China Customs expertise and Asia logistics consultancy

• Chinese customs collect duties and taxes, including customs duties, import VAT, consumption tax where applicable and other tonnage taxes on imports. A customs activity report for 2024 shows revenues of just over 244 billion RMB (around 30 billion EUR).

• 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. Overview of China's latest customs reforms in 2018

The parameters	Key official measures announced
Objectives	- Reduce customs bureaucracy and improve administrative efficiency - Promote freer and more open trade - Strengthen risk control and compliance
Institutional reorganization	- Merger of Customs Administration (GACC) with Inspection and Quarantine (CIQ) - Integrated “one inspection, one clearance” system
Simplification of procedures	- Implementation of a single national window for customs declarations - Faster customs clearance with standardized procedures
Reduction of customs duties	- Progressive reduction of customs duties (automotive, cosmetics, medicines, etc.) - Increased exemptions for certain strategic imports
Reinforced controls	- Risk management via data analysis - Increased post-clearance controls to combat fraud
International openness	- Partial harmonization with WTO standards - Support for agreements such as RCEP (15 nations) and BRICS member countries - Development of free trade zones (FTZ)

2.2. 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.

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

The Authorized Economic Operator (AEO) system, launched by the WCO in 2005, simplifies customs procedures for companies meeting high standards of compliance, security and solvency. China adopted it in 2016, integrating it into a national governance and traceability system. 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.

This program helps reduce logistics costs, strengthen international competitiveness and improve compliance. In 2023, AEOs accounted for 37% of the value of China's foreign trade, illustrating their central role in the economy. This status is a relevant criterion to take into account when choosing and selecting business partners in China, be they subcontractors, suppliers or distribution agents.

2.4 . The situation of customs inspections with conflicting results

• A company in China importing goods into several ports may be inspected by different customs offices, leading to conflicting conclusions between local inspectors. This can lead to lengthy procedures, as inspection findings are not binding at national level.

• Not all customs offices allow their products to be officially classified according to the tariff heading of the Chinese HS (customs) codes. In Europe, this is called a BTI (Binding Tariff Information). This can be problematic when it comes to applying a uniform customs clearance procedure at several Chinese points of entry. What's more, Chinese customs officials can retroactively examine and sanction past declarations, with retroactive deadlines ranging from 3 to 10 years, depending on the seriousness of the infringements.

• Cases considered fraudulent are transferred to a specialized customs department, the Customs anti-smuggling department. It has police powers. It is empowered to take cases to court. If possible, negotiation is preferred.
  
  
• In China, whistle-blowing is actively encouraged and financially rewarded as part of the fight against corruption and consumer protection. Dedicated hotlines enable the public to report cases of counterfeiting, imitations or out-of-date products. These reports lead to checks and inspections which increase the regulatory risk for companies.
  
  
• Apart from administrative and criminal sanctions, and the liability of company directors, the company's reputation is affected. Past convictions and fines are recorded in the company's public information register. Indeed, China's social credit system (社会信用体系) initiated since 2014 evaluates and regulates the behavior of individuals and that of companies.
  
  

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

 

• Like other Asian countries, China adopted the 10-digit HS customs code system in 1992. Since 2018, it has been using an extended 13-digit nomenclature. The last 3 digits are used by inspection and quarantine bureaus (ex-CIQ) for specific controls. Below is a table illustrating the structure of customs nomenclatures in Europe and China:

  1	2	3	4	5	6	7	8	9	10	11	12	13
  Harmonized European System (HS)
  European Community Customs Tariff (CCT)
  European General Product Nomenclature (NGP)
  European customs clearance nomenclature (NDP)
  Chinese customs clearance nomenclature with up to 13 digits, including control codes.

  
  
  
  
• 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.
  
  
• The difference between Chinese and European HS codes goes further. Around 30% of goods have different HS codes in China, which can lead to reclassification in an unfavorable tariff category. It is advisable to compile a code correspondence table to avoid misclassification during trade.
  
  
  

  Please note : a new Chinese customs nomenclature will come into force in 2025. This means that the validity of Chinese customs HS codes still in use for declarations in 2024 must be verified to avoid blocking products on arrival in China. Sub-categories have been created for certain products. Customs inspection offices are strictly monitoring compliance with the new standards. Checks are carried out not only at the time of import, but also afterwards.

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• A wise exporter will carefully check customs codes for declarative， fiscal and applicable standards reasons, which can influence his competitiveness. This will help confirm documentary requirements and identify any certification or homologation needs before exporting to China. Chinese standards are constantly evolving. So are the rules governing compulsory labelling in Chinese.
  
