ELO explained: A guide to France’s new digital border requirement for UK traders

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From 28 April 2025, French customs introduced a major change to cross-border trade procedures with the launch of the Enveloppe Logistique Obligatoire (ELO)—a digital system designed to streamline the documentation and customs clearance process for goods moving from Great Britain to France.

The ELO system was initially scheduled to become mandatory on 1 September 2025, but French authorities have since delayed enforcement until later in the autumn, with the final date expected to be announced in September.

Despite this delay, the ELO system is fully operational, and businesses are strongly advised to adopt it during the current transition period to avoid future disruptions.

The ELO functions as a digital “envelope” that groups together all customs and transport documents under a single barcode. This barcode is presented at check-in when a vehicle arrives at a French Roll- on Roll- off port such as Calais, Dunkirk, or Le Havre, or at the Channel Tunnel terminal.

French customs and transport operators can scan the barcode to access the full customs file, which has already been submitted and validated online. The aim is to remove paper-based checks, reduce processing time at the border, and ensure full compliance with EU import requirements, including new security protocols.

The ELO system is France’s equivalent of the UK’s Goods Vehicle Movement System (“GVMS” which produces the Goods Movement Reference (“GMR”), scanned at the UK border, but the two systems are not connected.

Traders must create and manage each one separately. This means that operators moving goods from the UK to France will need both a valid GMR for UK departure and a valid ELO for French arrival and vice versa for imports. Without a valid ELO, vehicles may be redirected to manual inspection lanes or denied boarding altogether.

How ELO works in practice

To create an ELO, an authorised party—often a freight forwarder, customs broker, or in some cases the exporter or importer—logs into the French customs portal (Prodouane) and creates an envelope for each vehicle. They must specify the direction of travel, whether the vehicle is full or empty, and enter all relevant customs references. These may include export or import declarations, transit Movement Reference Numbers (MRNs), Entry Summary Declarations (ENS) filed under the EU’s ICS2 system, and any required sanitary or phytosanitary certificates. Once submitted, the French customs system validates the ELO and generates a permanent barcode and reference number, which is sent to the driver to present at check-in. Each ELO corresponds to one specific vehicle, and sub-envelopes grouping multiple consignments across different trucks are not permitted.
Although the ELO system is not yet mandatory, the older French logistics envelope process is being phased out. Presenting the outdated envelope will soon no longer be accepted, and those relying on it risk serious delays. During the transition phase, businesses are encouraged to begin using ELO immediately so they can adjust processes, train staff, and fix any errors before enforcement begins later in 2025.

A critical element of the ELO is that it relies on compliance with the EU’s Import Control System 2 (ICS2), which governs Entry Summary Declarations. These security declarations must be filed electronically and accepted by EU customs before goods can move. If a trader has not yet migrated to ICS2-compliant ENS filings, they will not be able to complete an ELO for their shipments. This can result in full truckloads being excluded from boarding or facing delays. For this reason, ensuring ICS2 compliance is a necessary first step in ELO readiness.

What businesses should do now

From a practical standpoint, businesses should take immediate action.

  • First, they must ensure that someone in their supply chain—whether internally or through an agent—is registered on the Prodouane portal as an ELO creator.
    This person will be responsible for compiling documentation, submitting customs data, and managing ELOs for all relevant shipments.
  • Second, companies need to verify that they or their service providers are submitting ENS files in accordance with ICS2 requirements.
  •  Third, drivers should be trained to carry and present the ELO barcode—whether printed or digital—at French ports and terminals, as this will become a core part of the customs process.

While the initial transition may require effort, the long-term benefits of ELO adoption are clear.

  • The system enables faster and more predictable border crossings, as customs authorities can clear documentation in advance of a truck’s arrival.
  • It reduces the burden of paperwork by grouping all declarations under a single barcode, and it provides real-time visibility into the status of shipments, helping companies manage their logistics more efficiently.
  •  CustomsLink and other industry providers report that businesses already using ELO during the transition phase are experiencing smoother port operations and fewer administrative issues.

In short, the ELO is more than a regulatory hurdle—it is a critical part of modernising customs flows between the UK and France.

As with any new system, early adoption brings a competitive advantage. Businesses that prepare now—by registering on the French customs portal, ensuring ICS2 compliance, assigning an ELO creator, and training staff—will be well-positioned when the new requirements take full effect.

Those who delay risk shipment disruptions, port delays, and non-compliance fines once enforcement begins. Where your goods are part of a consignment the goods movement is at the mercy of the weakest link in the chain. If one of the exporters has not prepared its ELO, the truck may not be able to board the ferry and this will disrupt supply chains in the UK.

The same applies for GMRs and we have seen an increase in trucks being diverted to inland border posts because they are carrying goods that are not listed on the GMR.

The French customs authorities have clearly signalled that ELO is the future of cross-border logistics, and while the mandatory date has been extended, this grace period should be used wisely.

For importers, exporters, hauliers and customs agents alike, now is the time to act. Embracing ELO today will ensure a smoother, faster, and fully compliant trading experience tomorrow.

 

Do you need extra information?

Ruth Corkin; Principal at Hillier Hopkins - VAT and Indirect Tax Advisory

Ruth has been involved with VAT and indirect taxes for over 35 years and sits on a number of advisory committees and boards. She is well known in the VAT world and is the proud author of many articles and technical works.

Contact Ruth at ruth.corkin@hhllp.co.uk or on +44 (0)1908 713860

Based at the following office - Milton Keynes, Watford and London