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.
| Item | Description |
| Mandatory? | ✅ Any company importing/exporting goods to/from the EU must have an EORI number |
| How to apply | Apply at the customs authority of any EU member state (recommended in the country with the largest import volume) |
| Mutual recognition | The EORI number is valid throughout the EU |
| Chinese exporter | Does 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
| Requirement | Applicable Products | Description |
| WEEE Directive | Electrical/electronic products | Extended Producer Responsibility (recycling obligations) |
| RoHS Directive | Electrical/electronic products | Restriction of hazardous substances (lead, mercury, cadmium, etc.) |
| EMC Directive | Electrical/electronic products | Electromagnetic compatibility requirements |
| Textile Labelling | Textiles | Composition, origin, and care labelling |
| Food Contact Materials | Food packaging and containers | REACH + EU No 1935/2004 |
| GDPR | Digital products and software | Data 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
| Item | Description |
|---|---|
| Nature of the system | The EU advance cargo declaration system for completing security risk analysis before shipment |
| Declarant | The carrier is responsible for submission; freight forwarders and NVOCCs may submit house-level declarations |
| Sea freight requirements | Submit ENS before loading, including a 6-digit HS code, consignee EORI, cargo description, and other elements |
| Data source | Provided 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
| Stage | Action | Description |
|---|---|---|
| ① Submission of customs declaration | The importer or its customs agent submits a Single Administrative Document (SAD) in the member state system | Must reference a valid ENS record |
| ② Customs review and risk analysis | Member state customs decide release or inspection based on risk parameters | Usually 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 release | Release into free circulation after payment of duties and import VAT | Member 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 item | Basis | Common trigger situations |
|---|---|---|
| CE marking and technical documentation | Relevant product directives | Electrical and electronic products, toys, machinery, medical devices, etc. |
| REACH / SVHC declaration | REACH Regulation | Textiles, plastic products, coatings, inks |
| Food contact material compliance | EU No 1935/2004 | Tableware, packaging containers |
| Textile labeling | Textile labeling regulations | Missing composition, country of origin, or washing instructions |
| Wood packaging | ISPM-15 | Wooden 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
| Recommendation | Description |
| CE certification in advance | CE certification has a long lead time (1–3 months); start before signing contracts |
| REACH compliance | Before exporting chemicals/textiles, verify the REACH status of product substances |
| Tariff classification | Confirm TARIC codes (can be checked via the EU TARIC online database) |
| Importer capability | Verify the validity of the EU importer's EORI and VAT numbers |
| Authorised representative | Some products require an EU-based authorised representative |
| Packaging requirements | Wooden packaging must meet ISPM-15 standard heat treatment |
VI. Common Causes of Customs Clearance Failure and Countermeasures
| Cause | Manifestation After Arrival at Port | Countermeasure |
|---|---|---|
| No valid ENS / ICS2 declaration | Customs declaration cannot be accepted | Before shipment, confirm that the carrier has submitted it and check the receipt |
| Importer's EORI invalid or not activated | Customs declaration rejected by the system | Verify that the EORI number is authentic and valid before shipment |
| Missing CE marking or declaration of conformity | Detained by market surveillance, requiring supplementary documents or return shipment | Complete testing, technical documentation, and the declaration of conformity before export |
| Misclassification | Additional customs duties and VAT to be paid, possibly retroactively | Check using the 11-digit TARIC code; apply for an advance customs duty ruling if necessary |
| VAT deferral not applied for | Large VAT must be paid in cash at customs clearance, straining cash flow | Apply in advance to the tax authority of the member state for a deferral permit |
| Non-compliant wooden packaging | Return shipment or destruction | Use treated wooden pallets bearing the IPPC mark |
| Inaccurate declaration of origin | Additional tax payment and possible penalties | Declare 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
Bofeng Logistics specializes in domestic/international container shipping, Hong Kong/Macau dedicated logistics services, and value-added services (trucking, customs declaration, warehousing, insurance).
Customs declaration service areas: Zhuhai, Guangzhou, Shenzhen.
Tel: 13075678958 | Email: info@zhbfwl.com
Further Reading
- Complete Import Customs Clearance Process: A step-by-step guide to arrival and bill of lading exchange, customs declaration and tax payment, inspection and release, and cargo pickup
- Guide to U.S. Import Customs Clearance: ISF/AMS filing, Section 301 additional tariffs, and FDA/CPSC inspections
- Guide to Japanese Import Customs Clearance: NACCS system, RCEP tariff concessions, and JCT consumption tax
- Guide to Import Customs Clearance in Five Countries: Mexico, Russia, Canada, Australia, and South Korea: NOM/EAC/ACI, biological quarantine, and KC certification
- International Ocean Import Services: End-to-end import support from overseas shipment to domestic pickup
- Guide to European Ocean Freight Import Documentation: ENS declaration, the new ICS2 system, and EU EORI
- Guide to Handling Customs Inspections: inspection methods, factors affecting inspection rates, and practical responses
- China-Germany International Ocean Freight Dedicated Line: sailing schedules to European base ports and arrival connections
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.
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