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Importing from China to the EU in 2026: what's changed and what European importers need to know

By Will Partridge
6 May 2026·Last updated: 6 May 2026·chinaeu-importscustomscountry-guideseuropean-importers

Importing goods from China to the EU in 2026 looks materially different from how it looked a year ago. Three changes are now in force: ICS2 Release 3 requires complete pre-arrival data for all sea cargo (live since September 2025, hard cutoff February 2026); the Carbon Border Adjustment Mechanism entered its definitive financial phase on 1 January 2026; and the €150 customs duty exemption for low-value parcels ends on 1 July 2026. The fundamentals - duty under the EU Common Customs Tariff, import VAT at the destination country's rate, anti-dumping risk on specific product categories - haven't changed. What's changed is the compliance overhead.

This post covers what's actually changed for European importers buying from China this year, what hasn't and the operational habits that prevent most of the customs trouble. Sections are ordered roughly by the order you'd encounter them on a shipment: classification and duty first, then what you have to file, then the specific risks that catch China imports more than other origins, then prevention.

China is an MFN partner, not an FTA partner

China trades with the EU under Most-Favoured-Nation terms. There's no free trade agreement, no preferential origin claim, no tariff reduction available because your goods came from Shanghai instead of São Paulo. The Generalised Scheme of Preferences (GSP), which historically gave reduced duty on certain China-origin goods, ended for China in 2022. Form A is no longer accepted as evidence of preferential origin.

Form C/O issued by CCPIT (the China Council for the Promotion of International Trade) is sometimes still required - by your customer, by a letter of credit or by EU regulations covering specific regulated goods - but it does not reduce duty for China-origin goods. Provide it where asked, but don't expect it to lower your bill.

Operationally: budget the full EU Common Customs Tariff rate for every China shipment. Importers from FTA partners like the UK, Japan, South Korea, Vietnam or Switzerland get duty reductions where origin rules are met. China importers don't.

The customs procedure for a typical China import

Most China imports go through release for free circulation - the standard procedure where goods clear customs and enter the EU market without restrictions. Your customs broker files a declaration in the destination member state's system: DMS in the Netherlands, ATLAS in Germany, DELTA in France, PLDA in Belgium, AIDA in Italy. The declaration is filed where the goods physically enter the EU, even if the final destination is elsewhere.

The declaration covers the importer of record, the goods classification (HS code, country of origin, customs value), the procedure code and any preferential origin claim if applicable - which doesn't apply for China. Documents need to be ready before the vessel arrives: commercial invoice, packing list, bill of lading or air waybill, plus any product-specific certificates. Section 10 covers the document set in detail.

Once duty and import VAT are paid, the goods are released into free circulation. Other procedures exist - customs warehousing, inward processing for re-export, transit - and have their place. For most regular importers buying stock from China, free circulation is the path. Our guide to EU customs procedures covers the alternatives if you need them.

ICS2 Release 3: pre-arrival data is now mandatory

The Import Control System 2 (ICS2) is the EU's pre-arrival risk screening platform. Release 3 has been live since 1 September 2025, with ICS1 fully phased out on 3 February 2026. For sea cargo from China, a complete Entry Summary Declaration (ENS) must be filed before the vessel arrives at its first EU port of entry.

The ENS data has to be specific. Six-digit HS codes minimum, plain-language goods descriptions that actually identify what's in the box. Generic terms like "general cargo", "various", "parts", "samples" or "miscellaneous" are explicitly on the EU's stop-words list and trigger an automatic flag. "Stainless steel kitchen sinks, 304 grade, 600x500mm, undermount style" is the kind of description that passes. "Kitchen items" isn't.

Filing responsibility usually sits with the carrier or freight forwarder, who pulls the data from your shipping documents. But the importer is the source of truth. The HS code on your commercial invoice and the goods description you give your supplier propagate through the chain. If they're wrong at the source, they're wrong in the ENS.

The risk if data is missing, late or rejected is a "Do Not Load" decision before the vessel sails, or vessel-side delays at the port of entry. Either translates straight into demurrage and detention exposure.

Operator advice: agree with your forwarder up front who is filing the ENS, and review the goods descriptions on your commercial invoices before they go out to the carrier. Cleanup at supplier-invoice stage is far cheaper than cleanup at port.

Duty rates, HS codes and TARIC

Your HS code determines your duty rate. For China-origin goods, with no FTA in play, the rate that applies is the EU Common Customs Tariff third-country rate. Rates start at 0% for many raw materials and intermediate goods and climb to 12% or higher for finished products in textiles, ceramics, leather goods and similar.

