The container is packed. The shipping instructions have been submitted. The ship is on schedule. Everything seems ready to go. But if one crucial reference is missing, the journey could end before loading even begins: the Movement Reference Number, or MRN for short. Hapag-Lloyd already has a "No MRN, No Load" rule in place. As of September 30, 2026, Maersk will also implement such a policy for cargo that requires an ICS2 Entry Summary Declaration and is intended to be imported into or transit through the European Union.

If a valid MRN is not provided in time, it can have very practical consequences: the container will not make it onto the scheduled ship. But what is actually behind this?

What is ICS2?

ICS2 stands for Import Control System 2. It is the European Union's electronic advance cargo information system. Economic operators bringing goods into or transporting them through the EU customs territory must submit safety and security data before the goods arrive.

The goal is to identify potential security risks at an early stage. Based on the submitted data, customs authorities perform a risk analysis and can request further information or inspections if necessary. It is important to note that ICS2 is not new.

The system has been introduced in phases over several years and across various modes of transport. The current "No MRN, No Load" regulations of individual shipping lines should therefore not be confused with a new introduction of ICS2.

And what is the ENS?

A central component of ICS2 is the Entry Summary Declaration (ENS). It contains safety-related information about goods entering or being transported through the EU customs territory. The European Commission requires a complete ENS for goods brought into the EU. The data required depends, among other things, on the mode of transport and the specific business model.

In maritime transport, this includes numerous details about the shipment and the parties involved. The quality of this data is critical. Incomplete or incorrect information can prevent a declaration from being processed successfully.

What does the MRN have to do with this?

If a customs declaration is successfully processed in the relevant EU system, it receives a unique reference: the Movement Reference Number. The MRN serves as the identification for the declaration within the customs system. For the shipping line, it is crucial proof that the required ENS declaration has been submitted and accepted by the system.

This is exactly where "No MRN, No Load" comes in: No valid MRN – no loading.

What changes on September 30?

Maersk is introducing a "No MRN, No Load" policy effective September 30, 2026. It applies to cargo that requires an ICS2 Entry Summary Declaration and is intended to be imported into or transit through the European Union. For ships calling at the relevant first port of loading on or after September 30, a valid MRN must be available before loading.

Maersk has set a specific deadline: If a valid MRN is not provided at least 24 hours before the ship's arrival at the relevant compliance load port, the cargo in question will be removed from the loading list and may be moved to a later vessel. Rejected customs declarations must also be corrected and subsequently accepted before the cargo can be considered compliant for loading.

For shippers, this means one thing above all: the quality and timely submission of data is becoming even more important.

Why is it not enough to provide the data shortly before departure?

There are various deadlines when booking a container. In addition to the physical cut-off for container delivery, documentation and customs deadlines also play a role. A container can therefore be sitting at the terminal for a long time and still miss its scheduled voyage. This is because the necessary information for ICS2 must be provided, processed, and accepted by the system in good time.

Maersk therefore explicitly urges its customers to submit complete and accurate shipping instructions, including all required master and house-level data, well before the communicated documentation and customs deadlines. The physical location of the container alone does not determine whether it can be loaded.

Who is actually responsible for the ENS?

This is where it gets a bit more complex. In principle, according to the European Commission, the carrier bringing the goods into the customs territory of the European Union is responsible for submitting the ENS. However, the shipping line does not always have all the required information. In such cases, other parties in the supply chain—such as the importer, consignee, or freight forwarder—can submit the information they have available. ICS2 enables this through what are known as multiple filings.

Carriers and other parties must then transmit their data in such a way that the individual partial declarations can be linked within the system. The specific responsibility therefore depends on the respective transport and filing model.

Master and House – why does it get more complicated?

Especially in freight forwarding and groupage traffic, a shipment can be represented at different documentation levels. In addition to information at the master level, additional data may be required at the house level. If, for example, a freight forwarder or NVOCC decides to submit house B/L information themselves, these supplementary details must also be transmitted via ICS2 in a timely and successful manner.

Hapag-Lloyd currently points out that corresponding supplementary declarations in the multiple-filing process must be submitted and accepted by the ICS2 system no later than 24 hours before the vessel arrives at the non-EU port of loading. It is therefore not necessarily enough that some form of declaration exists. The information required for the respective filing model must be complete.

What happens if information is missing or incorrect?

In that case, a documentation problem can quickly turn into a transport problem. Typical causes can include missing or invalid EORI numbers, insufficient descriptions of goods, or incorrect or missing data in the required declarations. Hapag-Lloyd explicitly cites such errors as a potential cause for issues with ICS2 processing.

If a required declaration is not accepted in time, it can lead to customs holds, missed connections, or delays in import clearance, depending on the carrier and the situation. Hapag-Lloyd also notes that this can result in additional costs such as storage, demurrage, or detention.

With the new Maersk rule, the consequence is particularly clear: if the required valid MRN is missing within the specified deadline, the cargo will not be considered for the planned loading and may be moved to a later departure.

What does "rolled" mean?

In sea freight, the term "roll-over" is often used when a container is not transported on the originally scheduled vessel. This can have various causes—such as lack of capacity, operational changes, or, indeed, documentation and customs requirements that were not met in time.

The container does not disappear, of course. It is left behind and must be scheduled for a later, suitable connection. The extent of the resulting delay depends on factors such as the schedule and the frequency of the respective service.

In the worst-case scenario, a late document can result in a delay of several days.

Does ICS2 only apply to imports into the EU?

No. This is an important point. The ICS2 requirements do not exclusively apply to goods whose final destination is within the European Union. The European Commission also mandates these security data for goods transiting through the EU customs territory. A container can therefore be subject to the requirements even if its actual country of destination is outside the EU.

Maersk formulates its new policy accordingly for cargo entering the EU or intended to transit through the EU. The specific route is therefore just as important as the origin and destination.

What should shippers keep in mind now?

Basically, "No MRN, No Load" does not change the fundamental logic of proper transport preparation. However, the consequences of late or incorrect data become very immediately apparent. Shipping instructions should therefore not be put together just before the deadline expires. Required information must be complete and correct, responsibilities for master and, if applicable, house-level filings should be clarified, and necessary EORI numbers and other customs information must be accurate.

Above all, there should be enough time to correct a rejected declaration. After all, the crucial deadline is not necessarily the moment data is sent. What matters is that the required declaration has been successfully processed and accepted in time.

When documents become just as important as the container

When we think of logistics, we often focus on the visible: containers, ships, cranes, trucks, and terminals. Yet, an increasingly large part of international supply chains takes place digitally. Today, a missing number in a customs system can be just as decisive for whether a container begins its journey as a missed terminal cut-off.

The container can be packed and ready at the right location. The ship can be on time. And yet, the cargo remains behind. No MRN, No Load.