If your company imports regularly from China or Southeast Asia, you may have noticed something changing in recent months. Shipments that cleared without issue last year are now being held. Carriers are rejecting certain consolidated consignments. And customs brokers are asking for data you have never needed before.
This is not random. Three major changes are now fully in effect or phasing in during 2026:
- ICS2 (Import Control System 2) – complete safety and security data required before loading
- Stricter enforcement of VAT reverse charge on cross-border B2B imports
- Carriers refusing mixed-goods LCL shipments due to incomplete or mismatched declarations
RELATED INTELLIGENCE
ICS2 Stop-Words Update August 2026: The European Commission recently updated the prohibited data triggers. Read the ICS2 Stop-Words Update and avoid customs holds →
Below we explain each change in plain language, then give you a practical pre-clearance checklist.
ICS2: What changed and what you must send
ICS2 is the EU’s upgraded customs risk management system. The key change for importers: you (or your logistics partner) must submit full Entry Summary Declaration (ENS) data 24 hours before loading goods onto a vessel or aircraft.
In practice, this means:
- Complete shipper and consignee name/address
- Precise HS code (6 digits minimum, 10 digits preferred)
- Item description – no vague terms like “gift” or “samples”
- Gross weight and package count
- EORI number of the EU importer of record
If any field is missing or inconsistent, the carrier receives a “do not load” message.
Why carriers are refusing mixed goods – LCL (less than container load) shipments that combine different product categories (e.g., electronics + textiles + spare parts) under one vague HS code trigger manual reviews. Carriers have started rejecting such shipments outright because the administrative cost of fixing the declaration at the transshipment port is too high.
Hansato insight: We pre-validate every supplier’s packing list and invoice against ICS2 schema before the container is stuffed. This avoids “do not load” events that add 10–14 days to transit.
VAT reverse charge: A compliance trap for unprepared buyers
The EU’s VAT reverse charge mechanism is not new, but enforcement has increased sharply in 2025–2026.
Here is how it works for B2B imports:
- You (the EU buyer) are responsible for reporting VAT in your own country’s VAT return – not paying it at the border
- Customs will still require proof of your valid VAT number and EORI
- If your local tax authority does not see the import declared on your return, you face penalties and a compliance flag
The trap: many procurement managers assume their freight forwarder handles “everything”. Forwarders handle customs clearance but do not file your VAT return. That is your obligation.
Concrete consequence: An importer in Germany recently received a €12,000 penalty for missing reverse-charge declarations on six shipments from China. The goods cleared customs but the tax authority audited 18 months of imports.
What a complete pre-clearance package looks like
If you want zero customs delays and a carrier that accepts your mixed-goods LCL, send your logistics partner this checklist before the goods leave the factory:
| Document | Required for ICS2 | Required for VAT reverse charge |
|---|---|---|
| Commercial invoice (detailed line items) | Yes | Yes |
| Packing list (weight, cartons, dimensions) | Yes | No |
| Supplier’s declaration of origin (optional but recommended) | No | No |
| Valid EU EORI number | Yes | Yes |
| Valid EU VAT number | No | Yes |
| HS codes (10 digits per product line) | Strongly recommended | No |
The most common single error: using the supplier’s description (“multi-function device”) instead of the customs description (“electrical apparatus for switching or protecting circuits, <1000V”).
Three questions to ask your current logistics partner today
If you work with a forwarder or customs broker, ask them:
- “Do you run pre-loading ICS2 validation on all supplier docs from China?”
- “Will you reject a mixed-goods LCL shipment if HS codes are incomplete?”
- “Do you provide a post-clearance report for our VAT reverse-charge filing?”
If they hesitate on any answer, your supply chain has a hidden risk.
How Hansato Europe OÜ handles this
Hansato is not a general freight forwarder. We are a supply chain services company that integrates Asia logistics with EU trade compliance.
For every client importing from China or Southeast Asia, we:
- Pre-validate all supplier documents against ICS2 schema before the container is loaded
- Act as direct customs broker (not a subcontractor) for import entry in Germany, Netherlands, Poland, and the Baltics
- Provide a monthly import summary for your VAT reverse-charge filing
- Refuse to ship mixed-goods LCL without complete 10-digit HS codes per product line – because clearing a customs hold costs more than delaying a sailing by 48 hours
Not ready for a full engagement? No problem. We also offer one-time pre-clearance audits for €390 – we review your last three shipments and flag every ICS2 or VAT risk.
Last updated: August 2026
Hansato Europe OÜ – B2B supply chain services from Asia to the EU
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