The TARIC database at ec.europa.eu/taxation_customs/dds2/taric is the authoritative source. It shows the rate, any anti-dumping or countervailing duties, any quotas and any product-specific measures (CE marking, REACH, tariff suspensions, restrictions). Always check TARIC for your actual HS code before placing an order.

China-origin goods get classified-by-customs more aggressively than goods from most other origins. HS misclassification is the single most common audit finding in post-clearance reviews of China imports. Suppliers naturally pick the lowest-duty code; customs reviews and reclassifies upward; and you back-pay the difference plus interest.

For products you import repeatedly, a Binding Tariff Information (BTI) ruling from EU customs gives you a legally-binding classification valid for three years across all member states. The application is administrative - usually one to four months - but the protection is worth it for stable product lines. Our duty calculator gives a quick rate check by HS code.

Anti-dumping and countervailing duties: the China-specific risk

Anti-dumping duties (ADD) and countervailing duties (CVD) are the single biggest cost surprise for China importers. Where your standard duty might be 3% or 6%, an ADD measure can add 30%, 50%, 80%, even over 100% on top. They aren't applied instead of regular duty - they're stacked on top.

The Commission has hundreds of active measures. Categories most affected by current China-origin ADD include chemicals, steel and steel products, ceramics, e-bikes, e-bike batteries, solar panels, batteries, fasteners and biodiesel. Measures change: new investigations open continuously, definitive duties get imposed at the end of investigations and expiry reviews either extend or terminate existing measures.

Recent and current China-origin measures from 2026:

Product category Indicative ADD range Reference
Ceramic tableware and kitchenware 17.9% (cooperating exporters) - 79.7% (residual) Reg (EU) 2026/274, effective 7 Feb 2026
Phosphorous acid 122.8% Definitive duty imposed Mar 2026
Molten / fused alumina 88.7% - 110.6% (with duty-free quota) Reg (EU) 2026/114, effective 17 Jan 2026
Candles, tapers (paraffin/stearin) up to 60.3% Reg (EU) 2026/157, effective 26 Jan 2026
L-Valine (purity >95%) 31.3% - 53.8% Reg (EU) 2026/319, effective 14 Feb 2026
Steel wheels Definitive (expiry-review confirmed Feb 2026) Reg (EU) 2026/428

Two things matter operationally.

Check TARIC before each new product or new supplier. A measure that didn't exist when you last imported the same HS code may now apply. The Commission's trade defence portal at policy.trade.ec.europa.eu/enforcement-and-protection/trade-defence/anti-dumping-measures_en lists active and pending measures, with case numbers and Official Journal references. Free email alerts are available - subscribe so new investigations and definitive duty notices land in your inbox.

The additional TARIC code identifies the specific producer's duty rate. Cooperating exporters get listed by name with a lower rate; everyone else (the residual) pays the maximum. If your supplier's additional code is missing, wrong or unlisted, the residual rate applies automatically - and that can be the difference between 18% and 80% on a single shipment. Verify your supplier's additional TARIC code before placing the first order on any product subject to ADD.

CBAM if you import iron, steel, aluminium or fertilisers

The Carbon Border Adjustment Mechanism (CBAM) entered its definitive financial phase on 1 January 2026. The transitional reporting-only phase that ran from October 2023 is over. Importers of CBAM goods above a threshold now have to hold authorised declarant status, buy CBAM certificates corresponding to embedded emissions in their imports and surrender those certificates annually.

A 50-tonne annual mass-based threshold was introduced by Regulation (EU) 2025/2083 (the CBAM Omnibus simplification). Importers below 50 tonnes per year of CBAM goods are fully exempt - no declarant status required, no certificates to buy, no annual surrender. The threshold doesn't apply to electricity or hydrogen, which are in scope from the first kilogram.

Sectors in scope: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen. For European SME importers, the categories that bite in practice are Chinese steel coils, aluminium extrusions and similar primary or semi-finished metal products. A few container loads of steel a year easily clears 50 tonnes.

Above the threshold: authorised CBAM declarant status is required. The application deadline was 31 March 2026 - if you missed it, you can still apply, and pending applications allow continued imports while the authorisation is processed. Apply now if you haven't.

Certificate purchases begin 1 February 2027. The first surrender is due 30 September 2027 covering 2026 imports. Embedded emissions data has to come from your suppliers, so building that supplier-data pipeline now is far less painful than scrambling for it next September. The wider customs context sits in our guide to EU customs procedures.

The €150 customs duty threshold ends 1 July 2026

Until 30 June 2026, parcels valued under €150 sent from a non-EU country to an EU consumer are exempt from customs duty. (Import VAT has applied since July 2021 via the Import One-Stop Shop scheme, IOSS - this is about duty, not VAT.) The exemption is the rule that's let small e-commerce parcels from China flow through EU borders for years without facing tariff.

