China Customs expertise and Asia logistics consultancy

• Customs collects customs duties and taxes, import VAT, consumption tax and tonnage tax from cargo ships. A recent activity report shows an annual collection of more than 1.5 trillion RMB (CNY), increasing from 1.5% to 2% per year.

• As of 2010, the Chinese customs report that the average import tariff level has been adjusted to below 10%, down from more than 15% before China's WTO accession (December 2001), and is expected to reach an average of 7.3% by 2023.
  

 

2.1. A customs valuation system for import-export companies

Any international trading company established in China must register with an International Trade Operators Bureau. They then register with the supervising Chinese customs office. Customs assigns them a rating that reflects their status, size and behaviour. The rating applies to all Chinese-invested enterprises, wholly foreign-owned enterprises (WFOE) and joint ventures. The treatment and efficiency of the customs services varies according to the rating.

2.2. About Authorised Economic Operator (AEO) status in China

The AEO system, developed in 2005 by the World Customs Organisation (WCO), aims to simplify customs procedures for companies that meet high standards of legal compliance, security and solvency. AEO status has existed in China since October 2016, with China having integrated it into its own global system of traceability and good corporate governance. Approved members benefit from more than 40 facilitation measures offered not only by Customs but also by other Chinese administrations. These measures include

• Fewer inspections at ports and airports for customs declarations and formalities.

• A green channel to speed up customs clearance and import licensing services.

• Priority treatment for the processing of matters relating to the protection of intellectual property rights.

• Simplified procedures and a reduction in the number of documents required by related administrations.

• Major reference and consideration of AEO status during inspections carried out by other agencies.

• Priority given to AEO companies to participate in pilot projects implemented by customs and other government departments.

These benefits not only reduce the costs associated with international trade, but also increase the competitiveness of Chinese companies on a global scale. By establishing the AEO programme, China aims to improve the efficiency of its trade processes, strengthen global compliance and enhance the international position of its companies. With an EORI number, established companies will be able to receive notifications and check information on any changes in legislation imposed by the customs authorities of EU countries.

In 2023, Authorised Economic Operators (AEO) play a key role in the Chinese economy, accounting for 37% of the value of foreign trade and total tax contributions, according to the customs authorities.

This status is an important criterion to consider when selecting business partners in China, whether they are subcontractors, suppliers or distributors.

2.3 . The situation of customs inspections with conflicting results

• A company importing products in several Chinese ports of entry may be inspected simultaneously by several different customs offices. The possible zeal of the officers in the inspection department may lead to conclusions that are diametrically opposed to those of their colleagues in other regions. In such cases, several (lengthy) contradictory procedures will have to be initiated as the preliminary conclusions of customs inspections are not binding at the national level.

• Not all Chinese customs offices allow the official classification of products according to their Chinese tariff heading or HS (tariff) code. In Western countries, this is known as BTI (binding tariff information). This can be problematic for applying consistent customs clearance procedures at multiple entry points in China. Current regulations allow customs to retrospectively sanction customs declarations. Depending on the severity of their findings, the retroactive period can range from 3 to 10 years.

• Litigation files are transferred to a special Customs Anti-Smuggling Department. It has police powers.
  
  

2.4 . Chinese customs classification and tariff codes differ from western HS codes

• Like other countries in Asia did, China adopted the 10-digit HS code system in 1992. Since 2018, the Chinese HS code system has migrated to 13-digit codes. These 3-digit extensions are used specifically for the inspection and quarantine services.

• Although the terminology HS (Harmonised System) suggests a similarity of customs codes around the world, the tariff classification and customs codes adopted by China often differ from the European customs codes of the Integrated Tariff of the European Union for example.

• A well-informed importer or exporter will take care to check the relevant customs codes beforehand, both for declarative and fiscal reasons and to ensure compliance with import regulations and the conditions for releasing cargo into the Chinese market.
  

Example (header) of an import declaration submitted to the Chinese customs

 

2.5. Composition and calculation of import duties and taxes in China

• Customs Value Determination: The latest regulation has been in force since December 2013. It confirms that Chinese customs officials will determine value based on the transaction level of similar products imported into China at the same time as the goods being appraised. As in all other countries, customs officials reserve the right to reassess the value of import declarations that they consider suspicious.

• The duties and taxes payable when importing into China are as follows:
  
  
  • Customs duties
  • VAT (value added tax) or GST at a variable rate depending on the type of goods
  • Consumption tax on certain products (equivalent to excise tax in western countries)
    
    
    
• Depending on the country of origin of the imported goods, the applicable tariff rates are not the same. There are general rates (no tariff agreement) and preferential MFN rates (Most Favoured Nation agreements). Then there are intermediate rates (preferential or punitive) and preferential rates for so-called least developed countries. The percentage of import tariffs in China therefore varies according to the agreements in force with certain countries or regions. For example, in November 2020, China signed a free trade agreement called RCEP with a group of 15 countries, including 10 from ASEAN. From 2021, special tariffs will apply to goods produced in RCEP member countries. They will be lower than MFN rates.
  
