Yes, provided that it is with the knowledge and consent of the ocean carrier. Firstly, European law does not distinguish between "NVOCCs" and forwarders that merely act as agents. Second, the European security legislation explicitly allows any 3rd party to file - with its knowledge and consent - the ENS instead of the carrier. This follows from Article 36b (3) and (4) CC. Para (3) makes the party that brings the goods in to the Comunity (i.e. the carrier) ultimately responsible that an ENS is filed. Para (4), however, states that "Notwithstanding the obligation [in para 3], the [ENS] may be lodged instead by: (a) the person in whose name the person referred to in paragraph 3 acts; or (b) any person who is able to present the goods in question or to have them presented to the competent customs authority; or (c) a representative of one of the persons referred to in paragraph 3 or points (a) or (b)".
However, as noted, the filing of an ENS by any party other than the ocean carrier always requires the ocean carrier's knowledge and consent. How the ocean carrier's consent to a 3rd party ENS filing is to be evidenced and under which conditions and terms, e.g. time for submission of the ENS, the shipments involved, and the duration of the filing arrangement, are subject to contractual agreement between the commercial parties.