Customs Clearance for Imports from China to Germany and the EU
Eva Solutions handles customs clearance for your imports from China — from tariff classification and customs valuation through anti-dumping checks to the declaration itself, which our customs agents file in your name.
- Filed under direct representation: you remain the declarant and keep control of your customs data
- Tariff classification, customs valuation, and anti-dumping screening
- We check the Chinese export paperwork before the goods are loaded
- Also available when another freight forwarder is handling your shipment
- Documents are ready before the goods reach the EU border
Who Declares Your Goods? Declarant, Representation, and Customs Debt
The question decides who pays if duty is reassessed later. The Union Customs Code recognizes two forms of representation, which differ in liability.
Direct representation: you remain the declarant
We act in your name and on your account. You are both the declarant and the customs debtor. That is how we work. In practice:
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The customs data is yours
The import duty assessment, commodity codes, customs values, and declarations all run under your EORI number and stay available to you, even if you switch service providers.
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Your input VAT deduction is secure
As the importer holding the right to dispose of the goods at the time of import, you can recover the import VAT as input tax. If a third party appears as the importer, that deduction is lost.
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You keep control of the classification
We propose the commodity code and give our reasoning — the decision to approve it is yours.
What the customs power of attorney covers
To declare on your behalf, we need a written customs power of attorney. It names us as your direct representative, sets the scope (one-off or standing, all shipments or particular procedures) and can be revoked at any time. The customs debt stays with you.
Why we do not offer indirect representation
Under indirect representation, the representative declares in their own name and is jointly and severally liable for the import duties. Companies with no establishment in the EU need this. For importers based in Germany or elsewhere in Europe it brings no advantage, only an extra party in the liability chain.
We therefore work exclusively under direct representation. If your case genuinely requires indirect representation, we will say so and refer you elsewhere.
Classification: The Commodity Code Sets the Duty Rate
Every product is assigned a commodity code. That position in TARIC determines the duty rate, any anti-dumping duties, import licensing requirements, and prohibitions. A wrong code is a pricing error, not a formality, and it cuts both ways: classify too high and you overpay for years; classify too low and you face post-clearance recovery with interest.
Why you cannot simply look the code up
The tariff is organized by the nature and function of goods, not by trade names. A „smart home sensor" appears nowhere in the tariff. What matters is the technical function, the material, and whether the device counts as a part or as goods in their own right. With sets and composite goods, you also have to establish which component gives them their essential character.
We classify from the technical documentation and the material composition, not from the description your supplier typed onto the invoice.
BTI: a binding ruling for contested classifications
Where the classification is not clear-cut, or where recurring volumes are at stake, you can apply for Binding Tariff Information. A BTI binds the customs authorities of every member state to that classification for three years: to the classification itself, not to the duty rate, which can shift if the tariff is amended. Whether it is worth the effort depends on the value of the goods, how often you ship, and how much the disputed rate costs you. We will tell you when the application pays for itself.
Customs Value: What the Duties Are Actually Calculated On
Duty and import VAT are not calculated on the invoice amount but on the customs value, and that is routinely higher.
Among the items added to it:
- Freight and insurance up to the EU external border On an FOB purchase, the entire ocean freight, which is not on your invoice.
- Royalties and license fees Where you pay them as a condition of the sale.
- Assists Materials, tools, moulds, dies, and development work that you supply to your manufacturer free of charge or at a reduced price.
- Packing costs and commissions Other than buying commissions.
Assists catch out companies with their own production in China: if you pay for an injection mould and leave it with the factory, a proportion of the tooling cost belongs in the customs value. It is often overlooked and surfaces in a customs audit years later.
Not included in the customs value: transport costs within the EU beyond the place of introduction, and EU duties and taxes, provided they are shown separately. That is why we structure freight invoices so that costs before and after the EU border can be told apart.
Anti-Dumping, Origin, and Preferences on Chinese Goods
There are no tariff preferences for China
The EU and China have no free trade or preferential agreement. Goods of Chinese origin therefore always attract the third-country duty rate — an EUR.1 or any comparable preference document will not help here.