  
• Below is a practical example for 2025. It shows a wide range of tariff rates applied in China on a bottle of grape wine, depending on the tariff origin.
  
  
  
  

  Description	Fresh grape wine in a container of 2 liters or less
  European Customs HS Code	2204.2109	(the first 8 digits out of 10)
  Chinese customs HS code	2204.2100	(according to the China nomenclature)
  China import General rate	180 %	(rate applicable if no customs agreement)
  MFN (most favored nation) rate	14 %	(applicable to Europe for example)
  Current 2025 rate for a USA origin	from 29% to 54%	(temporary trade war retaliatory measures)
  Conventional (bilateral) rate negotiated with certain countries or regions	11.2 %	Pakistan origin
  	13,1 %	Nicaragua
  	0 %	Switzerland, Costa Rica, Island, Peru, Hongkong, Mauritius island, ASEAN countries, Georgia, Chili, Macao.
  Rates applicable to countries members of RCEP (Regional Comprehensive Economic Partnership), mostly located in the Asia Pacific Region.	10,2 %	Japan
  	from 0 to 9,8 %	South Korea
  	0 %	Brunei, Myanmar, Cambodia, Indonesia, Laos, Malaysia, Philippines, Singapore,  Thaïland, Vietnam, Australia, New-Zealand.
  + consumption (excise) tax	+ 10 %	(applicable on ordinary wine)
  + value added tax (VAT)	+ 13 %	(ordinary rate of 13% applies)

  
  
  • China import duty calculation formula : duty rate x CIF value to Chinese port.
  • Excise duty calculation base = [(CIF value + import duty) / (1-10%)] x 10%.
  • VAT calculation base = (CIF value + customs duty + excise duty) x VAT rate.

2.6 . Chinese standards and formalities for product approval

• As a non-tariff barrier tool that has evolved as China has become a major player in international trade, the authorities have developed a specific system of standards and certification. Throughout China, port and airport customs offices are one of the import control point

• The CNCA (China and Accreditation Administration) controls the system of Chinese standards GB (Guo biao stands for national standard). They are the only set of normative tests that must be carried out to certify a product sold in China. Without a GB standard, a CCC (China Compulsory Certification) certificate is not required. On the other hand, Chinese customs do not recognise an American or European Certificate of Approval. Nor do they recognise test reports, certificates and compliance marks associated with UL, GS or NF standards, for example.

• Chinese sales approvals are also required for food products, cosmetics, pharmaceuticals and medical devices. Qualification and inspections are carried out by the NMPA and the CFDA, the two agencies responsible for health product safety in China.
  
  

3 . Food export and registration at the Chinese Customs (GACC)

On April 12, 2021, the Customs Administration published 2 decrees that come into force starting Jan 1, 2022.

a. decree GACC 248 is the "Regulation on Registration and Administration of Foreign Producers of Food Imported to China" (GACC Decree 248). It requires that foreign food manufacturers and warehouses exporting to China must register with the Chinese customs.

b. decree GACC 249 is the “Administrative Measures on Food Security in Import and Export of China”. It covers a wide range of requirements for exporting food products to China.

 

For more details on the product classes and procedures, please refer to our page dedicated to the food registration formalities with Chinese customs (GACC).

 

4. China's exports to the rest of the world are strictly controlled

• Except in special cases, a regular shipment from Europe or the US is not subject to strict export customs control. In China, there are strict export clearance procedures for almost all shipments. Export procedures can be just as demanding and time-consuming as import procedures. Why is this?

  • Firstly, the export value of each shipment from China is subject to a VAT refund to the exporter. This refund is a portion of the VAT paid on domestic purchases and assembly services. In recent years, there has been much abuse of the export value reporting system.

  • In addition, the Chinese authorities want to tackle the problem of counterfeit and pirated products, which is damaging the country's international reputation in Asia and in western countries. The Chinese government has signed cooperation agreements with customs authorities in many countries to actively participate in control campaigns. This practice is aimed at detecting and stopping fraudulent, counterfeit or noncompliant products with the essential safety regulations of the destination country.
    
    
  • China may allow special customs regimes for bonded storage and processing trade activities.
    
    
  • From a European regulatory perspective, the year 2023 brings new restrictions on imports from China. For example, a complaint was filed with the European Commission in March, followed by the imposition of temporary anti-dumping duties on imports of certain plastics (PET). Concerned about their competitiveness, some PET producers based in China have negotiated additional tariffs of between +6% and +15%. For the others, the general temporary rate was set at +24%.
    
