and individual EU states are cracking down on unauthorized CBD foods:
- Many member states prohibit CBD as a food ingredient pending EFSA novel food approval (read more on EFSA 2025 update).
- France: Accepts CBD in foods and supplements at up to 0.3% THC, as long as the product is authorized (France CBD 2025 import guide).
- Sweden: Zero tolerance; any detectable THC (even trace) triggers seizure risk (Sweden 2025 CBD blog).
- Italy: Currently criminalizes oral and flower-based CBD, even from certified hemp, following new 2025 law changes (Italy 2025 CBD ban).
- Germany, Spain, and others: Allow cosmetic use, but food supplements remain unresolved pending EFSA and national approval.
👉 Brand Takeaway: Always screen SKUs for compliance with the destination country’s rules—don’t trust that “legal in the EU” means legal everywhere.
Carrier and Customs Risks in Late 2025: Do Not Load, Seizure, and Penalties
ICS2 dramatically increases the consequences for hemp- and cannabinoid-labeled shipments:
- Do Not Load (DNL): Major carriers (ocean, air, rail) are now issuing DNL instructions when HS codes or descriptions are unclear or reference regulated substances.
- Border Holds and Seizure: Customs will detain shipments flagged as potentially narcotic, incompletely declared, or in violation of local CBD bans.
- Fines and Audits: Incomplete ENS data—especially for goods marked as “extract,” “CBD,” or “cannabinoid”—can result in substantial penalties under customs and tax rules. Enforcement is now digital and rapid via ICS2 database integration.
- Carrier Reporting: ICS2 requires shipping lines and integrators to transmit data exactly as received from shippers—misaligned schemas or incomplete data may mean your shipment doesn’t even leave origin.
Operational Guidance: Steps to Navigate ICS2 Hemp Shipping EU 2025
1. Screen Products and Markets
- Inventory every SKU for hemp, CBD, or related keywords.
- Map each product to permitted uses in the target member state (cosmetic, textile, food, supplement).
- Remove or flag any SKUs that violate local restrictions.
2. Assign Proper HS Codes and Clear Descriptions
- Use official HS codes for each SKU. Avoid generic codes that could trigger review.
- Descriptions should reflect end use and comply with carrier and ICS2 schemas.
- Regularly review updated guidance from the European Commission Taxation and Customs Union.
3. Coordinate with Carriers and Brokers
- Confirm ENS data is submitted at the house-bill/package level.
- Align descriptions and codes across your ERP, warehouse, forwarder, and carrier systems.
- Get written carrier confirmation on acceptance/clearance of any cannabinoid-labeled goods.
4. Use Valid IOSS/VOEC Numbers for B2C Shipments
- For e-commerce, importers must integrate Import One-Stop Shop (IOSS) or Norway’s VOEC into invoice and customs data.
- Mismatches or missing data will cause carrier refusals under ICS2.
5. Prepare for (and Mitigate) Seizure Scenarios
- Keep all certificates of analysis, origin, and lab results available for every shipment.
- Document the legal and regulatory status of each SKU in the receiving country.
- Work with specialized customs brokers who understand ICS2 and cannabinoid regulation.
Final Thoughts: Stay Proactive to Avoid Disruption
ICS2 Release 3 is not just another customs upgrade—it’s a real test of compliance sophistication for the European hemp and CBD sector. Shipments that once slid by may now face immediate seizure or months-long review if data is incomplete or misaligned. Regulatory harmonization is still lacking at the member state level, making precise compliance and market-specific due diligence more important than ever.
Stay ahead of the curve by consulting regularly updated regulatory intelligence. For real-time support in mapping ICS2, HS codes, and EU member state restrictions for your products, visit CannabisRegulations.ai—the industry’s trusted resource for cannabis compliance.