From 1 July 2026, that exemption ends. An interim flat rate of €3 per item applies to e-commerce parcels under €150 where the seller is IOSS-registered. The interim regime runs until the EU Customs Data Hub is operational, expected around mid-2028. After that, full HS-code-based tariff rates apply to every parcel regardless of value.

For most small and medium importers, this isn't about direct-to-consumer parcels. It's about the small replenishment shipments and supplier samples you regularly receive from Chinese suppliers - the spare parts, the prototype runs, the small reorders that previously slipped under the threshold. Those are now dutiable. €3 per item for a sample shipment is small money; on twenty different parts in one consignment it adds up, and the customs paperwork burden grows because every parcel needs declaration.

If your suppliers ship small consignments DAP (Delivered At Place) where the buyer pays at delivery, expect the refusal rate at the door to climb. Plan to switch to DDP for small reorders, or absorb the duty into your landed cost.

Import VAT and country differences

Import VAT is charged at the destination country's standard rate when goods enter for free circulation. Rates vary: 21% in the Netherlands and Belgium, 19% in Germany, 22% in Italy, 20% in France and so on. Import VAT is recoverable for VAT-registered businesses - you offset the VAT you paid at import against the VAT you collect on your sales.

Most member states require import VAT paid at clearance and recoverable through your normal VAT return; if you import to the Netherlands or Belgium and meet the criteria, the deferment schemes are worth setting up because they can shift several weeks of import VAT off your cash position.

The Netherlands' Article 23 deferment licence is the best-known example: you don't pay import VAT at clearance, you account for it on your periodic VAT return as both a charge and an offset, netting to zero in most cases. Belgium's postponed VAT accounting works similarly. Both require Dutch or Belgian VAT registration and authorisation.

Documents you'll always need

Every China import needs the same core document set, plus product-specific certificates depending on what you're shipping.

  • Commercial invoice. Chinese supplier details, exact buyer details (matching your EORI), itemised line items with values, currency, HS code per line, country of origin, Incoterm. Vague descriptions trigger ICS2 flags.
  • Packing list. Has to match the commercial invoice exactly: same line items, same quantities, same weights, same carton counts. Mismatches between invoice and packing list are one of the most common reasons holds happen.
  • Bill of lading (sea freight) or air waybill (air freight). Issued by the carrier or forwarder. Spelling errors here propagate everywhere - an importer name with a typo on the BL forces an amendment that costs days.
  • HS code classification, verified against TARIC. Not just whatever the supplier wrote. You're the one liable.
  • Certificate of origin (Form C/O from CCPIT). Required for some regulated goods or commercial reasons. Doesn't reduce duty for China.
  • Product-specific certificates. CE Declaration of Conformity for electrical goods, machinery, toys, PPE. REACH compliance for chemicals. RoHS for electronics. Phytosanitary certificate for plant-based goods. Health certificate plus BIP entry for animal-origin products.

Our EU customs documents checklist covers each of these in depth.

Common pitfalls when importing from China

After enough shipments, the same mistakes show up again and again.

  • BL details that don't match the commercial invoice. Importer name spelled wrong, address wrong, quantity off by one carton. Amendment fees, days lost, demurrage exposure. Get your forwarder to send you the draft BL before it's released and read every field.
  • Goods descriptions too vague for ICS2. "Plastic items", "general goods", "parts". These get rejected. Tell your supplier exactly what to write on the commercial invoice and check it before they send it.
  • HS codes declared by the supplier without your verification. Suppliers pick the lowest-duty code; customs reclassifies upward on inspection; you pay back-duty plus interest. Verify against TARIC before the first order, not after the third audit.
  • Anti-dumping additional TARIC codes missing or wrong. The residual rate applies automatically - which can mean 80% duty instead of 18%. For any HS code subject to ADD, confirm your supplier's additional TARIC code in writing before you place the order.
  • Container demurrage during Chinese New Year and Golden Week. Late January through mid-February (CNY) and the first week of October (Golden Week) are full factory and port shutdowns. Shipments in transit during these windows lose days. Plan your purchasing calendar four to six weeks ahead of these dates.
  • Incoterms confusion on DDP shipments. Many Chinese suppliers offer DDP "we'll handle everything" pricing. Read the small print: the duty paid is rarely the actual landed cost, and disputes about who pays the gap arise on arrival. Our Incoterms 2020 guide covers what to verify before agreeing to DDP terms.