    
  • Another example of compliance with EU rules on trade restrictions with Russia. Last September, Customs sent a notice to European operators prohibiting the import of certain iron, cast iron or steel products containing steelmaking inputs originating in or coming from Russia. This provision indirectly affects Chinese suppliers who may use Russian-origin components in their production. See the presentation on the European CBAM regulation and its impact in China.
    
    
    

  • Below is the header of an export clearance notice issued by Chinese customs.

 

5 . What should I do if a package or sample is blocked at customs?

• In response to a frequently asked question from individuals

  • Chinese customs do not provide a tracking service for your blocked packages. They also cannot receive any information, requests or documents directly from you.

  • Typical situation: You have returned a product to China for a refund or replacement. The package is stopped at customs. A document is missing (invoice, description, value) or the package is damaged on arrival. Only the consignee of the returned package in China can contact the domestic office or agent of the express courier company you used (UPS, TNT, DHL, Fedex, etc.). This agent can only contact Chinese customs if necessary. Also note that the China Post and its affiliated express services EMS (Express Mail Service) or SF-Express are agents of many overseas post offices.

  • Before returning a package from your country to a seller in China, make sure you have followed all the necessary shipping instructions. This includes marking, labelling and the quality of the packaging if you want a refund or replacement.

  • Another example: You send a gift by post to someone in China. What happens if the package sent to China is blocked at customs? China Post will often call the recipient to let them know that a package has been blocked. Otherwise, try to locate the package by entering its number into China Post's tracking system. If necessary, the recipient can go to a post office in the destination city with an ID card or passport for information and assistance. Note that a parcel may be confiscated by customs if it contains items that are regulated or prohibited for import. Finally, remember that importing personal items that are allowed into China can be expensive, as they are subject to taxes ranging from 15% to 60%. Simply stating that it is a "gift of no commercial value" will not be enough to reduce its customs value to zero.
    
    

• For companies sending samples to Chinese suppliers or customers

  • Be careful about sending "samples", even if they have "no commercial value". There is a lot of abuse of this process for products that are not really samples. Chinese customs can stop, return or destroy the package if the contents do not meet the required standards. Customs also reserve the right to collect duties + VAT on a value and tax basis of their choice.

    It is advisable to check with your supplier or potential supplier in China for specific declaration statements and other points to consider before sending or returning a product to them.

  • Obviously, beware of under-declaration of value or fraudulent declarations of contents designed to avoid duties and taxes on arrival or to avoid the need for certification or compliance on arrival. Good understanding and co-ordination with the importer in China is essential for the smooth running of the declaration and import procedures. This starts with checking that the consignee and importer named on the shipping documents have the correct licences and permits. Fraud is as common as it is severely punished.
    
    
  • It is important to remember that products imported into China for display at trade fairs or exhibitions have different customs status depending on whether the goods are to be returned to the exporter or purchased or consumed locally.
  
  

• Benchmarking of transport providers (air, sea, rail, road) on logistics and warehousing projects, freight forwarders and carrieres monitoring and tendering.

• Optimisation of costs and logistics processes all over Asia: implementation of import and export customs clearance procedures, inward and outward processing trade files, optimisation of import-export flows, LCL/LCL, LCL/FCL grouping consolidation. Consultancy and Standard Operating Procedures (SOP) service for customs declaration formalities.

• Consultancy and preparation of specific projects and temporary imports : regulations and practice of ATA Carnet in China, imports for processing and re-export.

• Cross-border e-commerce : comparison of Chinese cross-border import solutions for B2C export sales of exported products sold to the Chinese customers.

• Preparation of Health Compliance Reports for Food, Pharmaceuticals & Drugs, Skin Care Products and Medical Devices. Surveillance services in the Chinese market.

• Standards, approvals and certification: Preparation of files for CCC conformity marking and comparative solutions from authorised laboratories.

• Machinery and industrial equipment export consultancy in China : these files deserve special attention. We take care of the preparation of import files with Customs to facilitate the further import process by your subsidiary or agent in China.

• Implementation of storage, delivery and distribution solutions by product category. Dry goods, temperature controlled or regulated products.

• Projects negotiation disputes with Chinese authorities (Customs office, AQSIQ, CIQ, CFDA, Port Authorities, Free Trade Zones (FTZ), Bonded Logistics Zones).

• Customs regulatory watch & advisory : laws and regulations, Chinese HS code classification, negotiation and assistance during inspections.

• Import file advice and follow up. Qualification and manufacturing SOP for hazardous or chemical products.

• Consultant in managing the logistics function as part of a major sourcing project, qualification or relocation of Chinese suppliers and distributors.
  
  

[ Get in touch with an expert on customs and logistics issues in China ]

	Our added value for China business services
• Our experience in registration, licensing and administrative matters in China • A managing resident for 30 years in the Chinese world • The complementarity of a Western and Chinese multicultural team • Our network with the Chinese authorities and administrations • Extensive knowledge of business practices and cultural norms