You still need proof of origin, but for other purposes: as evidence of non-preferential origin for anti-dumping measures, tariff quotas, trade policy measures, and origin marking. Confuse the two and you will ask your supplier for the wrong document.
Check anti-dumping duties before you order
Anti-dumping and countervailing duties are the biggest cost risk in China imports. They are set by product and often by manufacturer, reach rates of over 50 to 80 percent, and can wreck a costing model. Product groups affected have included bicycles and e-bikes, solar glass, steel products, ceramic tiles, and fasteners.
We check before you place the order, not once the container is sitting in port:
- Is there an anti-dumping measure on the commodity code?
- Is your specific manufacturer named, or does the rate for „all other companies" apply?
- Is an anti-circumvention investigation under way that also covers deliveries routed through third countries?
- Is an expiry review pending that could extend or end the measure?
A manufacturer-specific rate is a selection criterion in its own right: two factories making the same product can differ by dozens of percentage points in duty.
Customs Examination: When Customs Opens the Shipment
Not every declaration goes straight through: customs can call the goods in for examination — as a random check, on a risk basis, or because the declaration raises questions.
Depending on the trigger, they check quantity, nature, declared value or classification. For you that means idle time, the cost of opening and repacking and, with a container, demurrage mounting fast.
Lower odds come from a description matching the commodity code, a packing list matching the invoice, a plausible value and complete supporting documents. If an examination happens anyway, we deal with the customs office, submit what it asks for and keep you posted.
Special Customs Procedures
Not every shipment has to go straight into free circulation: certain procedures defer, reduce or avoid the duties.
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Customs warehousing
Goods are stored uncleared; duty and import VAT fall due only on removal. Worth considering for large batches with slow stock turnover and for goods that may be re-exported.
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Deferment of payment
Import duties are accumulated on a deferment account and settled later — this eases cash flow when you ship frequently.
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Procedure 42 and fiscal representation
Goods are imported into Germany but move straight on to another EU member state: the import is exempt from import VAT. Procedure 42 is open to any importer established in the EU; fiscal representation is for companies without an establishment in Germany. Both routes are strict on formalities — the evidence for the intra-Community supply has to be complete.
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Inward processing and temporary admission
For goods processed in the EU and then re-exported, and for goods that stay only for a while — trade fair exhibits, samples, test equipment. Import duties are waived or reduced.
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T1 transit procedure
Goods travel uncleared from the point of entry to a customs office inland — you clear customs where it suits you operationally, not at the port of arrival.
We assess case by case which procedure fits — the only one worth using is the one whose conditions you can meet on an ongoing basis.
The Export Side in China: What Has to Be Right Before Loading
Most customs problems in Germany start in China: an invoice describing the goods as „gifts" or „samples", a missing net weight, a packing list that does not match the invoice. Every one of these costs days later on.
Our office in China therefore checks, before the goods are loaded:
- The supplier's export license Can the factory export in its own right, or does the export run through a third party? That decides who appears as the shipper on the paperwork.
- The commercial invoice A description of the goods that fits the commodity code, correct values, the Incoterm, and complete party details.
- The packing list Unit counts, gross and net weight, dimensions per piece, and agreement with the invoice.
- Advance data for the entry summary declaration ICS2 (entry summary declaration) requires a meaningful description of the goods with a six-digit commodity code, plus the details of all parties. If missing or too vague, loading onto the vessel can be refused.
- Origin and product documentation Certificate of origin, CE declaration of conformity, test reports, depending on the product group.
We run this check in Chinese, directly with the factory — unlike a customs agency in Germany, which can only step in once the paperwork has long since been issued.
A Warning on DDP Offers from Chinese Forwarders
„All inclusive, duty paid to your door, one fixed price" — a common offer from Chinese forwarders. The price looks attractive because duty and import VAT are supposedly already covered. That is exactly where the problem lies.