Lead times and routes in 2026

Sea freight from Shanghai, Ningbo or Shenzhen to Rotterdam, Hamburg or Antwerp takes longer in 2026 than it did before 2024. The Red Sea security situation has pushed most carriers onto the Cape of Good Hope routing, adding roughly two weeks to most schedules.

If your purchasing planning assumed 30 to 35 days port-to-port - the Suez norm - your real numbers right now are 40 to 50+ days for Cape routing. Build the buffer into your inventory planning and supplier lead times. Not doing so is how stockouts happen on bestsellers.

Air freight remains the fallback for time-critical or high-value goods. Cost step-up is significant - typically five to seven times sea freight per kilo - but it's there when you need it.

Chinese New Year (late January, mid-February) and Golden Week (first week of October) are the predictable shutdowns. Factor them into your purchasing calendar. They aren't surprises if you're tracking them.

How to stay on top of all of this

A few practical habits that compound over years.

  • Maintain a per-supplier HS code list, validated against TARIC, refreshed annually. Don't trust supplier-stated codes.
  • Subscribe to the European Commission's free email alerts on trade defence measures. Early warning of a new ADD investigation on a category you import is worth more than any retroactive damage control.
  • Check ADD status before every new product or supplier, particularly for chemicals, ceramics, steel, e-bikes, solar, batteries.
  • Build buffer for Chinese holiday shutdowns into your purchasing calendar. CNY and Golden Week aren't surprises.
  • If you import iron, steel, aluminium or fertilisers, count your annual tonnage. Above 50 tonnes you're a CBAM declarant; below it you're exempt under the Omnibus simplification.
  • Use shipment management software that tracks documents, deadlines and customs events across all your shipments together rather than per-spreadsheet. CARVO is built for small and medium European importers and includes country-specific customs checklists, document tracking and deadline notifications - it replaces the spreadsheets and email threads that import teams typically rely on.

If you're at the spreadsheet-and-email stage and considering moving to dedicated software, our piece on why European importers outgrow Excel walks through what tends to break first.

Frequently asked questions

Do I need a Chinese certificate of origin to import from China to the EU?

A certificate of origin (typically Form C/O issued by CCPIT) is sometimes required by EU customs or by your customer, but it does not reduce your duty - China is not an FTA partner. It's most often needed for regulated product categories, for tender or banking documentation or where your buyer specifically requires it. Provide it when asked, but don't expect any tariff benefit. Your supplier obtains it through CCPIT, the China Council for the Promotion of International Trade.

What's the import duty rate from China to the EU?

Duty rates depend on the HS code of your product and range from 0% to 12% or higher under the EU Common Customs Tariff. The TARIC database is the authoritative source - search by HS code to find the third-country rate that applies to China-origin goods. On top of standard duty, anti-dumping duties may apply for specific categories like ceramics, steel, e-bikes and chemicals. Verify both before ordering.

Are anti-dumping duties applied on top of regular customs duty?

Yes - anti-dumping duties are added to the regular customs duty, not in place of it. Rates can exceed 100% in some cases, and they're product-and-supplier specific. The additional TARIC code on your declaration identifies which producer your supplier is and which rate applies; without the right additional code, the residual (maximum) rate applies automatically. Categories currently subject to ADD include ceramics, steel products, chemicals, e-bikes, batteries, fasteners and solar panels.

Does CBAM apply to my Chinese imports?

CBAM applies if you import more than 50 tonnes per year of cement, iron and steel, aluminium or fertilisers from China (or any non-EU origin). The 50-tonne de minimis threshold was introduced by Regulation (EU) 2025/2083; importers below the threshold are fully exempt. Above it, you need authorised CBAM declarant status. Certificate purchases begin 1 February 2027 with the first surrender on 30 September 2027 covering 2026 imports. Electricity and hydrogen are in scope from any quantity.

What changes from 1 July 2026 for low-value parcels from China?

From 1 July 2026, parcels valued under €150 from China lose their customs duty exemption and become subject to a flat €3 duty per item under an interim regime. IOSS for VAT continues unchanged - this affects customs duty, not import VAT. The interim €3 charge runs until the EU Customs Data Hub goes operational, expected around mid-2028, when full HS-code-based tariff rates apply to every parcel regardless of value.

How long does sea freight from China to the EU take in 2026?

Typical Shanghai or Ningbo to Rotterdam transit times in 2026 are 40 to 50+ days when routed via the Cape of Good Hope, longer than the pre-2024 norm of 30 to 35 days via Suez. Air freight is the fallback for time-critical or high-value goods - significant cost step-up but reliable transit. Plan around Chinese New Year (late January, mid-February) and Golden Week (first week of October), when factories close and ports run light.

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