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The Role of the Obligatory Logistics Envelope (ELO) in ICS2 Compliance

The European Union’s Import Control System 2 (ICS2) is reshaping how goods enter the EU. One of its critical components is the Obligatory Logistics Envelope (ELO)—a term that may still be unfamiliar to many in the logistics and trade community. Yet, for freight forwarders, air carriers, and e-commerce platforms, understanding and implementing the ELO is now a fundamental compliance requirement.

This article explores the specific function and necessity of the Obligatory Logistics Envelope (ELO) within the ICS2 framework, and how overlooking it can result in shipment delays, non-compliance penalties, and costly disruptions.

What Is the Obligatory Logistics Envelope (ELO)?

The Obligatory Logistics Envelope (ELO) is a structured, digital data set required under the ICS2 system. It acts as a “container” that links multiple pre-loading and pre-arrival declarations for a single shipment into one unified electronic submission. The goal is to provide EU customs authorities with a complete and synchronized view of all related transport and goods data before the cargo reaches EU territory.

The ELO is especially crucial for shipments involving multiple actors—such as air carriers, freight forwarders, and postal operators—who each submit separate pieces of customs data. Without the ELO, these submissions may remain disconnected, leading to incomplete risk assessments or customs rejections.

Why Was the ELO Introduced?

Prior to ICS2, customs authorities often struggled to piece together fragmented information submitted by different parties. This lack of integration caused delays, security risks, and gaps in customs visibility.

The ELO resolves this by:

Consolidating data from all supply chain participants

Reducing the likelihood of duplicate or conflicting declarations

Enabling early risk analysis and faster customs decisions

Supporting EU safety and security standards

In short, the ELO is designed to create a digital bridge between all customs-related data points, forming a complete logistics picture before a shipment enters the EU.

Who Must Submit an Obligatory Logistics Envelope (ELO)?

Under ICS2 Release 2 and beyond, the Obligatory Logistics Envelope is required primarily for air shipments involving multiple actors, including:

Freight forwarders and logistics providers

Air carriers and ground handlers

Express and postal operators

E-commerce platforms shipping to EU customers

The ELO is mandatory for both pre-loading and pre-arrival filings. If any party fails to provide their required data or the ELO is not correctly structured, the customs risk assessment will remain incomplete—and the shipment may be held at the first point of entry.

Key Elements Included in the ELO

To form a valid Obligatory Logistics Envelope (ELO), the following data components typically need to be linked:

House-level data (H7 or H1 declarations)

Master-level transport data (AWB/MAWB)

Flight information and logistics routing

Consignee and consignor details

Product descriptions and tariff codes

This linking is done using a unique envelope reference number, which allows customs systems to merge data sets and evaluate the entire shipment as one.

What Happens If the ELO Is Missing or Incorrect?

A shipment entering the EU without a proper Obligatory Logistics Envelope (ELO) is considered non-compliant. The consequences can include:

Delayed clearance or cargo being held at the port or airport

Rejection of customs declarations and forced re-submission

Risk profiling of your company or shipping line

Fines or administrative penalties for repeated violations

Additionally, poor ELO compliance may result in your organization being flagged for future inspections, reducing operational efficiency and increasing costs.

The ELO and Post-Brexit UK-EU Trade

For UK-based exporters and logistics providers moving goods into the EU, ELO requirements apply just as they do for any non-EU country. With the UK now outside the EU customs union, businesses must ensure they are fully compliant with ICS2 processes—including proper use of the Obligatory Logistics Envelope.

Failure to adapt to these requirements post-Brexit has already caused backlogs for many UK-to-EU shipments, particularly in the air freight and e-commerce sectors.

Simplifying ELO Compliance with Expert Support

Creating and submitting a correct ELO requires coordination across multiple actors and a clear understanding of the ICS2 system. For many businesses—especially SMEs—this can be a steep learning curve.

That’s where Customs-Declarations.uk comes in. As specialists in EU and UK customs compliance, they offer hands-on support with:

Structuring and submitting Obligatory Logistics Envelopes

Coordinating data exchange between carriers, forwarders, and platforms

Ensuring all components of your ICS2 filing are properly linked and validated

Preventing costly delays or shipment rejections at the EU border

Whether you’re shipping occasional parcels or managing high-volume air freight, Customs-Declarations.uk ensures your ELO is accurate, timely, and fully compliant.

Final Thoughts

The Obligatory Logistics Envelope (ELO) may sound like just another layer of bureaucracy, but it plays a vital role in modern customs risk management. Under the ICS2 framework, it's not just helpful—it’s mandatory.

As customs systems across Europe become more digital and data-driven, companies that fail to meet new documentation standards like the ELO will face increasing friction. On the other hand, those who prepare—by understanding the requirements and working with trusted customs experts—will keep their supply chains smooth, compliant, and competitive.