NCTS Phase 6 and ICS2: Data Required for One Declaration

A truck approaching the Bulgarian border has its transit declaration ready, but the entry summary declaration (ENS) in ICS2 is still incomplete. The carrier must submit the ENS at least one hour before arrival, while the consignor is still looking for the consignee's EORI number. NCTS Phase 6 can combine these two declarations in a single channel. This requires complete data and the relevant countries to have enabled the option.

On 26 October 2026, the European Commission announced that Phase 6 was live in 27 EU member states and the countries of the Common Transit Convention, 41 countries in total. Turkey is one of them. Turkey has operated under the opt-out model since 1 June 2026; transit declarations originating in Turkey do not carry ENS data.

What Do Opt-in and Opt-out Mean?

Each customs administration chooses one of two options. Under opt-out, ENS information is not included in the transit declaration and the ENS is submitted directly to ICS2. Under opt-in, ENS information is added to the transit declaration, NCTS Phase 6 connects to ICS2, and risk analysis and control decisions are processed through ICS2. The Commission permits only a complete ENS to be submitted with the transit declaration. An opt-out country can later move to opt-in.

A combined declaration does not depend on the decision of a single country. The DG TAXUD B1 presentation for Common Transit countries lists four conditions. The customs office of departure must be technically ready to accept the combined declaration and must have an interface to the Transit ENS bridge (TED) connected to ICS2. The same two conditions apply to the customs office of first entry into the EU.

The Commission's State of Play document (v035), dated 5 August 2026, shows 9 of its 40 listed entries as opt-in: Bulgaria, Estonia, Croatia, Latvia, Montenegro, Poland, Serbia, Slovakia and Ukraine. Germany, Greece, Hungary and Romania are opt-out. Poland's start date is 3 August 2026. The table may change as the document is updated; the Commission's news item does not link to the current version, so check the table again when planning each shipment.

The Situation in Turkey: Opt-out and a Separate ENS

A letter from the Mediterranean Exporters' Associations dated 1 June 2026 relays information that the Ministry of Trade sent to the Turkish Exporters Assembly. Turkey had initially aimed to move to Phase 6 under opt-in. Technical and scheduling requirements led to opt-out being selected for the first stage. The transition from Phase 5 to Phase 6 took place during the night of 31 May to 1 June 2026. The State of Play document also shows Turkey as opt-out with the date 1 June 2026.

According to the same letter, only code "2" (EXS only) is sent as the security indicator in T1/T2 declarations departing from Turkey. The entire data set declared under code "3" (ENS + EXS) in Phase 5 continues to be entered with the same content in Phase 6. Data entry for national transit declarations has not changed.

The ENS, however, follows a separate flow from the transit declaration. The Ministry of Trade announcement of 21 May 2026 says that the ENS is submitted under ICS2 and must be sent electronically at least one hour before the goods arrive at the point of entry. The announcement gives three scenarios. When the first entry is into Bulgaria, the ENS obligation arises in Bulgaria. If the goods enter via Greece, leave the EU security area and re-enter through Hungary or Croatia, a second ENS is required. The Ministry also states that "there is currently no difference" between the entry country being opt-in or opt-out. This outcome is consistent because the office of departure is opt-out.

Exporters and logistics partners sending goods to the EU by road or rail are the source of the ENS data. In Turkey's implementation, the carrier is responsible for submitting the declaration on time. Businesses carrying out only national transit fall outside the ENS flow described in this article. A business filing a declaration originating in Turkey cannot currently use the combined declaration either. The sources provide no information on Turkey's opt-in date.

How Does the Same Shipment Stay Consistent in Three Places?

The fictional scenario below shows where the data breaks down. A groupage truck travelling from Gebze to Germany carries goods for three consignees. The route passes through Bulgaria. The ERP holds order and product data, the forwarder consolidates the load, and the carrier submits the ENS.

The Commission's NCTS 5 trader note also sets out three limits. Each transit declaration corresponds to one master consignment. A declaration can contain no more than 1999 house consignments and 1999 goods items. An export MRN cannot be used in more than one transit declaration.

According to the Irish Revenue's ICS2 presentation, the consolidator must provide house-level data to the road carrier for groupage cargo. The carrier submits the ENS. In accompanied road transport, only one party can submit the ENS, using the complete data set. The presentation dates from 2025 and expected multiple filing for road transport to arrive in 2026; check the current status in the Commission's Multiple filing factsheet.

For this shipment originating in Turkey, the same goods information is entered in two places. The declaration holder prepares the transit declaration, while the carrier prepares the ENS. If the information follows two different paths from the ERP, it can diverge. The benefit of the opt-in model lies in one data set and one entry.

One Declaration or a Separate ENS? The Decision Rule

The decision comes down to four questions.

1. Is the customs office of departure opt-out? If so, submit the ENS separately. This is the current situation for shipments originating in Turkey.
2. If the office of departure is opt-in, is the country of first entry also opt-in? Verify this in the State of Play. The combined declaration will not work unless both are opt-in.
3. Is the ENS data complete? Do not combine the declarations if house-level data, the consignee's EORI number or the 6-digit HS code is missing. The Commission permits only a complete ENS.
4. Do you actually need a combined declaration? The Commission offers it as an option. If your data is also ready for a separate ENS, there is no reason to disrupt the existing flow.

The same shipment data also serves as a source for eFTI. MAP's eFTI 2027 guide explains the transport information presented to competent authorities. The ENS and transit declaration cover data submitted to customs before arrival. The two frameworks are separate, but both rely on the same ERP and TMS data.

What Preparations Should Be Made Today?

Assign an owner to each data field. The consignee's legal name and EORI number sit with the sales team, the tariff code in the product master data, the house structure with the forwarder, and ENS submission with the carrier. A field without an owner will be missing on the day of shipment.

Clean up the consignee master data. The ERP customer record should contain the legal name, full address and valid EORI number. The ICS2 stop word list was updated in July 2026 and entered into force on 3 August 2026. The current list is on CIRCABC. Remove general expressions such as "Customer" and "consignee", as well as vague goods descriptions such as "spare parts", from templates.

Compare tariff codes across the order line, product record and shipping document. A 6-digit HS code is mandatory on the NCTS side, and an 8-digit CN code is required if transit follows export. Verify that the first six digits of the national code in your ERP match the HS code.

Set a fixed data handover time with the carrier. The ENS must be submitted at least one hour before the goods arrive at the point of entry. In practice, the shipment data must be final before the truck departs. Finally, monitor the State of Play document and Ministry of Trade announcements. If Turkey moves to opt-in, the option to add ENS data to the transit declaration will become available, and the currently separate flow can be linked to a single data set.

MAP's B2B and EDI integration page describes a service that carries order and shipment data between ERP systems and business partners using standards such as EDIFACT. The page does not describe a customs declaration service. The part relevant to this article is establishing a consistent data flow between the systems on which the declarations rely.

Next week, pick your last ten completed European shipments and check whether the consignee's legal name, EORI, tariff code and house structure match across the ERP, forwarder and carrier for each one. Fields that differ show the gaps that must be closed before an ENS is rejected on the day of shipment. You can follow new articles on the subject on the MAP Blog page.