Maersk introduces 'No MRN, No Load' policy from September 2026 – what does this mean for importers and freight forwarders in Europe?

One of the world's largest container carriers has announced a policy that will radically change the rules for access to loading for goods bound for or transiting the European Union from September 30, 2026. Maersk is implementing the rule. "No Movement Reference Number, No Load" — No container will be loaded onto a ship without first obtaining a valid MRN from the EU customs system. For companies lacking efficient customs documentation processes, this is a wake-up call requiring immediate action.

Where does this new requirement come from? ICS2 as the foundation for change

Maersk's new policy didn't come about in a vacuum. It's a direct consequence of the European Union's implementation of an advanced import control system— Import Control System 2 (ICS2)This comprehensive IT platform collects detailed data on cargo before it actually reaches EU borders. The system's primary goal is to strengthen supply chain security through early identification of potential threats—both physical and financial.

ICS2 replaces and expands the existing import declaration mechanisms by introducing the requirement to submit the so-called Entry Summary Declaration (ENS) — a summary import declaration, which must be submitted to the EU customs system before the goods are loaded. Only after it has been correctly processed does the system generate Movement Reference Number (MRN) — a unique movement reference number confirming that the shipment has passed customs pre-clearance and may be authorised for transport into or through the Community.

By adapting its operational procedures to these requirements, Maersk goes a step further than simply complying with regulations—it enforces them directly with its customers, eliminating the possibility of last-minute "catch-up" procedures. It's a binary approach: either you have an MRN, or your container stays at the quay.

24 hours that can decide the entire supply chain

A key operational parameter of the new policy is the time window. A complete ENS declaration must be submitted, processed by the customs system, and completed with the assignment of a valid MRN. at least 24 hours before the vessel arrives at the first loading port, where new regulations apply. This may seem reasonable, but in industry practice, 24 hours can evaporate quickly, especially when documentation is incomplete or contains errors.

The consequences of missing this deadline are immediate and severe. The cargo is removed from the voyage's loading list and automatically transferred to the next available vessel. This, in turn, triggers an avalanche of costs and problems:

• Delivery delays — Postponing your flight to the next one may mean a delay of several days to even several weeks, depending on the frequency of connections on a given route.
• Port storage costs — Cargo waiting for the next ship generates storage fees at the terminal, which can be significant for bulky goods or goods requiring special storage conditions.
• Risk of contractual penalties — Delayed deliveries may trigger penalty clauses in contracts with end customers, transferring the financial risk to the importer or freight forwarder.
• The need to re-submit the declaration — Any rejected ENS declarations must be corrected and re-accepted by the customs administration before the goods are formally released for loading. This involves additional time and administrative work.

Importantly, the "No MRN, No Load" policy covers not only cargo imported directly into the EU, but also transit goods — that is, those that merely transit through EU territory on their way to third countries. This expansion of scope significantly increases the number of entities that must adapt their processes to the new requirements.

Detailed Technical Requirements - The Devil is in the Details

Maersk has published a set of guidelines for the correct submission of data in shipping instructions. Each of the following requirements is necessary for the ENS declaration to be processed correctly and for obtaining an MRN.

1. HS Codes - Classification without compromise

Each item of cargo must be marked valid six-digit HS code (Harmonized System), consistent with the World Customs Organization's 2022 classification (WCO HS 2022). The code must precisely match the actual goods being transported—it cannot be approximate or general. Misclassification for customs purposes is not just a procedural issue; it is a potential violation of customs regulations that may result in additional inspections and sanctions by customs authorities.

2. Clear identification of the entity's status

Maersk customers must clearly state whether they are acting as Beneficial Cargo Owner (BCO) or as Freight ForwarderThis distinction is crucial for correctly assigning responsibility for the ENS declaration in the ICS2 system. Failure to provide this information, or providing it incorrectly, will result in the declaration not being processed correctly.

3. EORI numbers – format matters

The absolute requirement is to provide valid and active EORI numbers (Economic Operator Registration and Identification) for all entities involved. The EORI number must be written in capital letters, without punctuation errors, and must be active in the EU database. Even a minor typo or an expired number can block the entire application. For companies operating in multiple EU countries, this means regularly verifying the EORI status of each entity in the transaction chain.

4. Structured customer data

Buyer and seller details must be sent in full, structured format, including: full company name, street address, city, postal code, and country. General or abbreviated address data will not be accepted. This requirement may surprise companies accustomed to abbreviated data entry in IT systems—especially where historical customer databases were not maintained with a complete address structure.

5. Precise cargo descriptions

The vague product descriptions that were common practice for years are becoming a thing of the past. Maersk strictly prohibits the use of vague categories such as "Accessories" or "Apparel." Accurate and unambiguous descriptions are required—for example: "Stainless steel bathroom accessories" instead of "Accessories" or "Men's cotton jackets sizes M-XL" instead of "Clothing." The precision of the descriptions is directly linked to the accuracy of the HS codes and is an element of consistent, verifiable customs documentation.