Under arrangements like these, it is often a third party that appears as the importer, not your company: the forwarder, a customs agent or a nominee importer. The consequences:
- No input VAT deduction If you are not the importer and do not hold the right to dispose of the goods at the time of import, you cannot recover the import VAT as input tax. A pass-through item becomes a real 19% cost.
- No import duty assessment You receive no document for your tax office, and often do not know under which commodity code or at what value your goods were declared.
- Liability exposure If the declaration understates the value, a post-clearance recovery follows the facts of the case — and you are the one who received and sold the goods.
If you want to buy DDP, we review the offer first: who is entered as declarant, which EORI number is used, what customs value is declared, and whether you receive the import duty assessment. If those questions cannot be answered cleanly, the attractive fixed price rarely turns out to be one.
Process: How Customs Clearance Works with Eva Solutions
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Goods intake and classification
You send technical documentation, data sheets, and samples. We propose the commodity code, give our reasoning, and screen for anti-dumping duties, licensing requirements, and import bans.
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Power of attorney and master data
You grant the power of attorney for direct representation. We set up your profile: EORI number, contacts, and regularly shipped commodity codes.
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Review of the export paperwork in China
Before loading, our office in China checks the invoice, packing list, and supporting documents. Errors are corrected where they arose.
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Preparing the declaration
While the goods are in transit, we establish the customs value, assemble the documents, and prepare the declaration.
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Declaration and assessment
Our customs agents file the declaration through the ATLAS system in your name. You receive the import duty assessment and a breakdown of customs value and charges.
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Release for free circulation
Once the goods are released for free circulation, they go on to your site: with our delivery or your own forwarder.
The Cost of Customs Handling
Every import involves three separate costs:
- Customs duty
- By commodity code and origin, plus anti-dumping duty where applicable.
- Import VAT
- 19% on the customs value, duties and transport costs to the first place of destination. Normally a pass-through item if you are the importer and entitled to deduct input tax.
- Our fee
- For the handling — shown separately from the duties.
What drives the workload: number of commodity codes in the shipment, first-time or repeat clearance, anti-dumping and origin research, special customs procedures, evidence for licensable goods, and any examination.
No flat rates: we price each case individually and show duties and fee separately, so you can always see what is tax and what is service.
Who Is Customs Clearance Through Eva Solutions For?
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Importers of goods that need explaining
Electronics, machinery, composite goods: the classification is not obvious and a single percentage point of duty counts.
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Companies in anti-dumping-exposed product groups
Bicycles, solar, steel, tiles, fasteners — the choice of manufacturer decides the duty rate.
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Customers with their own production in China
Tooling, moulds and development work have to feed correctly into the customs value.
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Distributors selling across Europe
Importing into Germany and moving goods on to other member states.
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Importers who buy their freight elsewhere
Outsourcing customs handling alone: we take it on without a transport order.
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First-time importers
First import, with no EORI number and no grasp of the process or the evidence requirements.
- Usually within 24 hours on working days
- A first, non-binding assessment of your project
Why Eva Solutions for Your Customs Handling?
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Checks start in China, not at the port
We review the invoice, packing list and supporting documents before loading, in Chinese, directly with the factory. An error there costs an email; in Hamburg it costs idle time.
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Classification as real work, not a by-product
We determine the commodity code from technical documentation and document our reasoning, not from the invoice description. In contested cases we tell you when a binding ruling is worth applying for.
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Anti-dumping screening before you order
We check before you place the order — and point it out when a different manufacturer of the same product carries a markedly lower rate.
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Direct representation, no intermediate structure
You remain the declarant and importer, with input VAT deduction and full access to your own customs data.
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Available without a transport order
You can book customs handling on its own, regardless of who moves your goods.
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A German company on German business hours
An office and contacts in Waldrach, Germany (Naga Technologies GmbH) — also our contact and service address. Reachable when the customs office calls. Plus a team in China that knows the same shipment from the other end.
Four locations in China
Offices and warehouses in the north and south of China – where we collect and check goods and prepare them for export.
