ICS2 RFI and DNL Handling: Should It Be Included in the Service Scope?

Direct Answer

A foreign NVOCC should include ICS2 referral handling in its service scope if it files ENS data, controls house-level information, manages consolidated shipments, or needs to respond quickly to customs risk analysis results.

ICS2 filing is not only about submitting the Entry Summary Declaration. After risk analysis, customs authorities may issue referrals requesting additional information, screening, or a Do Not Load action.

The European Commission states that, as a result of ICS2 risk analysis, risk-mitigating referrals may request the declarant to provide additional information, perform high-risk cargo and mail screening, or not load the cargo. These referrals must be answered before risk assessment can resume.

Why Referral Handling Matters

Many companies choose an ICS2 filing provider based only on submission capability.

But the real operational test comes after submission.

A shipment may face:

• Missing data request
• Additional information request
• Screening request
• Amendment request
• Filing rejection
• House consignment state issue
• Do Not Load request
• Carrier escalation
• Customer data correction
• Time-sensitive loading pressure

If the service scope only includes submission, the company may not know who responds when a referral appears.

What Is an RFI?

RFI usually refers to a request for additional information.

In an ICS2 context, this may happen when customs authorities need more or clearer data before risk assessment can continue.

The company should decide in advance:

• Who receives the request?
• Who understands the request?
• Who contacts the customer?
• Who collects missing data?
• Who submits the response?
• Who informs the carrier?
• Who stores the response record?

If the NVOCC controls house-level data, it should be ready to support the response process.

What Is a DNL Request?

DNL means Do Not Load.

This is one of the most serious ICS2 outcomes because it may affect whether cargo can be loaded.

The European Commission FAQ identifies IE3Q01 as a Do Not Load request in the ICS2 message context.

A company should not wait until a DNL appears to decide who is responsible.

The response path, customer communication, carrier coordination, and escalation process should already be defined.

Basic Filing vs. Referral Handling

A company should not pay for full exception support if its EU filing volume is low and simple.

But it should not choose basic filing only if it controls house-level data and needs fast response capability.

When Basic Filing May Be Enough

Basic filing may be enough when:

• Shipment structure is simple
• One party has complete data
• No consolidation is involved
• The carrier or provider handles all follow-up
• The company does not control house-level data
• EU filing volume is low
• Customers do not expect support after submission

This model reduces service scope but also reduces direct control.

When RFI Handling Should Be Included

RFI handling should be included when:

• The NVOCC controls house-level data
• The shipment is consolidated
• Customer data may be incomplete
• The cargo description may need clarification
• Multiple parties hold required data
• The carrier does not have full information
• The company needs to protect customer relationships
• The company wants faster customs response support

The European Commission states that incomplete ENS declarations may be rejected or may trigger risk-mitigating referrals in the pre-loading or pre-arrival phase, and that this can create delays in ENS processing and entry.

When DNL Escalation Support Should Be Included

DNL escalation support should be included when:

• Cargo loading timing is critical
• The company handles high-value or urgent shipments
• The carrier requires fast response
• Customers expect active exception follow-up
• The company files house-level data independently
• Multiple filing is used
• The NVOCC needs a clear emergency escalation path

DNL handling should not be informal. It should be part of a written service workflow.

Service Decision Table

Factor 1: Data Complexity

Complex data increases referral risk.

A company should review referral handling when shipments involve:

• Multiple sellers
• Multiple consignees
• Multiple house bills
• Consolidation
• Sensitive customer data
• Incomplete goods descriptions
• Unclear routing information
• Late customer amendments
• Split ENS filing responsibility

If data is complex, submission-only service may not be enough.

Factor 2: Notification Ownership

The filing model should define who receives ICS2 notifications.

Depending on the model, notifications may go to:

• Carrier
• House-level filer
• IT Service Provider
• Declarant
• Representative
• Internal compliance team

If the notification recipient is not the same party that controls the data, response delays may occur.

Factor 3: Customer Communication

When an RFI or DNL appears, the customer may need fast explanation.

The service scope should define:

• Who contacts the customer
• What information is requested
• How quickly the customer must respond
• Who confirms corrected data
• Who updates the filing
• Who informs the carrier

Customer communication should not begin only after a problem becomes urgent.

Factor 4: Carrier Coordination

In maritime shipments, carriers may need to know whether a filing issue has been resolved before loading.

If a foreign NVOCC files house-level data, it should coordinate with the carrier or master-level filer when referrals affect the shipment.

This is especially important in multiple filing scenarios.

Factor 5: Internal Escalation

A serious service model should have escalation rules.

For example:

• Normal RFI: operations team handles
• Urgent loading-risk case: compliance manager escalates
• DNL request: senior operations and customer service are notified immediately
• Repeated issue: root cause review is opened
• Missing customer data: commercial team follows up

Exception handling is easier when responsibility is assigned before the exception occurs.

Referral Handling Checklist

Before choosing the service scope, ask:

1. Who receives ICS2 notifications?
2. Who monitors filing status?
3. Who identifies RFI or DNL messages?
4. Who contacts the customer?
5. Who collects missing data?
6. Who checks corrected data?
7. Who submits the response?
8. Who coordinates with the carrier?
9. Who escalates urgent cases?
10. Who stores response records?
11. Who reviews repeated errors?
12. Who is available outside normal office hours?

If several answers are unclear, referral handling should be included in the service scope.

Common Mistakes

Mistake 1: Thinking ICS2 Ends After Submission

ENS submission is only one step. Customs risk analysis may require follow-up.

Mistake 2: Choosing a Provider That Only Submits Data

Submission-only support may not help when RFI or DNL handling is needed.

Mistake 3: Not Defining Notification Ownership

If nobody monitors messages, referrals may be missed.

Mistake 4: Ignoring Customer Data Readiness

RFI response speed depends on whether the customer can provide missing information quickly.

Mistake 5: No DNL Escalation Path

Do Not Load cases should have a clear escalation workflow.

FAQ

What is an ICS2 RFI?

An RFI is a request for additional information. In ICS2, referrals may be issued when customs authorities need more information before risk assessment can continue.

What is an ICS2 DNL?

DNL means Do Not Load. The European Commission FAQ identifies IE3Q01 as a Do Not Load request in the ICS2 message context.

Is referral handling required for every shipment?

Not always. It depends on data complexity, filing model, shipment sensitivity, and customer expectations.

Should a foreign NVOCC include RFI handling?

Yes, if the NVOCC controls house-level data, uses multiple filing, or handles complex EU-bound shipments.

Does referral handling replace data validation?

No. Data validation helps reduce risk before submission. Referral handling manages customs requests after submission.

Final Takeaway

ICS2 service should not stop at ENS submission.

Foreign NVOCCs and freight forwarders should decide who monitors notifications, answers RFI messages, manages DNL escalation, coordinates with carriers, and communicates with customers.

Basic filing may work for simple shipments.
Referral handling is safer for house-level filers, consolidated shipments, multiple filing workflows, and service-focused EU route operations.

Navigator International supports logistics companies with ICS2 ENS filing coordination, house-level data review, multiple filing workflow support, RFI and DNL response coordination, data validation, and related EU manifest filing compliance services.