Import documentation requirements for European countries

I. Overview of EU Customs

The 27 member states of the European Union (EU) operate a unified Customs Union — goods entering any member state can circulate freely within the EU without the need for repeated customs clearance between member states.

Key Points:

  • Unified EU customs legislation (Union Customs Code, UCC)
  • Uniform import tariff rates (Common Customs Tariff)
  • VAT rates vary by member state (set by each country)
  • Customs clearance can be completed in any member state (preferably at the first port of entry)

II. Main Requirements for EU Import Clearance

2.1 EORI Number 

The EORI (Economic Operators Registration and Identification) number is the EU registration and identification number for economic operators, serving as the "corporate ID" for EU customs.

ItemDescription
Mandatory?✅ Any company importing/exporting goods to/from the EU must have an EORI number
How to applyApply at the customs authority of any EU member state (recommended in the country with the largest import volume)
Mutual recognitionThe EORI number is valid throughout the EU
Chinese exporterDoes not need an EORI number; the EU importer (consignee) provides it

2.2 Import VAT

Imports into the EU are subject to Import VAT, with rates varying by member state:

Member State

Standard VAT Rate

Germany

19%

France

20%

Italy

22%

Spain

21%

Netherlands

21%

Belgium

21%

Poland

23%

Sweden

25%

Denmark

25%

VAT Deferral (Import VAT Deferral):

  • Some member states allow importers to apply for VAT deferral — VAT is not paid at the time of import but is reported and offset in the next VAT return period
  • Helps improve cash flow

2.3 Customs Duties

  • The EU uses the TARIC code (EU integrated tariff, 11 digits)
  • Tariff rates: average approx. 0%–12% (depending on HS code)
  • Most-Favoured-Nation (MFN) rates apply to China (no FTA)
  • EU Customs Union: all member states apply the same tariff rate

III. EU Product Compliance Requirements

3.1 CE Certification 

The CE marking (Conformité Européenne) is a mandatory safety mark for products entering the EU market. Many products must bear the CE mark before they can be placed on the EU market.

Product categories requiring CE certification (partial list):

  • Electrical and electronic products (LVD, EMC Directives)
  • Toys (Toy Safety Directive)
  • Medical devices
  • Personal protective equipment (PPE)
  • Pressure equipment
  • Construction products (CPR)

CE certification process:

Product testing (accredited lab) → Technical documentation → Declaration of Conformity (DoC) → Affix CE mark → EU representative registration

Note: CE certification is the responsibility of the exporter, not the EU importer. Chinese exporters must complete CE certification before shipping.

3.2 REACH Regulation

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is the EU regulation concerning the registration, evaluation, authorization, and restriction of chemicals.

Impact on Chinese exporters:

  • Products containing chemical substances (textiles, plastics, coatings, inks, etc.) must comply with REACH requirements
  • Exporters must ensure that chemical substances in their products are registered in the EU REACH system
  • Consequences of REACH non-compliance: goods detained, returned, or subject to fines

3.3 Other Compliance Requirements

RequirementApplicable ProductsDescription
WEEE DirectiveElectrical/electronic productsExtended Producer Responsibility (recycling obligations)
RoHS DirectiveElectrical/electronic productsRestriction of hazardous substances (lead, mercury, cadmium, etc.)
EMC DirectiveElectrical/electronic productsElectromagnetic compatibility requirements
Textile LabellingTextilesComposition, origin, and care labelling
Food Contact MaterialsFood packaging and containersREACH + EU No 1935/2004
GDPRDigital products and softwareData protection compliance

IV. Practical Customs Clearance After Arrival in the EU

EU import customs clearance is handled by each member state's national customs declaration system (such as Germany's ATLAS, the Netherlands' AGS/DMS, Belgium's PLDA, and France's DELTA), and is linked with the EU central ICS2 system. After ICS2 is implemented in phases, sea imports must also submit an Entry Summary Declaration (ENS) before loading; if there is no valid ENS record at arrival, the goods cannot complete customs clearance.

4.1 ICS2 and Pre-Arrival Declaration

ItemDescription
Nature of the systemThe EU advance cargo declaration system for completing security risk analysis before shipment
DeclarantThe carrier is responsible for submission; freight forwarders and NVOCCs may submit house-level declarations
Sea freight requirementsSubmit ENS before loading, including a 6-digit HS code, consignee EORI, cargo description, and other elements
Data sourceProvided by the exporter to the carrier or freight forwarder; incomplete information will cause the declaration to be rejected

Implications for exporters: Exporting enterprises do not declare directly to ICS2, but must provide accurate declaration elements to the carrier or freight forwarder—consignee EORI number, 6-digit HS code, specific product name, and pieces, weight, and dimensions. Incorrect information may lead to refusal of loading at the port of shipment or inability to clear customs after arrival.