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Harbin
Head office and warehouse
Logistics park in Harbin where our warehouse is located
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Guangzhou
Office and warehouse
Guangzhou: the building that houses our warehouse
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Shenzhen
Office and warehouse
Shenzhen: the building that houses our office and warehouse
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Sanya
Office, IT and technology
Yazhou Bay Science & Technology City in Sanya, home to our office
Frequently Asked Questions
What does customs handling cost on imports from China?
Duties and services are two different things. Duty follows the commodity code and the origin, and 19% import VAT applies to the customs value. Our fee depends on the workload: the number of commodity codes, whether it is a first-time or a repeat clearance, the research involved in anti-dumping questions, and any special procedures. We price case by case and show both separately.
How long does customs clearance take?
Where the documents are complete and the declaration prepared, release often happens the same day in practice. Delays almost always come from incomplete paperwork or an examination. Because we prepare the declaration while the goods are still in transit, the most common cause of waiting disappears.
What is the difference between direct and indirect representation?
Under direct representation we act in your name and on your account: you are the declarant and the debtor. Under indirect representation the representative declares in their own name and is jointly and severally liable. We work exclusively under direct representation — that secures your input VAT deduction and your access to your customs data.
Do I need an EORI number?
Yes. No customs declaration is possible without one. You apply for it once and it is valid across the EU — our page on importing from China covers the details.
Who is liable if the commodity code turns out to be wrong?
Under direct representation the declarant — you — is the debtor, and a post-clearance recovery is addressed to you. That is why we document our reasoning for every classification and put it to you for approval, rather than setting it silently. In unclear cases we recommend applying for Binding Tariff Information.
Are there tariff concessions on goods from China?
No. There is no preferential agreement between the EU and China, so the third-country duty rate always applies. No preference document such as an EUR.1 exists for China. You still need a certificate of origin, though — for anti-dumping questions, quotas, and origin marking.
How high are anti-dumping duties and who do they hit?
They are set per product group and often per manufacturer as well, ranging from a few percent to over 80 percent. Product groups affected include bicycles and e-bikes, solar glass, steel products, ceramic tiles, and fasteners. We check before you order whether your goods and your specific manufacturer are covered.
What goes into the customs value?
The purchase price plus freight and insurance up to the EU external border, royalties and license fees, packing costs, and assists such as tools, moulds, or materials that you supply to your manufacturer free of charge. Transport costs within the EU beyond the place of introduction and the EU charges themselves are excluded, provided they are shown separately.
Do I have to pay duty on tooling costs if I paid for the mould myself?
As a rule yes, on a pro-rata basis. A mould or tool that you supply to the factory free of charge or at a reduced price is an assist and increases the customs value of the goods produced with it. We apportion the cost properly across the shipments instead of ignoring it.
Can you handle customs clearance if another forwarder moves the goods?
Yes. Customs handling is a standalone service with us. We need the transport documents, the commercial invoice, the packing list, and your customs power of attorney — who carries the goods makes no difference.
What happens during a customs examination?
Customs calls the goods in and checks quantity, nature, value, or classification. This causes idle time and the cost of opening and repacking. We deal with the customs office, submit whatever documents they ask for, and keep you posted.
Is a customs warehouse worth it for my imports?
If you import large batches and sell them down over a longer period, or if goods may be re-exported, a customs warehouse defers the duties until removal and eases cash flow. With fast stock turnover, the administrative overhead usually outweighs the benefit. We work the numbers for your case.
Is a DDP offer from China really cheaper?
Often only on paper. If a third party appears as the importer under a DDP arrangement, you lose the input VAT deduction on the import VAT and receive no import duty assessment. We review a DDP offer up front to establish who will be entered as declarant and what customs value is to be declared.
Request Customs Handling for Your Shipment
Tell us the type of goods, the manufacturer, and your shipment volume — we screen classification and anti-dumping, establish the customs value, and show duties and fee separately.
Need every detail in one place? Download the questionnaire, fill it in and send it to contact@versendex.de.
Planning a project in China?
Send us your enquiry with the product, quantity and destination. We'll work out which steps you need and come back to you with a proposal.