  
  

  Below is the header of an import declaration form for Chinese customs.

  An importer in China (local agent or foreign-owned company) prepares documents for import customs clearance. His declarant forwards them to the customs office with which he is registered. Apart from special requirements depending on the sensitivity of the products, the documents required are as follows: advanced cargo manifest bill of lading (B/L) or air waybill (AWB) packing list commercial contract with exporter and commercial invoice certificate of origin (COO), if required copy of transport insurance policy and an import customs declaration form (see example above). Sometimes, the importer in China must present an import license, a certificate of Quality, a certificate of conformity or a special permit. For example, if quotas are applicable, or for sensitive, dangerous or chemical products.

  
  

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

• Determination of customs value is based, according to the December 2013 regulation, on the transaction value of similar products imported at the same period. Chinese customs officials may reassess declarations. The choice of incoterms with your Chinese partner is crucial when drawing up contracts.

• Duties and taxes to be paid when importing into China include customs duties, VAT at a variable rate and consumption tax on certain products (excise duty in Europe).
  
  
  • Calculation formula for import duties in China: duty rate x CIF value of Chinese port
  • Calculation of X% consumption tax: [(CIF value + customs duties) / (1-X%)] x X%.
  • VAT calculation base: (CIF value + customs duties + consumption tax) x VAT rate
  
  
  
• China's import tariffs based on country of origin: tariff rates vary depending on trade agreements in place. They include general rates (no agreement), MFN rates (Most Favoured Nation), intermediate rates (preferential or punitive), and special rates for least developed countries. Since 2021, goods originating from RCEP member countries benefit from lower preferential rates compared to MFN tariffs..
  
  
• Below is a practical example from 2025. It highlights the disparities in customs duties levied in China according to customs origin. Example below for a bottle of wine.
  
  
  
  

  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 China 2025 nomenclature)
  China import General rate	180%	(rate applicable if no customs agreement)
  MFN (most favored nation) rate	14%	(applicable to Europe for example)
  Current rate for a USA origin	from 29% to X%	(punitive rate variable according to the evolution of the US China trade war)
  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)

2.7 . 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 oversees China's GB standards (Guo Biao – national standards), which are the mandatory reference for certifying products sold in China. If no GB standard applies, a CCC (China Compulsory Certification) is not required. However, Chinese customs do not accept foreign certifications such as UL, GS, NF, or related test reports and compliance marks.

• 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.
  
  

2.7. About automatic and non-automatic import licenses

An import license is an official authorization issued by the Chinese authorities, required to import certain categories of goods into China. There are 2 categories of license:

• Automatic import licenses: their purpose is to enable statistical monitoring of the entry of certain products. Automatic licenses concern certain food, electronic, textile and chemical products. They are obtained through a simplified procedure. Generally valid for 6 months.

• Non-automatic import licenses: their purpose is to regulate or limit the importation of certain strategically or economically sensitive products (quotas, systematic prior authorization). Non-automatic licenses apply to certain sensitive agricultural products (cereals, sugar, etc), critical raw materials or other products linked to national security (advanced technologies, special equipment). The requirements to obtain such a licence include a strict application procedure to be followed.
  

The competent authorities are the Chinese Ministry of Commerce (MOFCOM) and its local branches, as well as the relevant customs authorities. In practice, only a commercial enterprise registered in China can obtain an import license on its behalf. This means that when exporting to China under a DDP incoterm, for example, an authorized Chinese import agent must handle this procedure on behalf of the foreign exporting company. Unless, ideally, the importing customer agrees to help with these formalities.

 

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.
    
    
    

  • Belo, 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?

5.1. In response to a frequent question from individual buyers

• 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.
  
  

5.2. For companies sending a sample to a Chinese supplier or customer

• 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.
  
  
• Beware of under-declarations of value or fraudulent declarations to avoid charges and taxes on arrival or to circumvent compliance requirements. Good coordination with the importer in China is essential for smooth procedures. Check that the importer (consignee) listed on the shipping documents has the required licenses and authorizations. Fraud is common and severely punished.
  
  
• As a reminder, the entry into China of products that are to be exhibited at trade shows or fairs entails a special customs status, which differs depending on whether the goods are to be returned to the sender 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.

• Logistics and cost optimization across Asia: we support the setup of import/export customs procedures, processing trade operations, and optimized flow management including LCL/FCL consolidation. Consulting and drafting of Standard Operating Procedures (SOP) for customs declarations.

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

• 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.

• Export support for machinery and industrial equipment to China: these projects require careful attention to technical compliance and import procedures.

• 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 distribution agents.
  
  

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