4.2 Four Stages After Arrival

StageActionDescription
① Submission of customs declarationThe importer or its customs agent submits a Single Administrative Document (SAD) in the member state systemMust reference a valid ENS record
② Customs review and risk analysisMember state customs decide release or inspection based on risk parametersUsually completed within a few hours
③ Inspection (if selected)Documentary inspection or physical inspection (partial or full unstuffing)Depending on customs and port scheduling
④ Tax payment and releaseRelease into free circulation after payment of duties and import VATMember states that support deferral handle it under deferral arrangements

4.3 Import VAT and Deferral Arrangements

  • Import VAT is declared by the importer; most member states allow it to be deducted in the current period's VAT return
  • Import VAT deferral: Some member states allow VAT not to be paid in cash at import but handled directly in the current period's return, improving cash flow
  • Deferral requires prior application for permission from that country's tax authority (such as the Netherlands' Article 23 permit) and is not automatically applicable
  • Importers that have not obtained deferral approval must still pay import VAT in cash at customs clearance

4.4 Key Compliance Checks After Arrival

Check itemBasisCommon trigger situations
CE marking and technical documentationRelevant product directivesElectrical and electronic products, toys, machinery, medical devices, etc.
REACH / SVHC declarationREACH RegulationTextiles, plastic products, coatings, inks
Food contact material complianceEU No 1935/2004Tableware, packaging containers
Textile labelingTextile labeling regulationsMissing composition, country of origin, or washing instructions
Wood packagingISPM-15Wooden pallets without IPPC marking

The above checks are mostly carried out by member state market surveillance authorities through random inspections at ports or after release, and are independent of customs inspection—even if customs has released the goods, market surveillance may still impose additional requirements.

4.5 Free Container Time and Port Demurrage

  • Free container time is agreed by the carrier in the bill of lading or freight rate terms; for major European ports it is commonly 5–7 days
  • Overdue container detention charges arise, with incomplete customs clearance documents and pending CE documents being the main causes
  • It is recommended to confirm free container time and container return location at the booking stage, and to prepare compliance documents in advance before export

V. Recommendations for Chinese Exporters

RecommendationDescription
CE certification in advanceCE certification has a long lead time (1–3 months); start before signing contracts
REACH complianceBefore exporting chemicals/textiles, verify the REACH status of product substances
Tariff classificationConfirm TARIC codes (can be checked via the EU TARIC online database)
Importer capabilityVerify the validity of the EU importer's EORI and VAT numbers
Authorised representativeSome products require an EU-based authorised representative
Packaging requirementsWooden packaging must meet ISPM-15 standard heat treatment

VI. Common Causes of Customs Clearance Failure and Countermeasures

CauseManifestation After Arrival at PortCountermeasure
No valid ENS / ICS2 declarationCustoms declaration cannot be acceptedBefore shipment, confirm that the carrier has submitted it and check the receipt
Importer's EORI invalid or not activatedCustoms declaration rejected by the systemVerify that the EORI number is authentic and valid before shipment
Missing CE marking or declaration of conformityDetained by market surveillance, requiring supplementary documents or return shipmentComplete testing, technical documentation, and the declaration of conformity before export
MisclassificationAdditional customs duties and VAT to be paid, possibly retroactivelyCheck using the 11-digit TARIC code; apply for an advance customs duty ruling if necessary
VAT deferral not applied forLarge VAT must be paid in cash at customs clearance, straining cash flowApply in advance to the tax authority of the member state for a deferral permit
Non-compliant wooden packagingReturn shipment or destructionUse treated wooden pallets bearing the IPPC mark
Inaccurate declaration of originAdditional tax payment and possible penaltiesDeclare according to the actual origin and retain production and procurement records

The above is a summary of common situations; specific determinations and handling are subject to the latest regulations of the customs authorities of the EU and its member states.


Note: This article is provided for general knowledge only. Bofeng Logistics does not provide destination customs clearance agency, consulting or assistance services in the EU. We provide China-side export declaration and international ocean freight booking; clearance at the destination must be handled by the importer or its local customs broker.

📖 Next: 6.3 Japan Import Clearance Guide — Customs procedures, tariff policies, Food Sanitation Act and Pharmaceutical Affairs Law

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Customs declaration service areas: Zhuhai, Guangzhou, Shenzhen.

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Further Reading

Frequently Asked Questions

Do Chinese exporters need to apply for an EORI number themselves?

No. The EORI number is held by the importer (consignee) within the EU and provided during customs clearance; before shipment, exporters should confirm that the other party's EORI number is authentic and valid, to avoid being unable to declare after the goods arrive at port.

Is CE certification the responsibility of the exporter or the EU importer?

Affixing the CE mark, preparing the Declaration of Conformity (DoC), and compiling technical documentation are the responsibility of the manufacturer (exporter) and must be completed before the goods are exported; some products also require an authorized representative to be appointed within the EU. Detailed requirements are subject to the current text of the corresponding EU directive.

What do exporting enterprises need to do after ICS2 implementation?

Exporting enterprises do not declare directly to ICS2, but they must provide the carrier or freight forwarder with complete and accurate declaration data elements: consignee EORI number, 6-digit HS code, specific description of goods, piece count, weight, and dimensions. Incomplete or incorrect elements will cause the ENS to be rejected, and the goods may be refused loading at the port of loading.

Is import VAT deferral automatically applicable?

No. Deferral requires the importer to first apply to the tax authority of the Member State in which it is located for authorization, and it can only be applied after approval; those not approved must still pay import VAT in full at customs clearance. Authorization conditions and application procedures vary by country; the specific rules of that country's tax authority shall prevail.

This article was prepared by the Bofeng Logistics team and reviewed in September 2026. Customs rules change frequently; refer to official customs and authority notices for the latest requirements.