05/2011 - ICS and risk analysis, a barely exaggerated parallel on the data efficiency

Dr. Lance Thompson, International Development Manager -CONEX-, was in Seattle, USA at the beginning of May 2011 for the annual World Customs Organisation conference dedicated to new information technologies.

Although the main theme of this meeting was oriented towards “Cloud computing”, the implementation of the European ICS regulation was also discussed. Mr David HESKETH from British Customs (HMRC) and Dutch Customs’ Mr HEIJMANN co-presented the current system by way of a role play about air travel passenger security:

  • How many bags are you checking in? Just one.
  • Did you pack the bag yourself? No.
  • Has anyone handled the bag since it was packed? Yes, several people…
  • Do you know what’s inside the bag? All I know is what I wanted to put into it, but not what’s actually inside it now.
  • Are there any dangerous items in the bag? No, not that I know of.

Why does this passenger risk not being allowed to board the flight? Simply because his bag will be considered as potentially dangerous. Our two speakers went on to explain that the implementation of ICS is a little like this dialogue which seems completely surreal.

In most cases, it is indeed the transporter who files ICS declarations even though he has not packaged the goods to be transported. Are they dangerous? Who has manipulated the container? So many questions which jeopardise an effective risk analysis from taking place.


The customs administration needs to know the original consignor and the consignee at the final destination, what is being transported, where the goods comes from and where they are destined along with all the stopover points along the way. The many concessions and the “softening” of certain aspects of the regulation by TAXUD have meant that some of these data elements have been lost.

Mr David HESKETH and Mr HEIJMANN then suggested a solution in the form of an “information pipeline” which has fact been proposed in part by CONEX in its ICS via conex solution ever since the ICS regulation came to light; in this model each actor in the supply chain can deposit information which is relevant to him. All the information could then be used by various authorities according to their needs: export declaration, security declaration (ICS), import declaration, transit declaration and so on.


Operators would be able to access information which concerns their needs while at the same time being assured that sensitive commercial details, for example, remain confidential.

The ICS via conex solution is able to operate in this way thanks to its considerable flexibility which allows each supply chain operator to be able to lodge his declaration. Furthermore, CONEX has been working for quite some time on B2B information exchange (the exchange of commercial and logistics data between economic operators) which comprises to a large extent the model proposed here.