Supply chain compliance in the EU has historically been treated by logistics operators as someone else's problem — specifically, the problem of the manufacturer or importer who sources goods and must demonstrate regulatory compliance for what they bring to market. Freight forwarders and 3PL operators moved things. They were not, in the traditional framing, responsible for the governance of what they moved.
That framing is shifting under two overlapping regulatory developments that took concrete shape in 2024 and 2025: the EU Corporate Sustainability Due Diligence Directive (CS3D) and the updated EU customs pre-notification requirements under the Union Customs Code (UCC) amendments. Neither was designed primarily with freight operators in mind, but both have direct operational implications for any EU-based 3PL or forwarder handling cross-border shipments as part of a supply chain serving large EU companies.
CS3D: the supply chain due diligence obligation that flows upstream
The EU Corporate Sustainability Due Diligence Directive (Directive 2024/1760), which entered into force in July 2024 with a phased implementation timeline, places due diligence obligations on large EU companies regarding human rights and environmental risks in their supply chains. The primary obligation falls on the company in scope — typically a manufacturer, retailer, or importer above a revenue and employee threshold. But the due diligence requirement extends to their "chain of activities," which explicitly includes upstream and downstream business partners.
For freight operators, the relevant question is: are 3PL operators and freight forwarders considered "established business partners" of the large companies they serve, and does that bring them into the CS3D compliance perimeter? The answer is context-dependent, but the practical guidance emerging from early legal interpretation in Germany and the Netherlands suggests that logistics service providers handling a significant portion of a in-scope company's supply chain operations — particularly for high-risk goods categories or high-risk origin countries — will increasingly face contractual due diligence documentation requirements from their shipper clients, even if the 3PL itself is not directly in-scope under CS3D by size.
What does "documentation requirements" mean operationally? At minimum, it means being able to demonstrate that a shipment was handled through documented, traceable procedures — that the carrier used was screened, that the route was legitimate, that there are no suspicious indicators of forced labour involvement at origin or en route. The data that supports this is largely the data that good freight visibility infrastructure already generates: timestamped event logs, carrier identity records, border crossing records, ePOD (electronic Proof of Delivery) records. The question is whether that data is structured and retained in a way that can support a CS3D audit trail.
UCC pre-notification updates and what they mean for transit document management
The Union Customs Code amendments affecting pre-arrival and pre-departure notifications have been phased in incrementally. The ICS2 (Import Control System 2) release 3 requirements, which extended pre-notification obligations to road transport carriers crossing EU external borders, represent the most operationally significant change for EU cross-border freight in recent years.
Under ICS2 release 3, carriers moving goods by road across EU external borders are required to submit Entry Summary Declarations (ENS) before the vehicle arrives at the first EU point of entry — the timing requirement varies by mode but for road freight generally requires submission at least one hour before arrival at the border crossing. The ENS must include, among other fields, the consignee and consignor EORI numbers, the commodity codes (HS tariff headings) for the goods, the country of provenance, and the transport equipment identifiers (container numbers using BIC codes for containerised cargo, or vehicle registration for road).
We're not saying that ICS2 release 3 is a new compliance burden without precedent — the pre-notification concept has been in place for maritime and air freight for years. The change is that road freight operators who previously handled only intra-EU transit under NCTS and did not interact with ICS2 now need to build ENS submission capability for any movements crossing EU external borders (e.g. UK–EU, Switzerland–EU, or goods originating from non-EU countries transiting through EU external entry points).
The data requirements for an ENS are largely a subset of what should already be in the shipment record in a well-managed TMS. The operational challenge is the timing: ENS must be submitted before arrival, which means the commodity and party data must be complete in the system at booking time, not at collection. This is a process discipline issue as much as a technology issue — and it exposes gaps in document completeness that many freight operators have historically patched with phone calls rather than data flows.
What data your TMS needs to hold to be compliance-ready
The practical data requirements that emerge from combining CS3D traceability expectations with UCC pre-notification rules are reasonably well-defined. For each cross-border shipment, a compliance-ready TMS or visibility platform should be able to produce:
- Timestamped event log from departure to delivery, including border crossing events with MRN references where applicable
- Carrier identity record including EORI number and any applicable transport operator licence references
- Consignor and consignee EORI numbers, verified at booking time
- HS commodity codes (6-digit minimum, 8-digit for EU import/export declarations) for each line in the shipment
- Transport document type (T1/T2 for intra-EU transit; ENS reference for EU external border crossings)
- ePOD record linked to the shipment, timestamped and with receiver identification
- Carrier screening record: date, method, result (for CS3D chain-of-activity documentation)
None of this is exotic data. Most of it lives in existing TMS records in some form. What is often missing is the structural linkage between events and the immutability of the record — the ability to demonstrate, months later, that the event log has not been edited and reflects what actually happened.
The audit trail problem is a data architecture problem
Consider a Baltic Freight Solutions, a mid-size Gdansk-based 3PL running approximately 200 active shipments at any time across Poland, Germany, and the Baltic states. A CS3D audit request from one of their German manufacturing clients in Q3 2025 asks them to produce a complete shipment event log for a specific consignment that transited from a non-EU origin through Hamburg in March 2025. The shipment involved two carrier legs, a customs pre-clearance at Hamburg under NCTS, and a final delivery to a factory in Bydgoszcz.
If the event data lives only in the carrier's tracking portal (accessible for 90 days before archiving), the TMS's live shipment table (which overwrites records on status update), and an ePOD that was emailed as a PDF — reconstructing that audit trail six months later is a manual investigation project. If the event data was captured into an immutable event log in a visibility platform at the time of transit, with source timestamps and references to the MRN and carrier identifiers, producing the audit trail is a query.
This is the operational implication that most directly affects the technology stack decision: compliance documentation is not a reporting feature you add later. It requires that the visibility platform treats event capture as a system-of-record function, not just a monitoring function.
What to act on now versus what to watch
The CS3D implementation timeline is phased: the largest EU companies (turnover >€1.5 billion, >1,000 employees) face obligations starting in 2027, with broader applicability extending through 2029. This does not mean logistics operators should wait. Contractual requirements from in-scope clients tend to run 12–18 months ahead of the regulatory deadline — procurement teams at large manufacturers are already incorporating CS3D supply chain documentation requirements into new contract terms in 2025.
ICS2 release 3 road freight obligations are already active for the relevant border-crossing scenarios. If your operations include road freight crossing EU external borders, the ENS submission process should be in your current operational procedures, not your 2026 roadmap.
The freight visibility data infrastructure decisions you make now — whether your event logs are structured and retained, whether your TMS captures commodity codes and EORI numbers at booking time, whether your ePOD records are linked to shipment events — will determine whether compliance documentation in 2026 and 2027 is a query or an investigation.