Maersk is not alone – the shipping industry is changing the rules of the game

Although Maersk's announcement is the loudest, it is worth emphasizing that other carriers are also taking similar steps. Hapag-Lloyd, the world's second-largest container shipping company, is implementing similar operational lockdowns in a "no MRN—no load" model. This signals that the change is systemic and not an individual decision by a single carrier.

In the broader industry contextrodoThe number of freight forwarders is sounding the alarm. Organization CLECAT — The European Association of Freight Forwarders, Customs Brokers and Logistics Operators — points to significant barriers to ICS2 implementation on the part of market operators. Among the reported problems are:

• Deficiencies in the integration of forwarders' IT systems with the ICS2 platform,
• Delays in responses from customs helpdesks,
• Shortage of certified ICS2 software vendors in many European markets,
• Difficulty adapting internal processes to new requirements in a short time.

These signals indicate that the risk of disruption in the first months after the new rules come into force is high – especially for smaller freight forwarders and importers that do not have dedicated compliance departments or advanced customs documentation management systems.

Business Risk Perspective – What Should Companies Do Now?

From an operational and financial risk management perspective, the "No MRN, No Load" policy is one of the most significant regulatory challenges for the transportation and logistics industry in the coming years. Companies that ignore this issue or leave compliance to the last minute risk significant losses.

Operational risk

Delayed shipments aren't just a logistical problem—they also pose real disruptions to production and distribution planning on the receiving end. In industries operating under just-in-time models, such as automotive or electronics, a delay of several days in component delivery can bring the entire production line to a halt. Supply chain managers should audit their documentation processes now and identify all suppliers and logistics partners who may not be ready for ICS2 requirements.

Financial risk

The direct costs of delays—port storage, container downtime, cargo redirection—are one thing. More severe may be the contractual penalties resulting from failure to meet delivery deadlinesIt's worth reviewing existing contracts with buyers for clauses regarding force majeure and liability for delays resulting from customs formalities. Not every contract provides for such exclusions, and the new customs regulations do not automatically exempt from contractual liability.

Reputational risk

For logistics and freight forwarding companies, the inability to ensure on-time deliveries under the new regulatory environment could mean losing customers to more prepared competitors. Those who invest in the right systems and capabilities early will gain a competitive advantage; those who delay will be left to manage the crisis.

Practical preparatory steps for companies

With over a year remaining until the new policy takes effect, companies still have time to implement the necessary changes. Here are the key areas requiring action:

• IT systems audit — Check whether your freight and customs documentation management software is integrated with the ICS2 platform or if such integration is planned. If not, contact your system provider as soon as possible or seek an alternative solution.
• Verification of EORI numbers — systematically updating the database of trading partners to ensure they have active EORI numbers. Companies that have not yet registered as economic operators in the EU should begin this process immediately.
• Review and update of the HS classification — inventory of goods and verification of assigned HS codes for compliance with WCO HS 2022. This is a time-consuming but absolutely necessary process.
• Training for employees — Customer service, forwarding, and customs documentation departments must be familiar with new requirements and understand the consequences of non-compliance. Investing in training now saves on crisis management in the future.
• Verification of suppliers and partners — ensuring that all partners in the supply chain (especially non-EU suppliers) understand the new requirements and will be able to provide the complete data required for the ENS declaration.
• Analysis of contractual agreements — review of liability and force majeure clauses in contracts with recipients and carriers in terms of risks arising from customs delays.

Summary - Time to prepare, not wait

Maersk's "No MRN, No Load" policy isn't a distant regulation that can be ignored until autumn 2026. It heralds a fundamental shift in the way European maritime trade operates, requiring concrete preparatory action now. Implementation of the ICS2 system, which underpins these changes, is progressing—and shipping lines, by enforcing their own operational rules, are effectively becoming the bodies verifying their customers' readiness for the new requirements.

For risk managers and owners of transport and logistics companies, there is one key conclusion: Companies that do not implement appropriate processes and tools before September 30, 2026, will be exposed to serious operational disruptions, real financial losses and the risk of losing customersIn the wedrodoIn a world where the margin of error in supply chains is getting smaller and smaller, the lack of MRN may turn out to be the element that spoils a carefully built business relationship.

It's also worth monitoring the customs software market and efforts by industry organizations like CLECAT to negotiate a transition period or technical support from customs administrations. However, relying on the possibility of delayed implementation would be a risky strategy. Historical experience with customs system implementations in the EU shows that deadlines can be postponed—but companies that haven't prepared for the change always lose more than those that have.