Clearing an import from China: EU, UK, US, Canada

Goods manufactured in China enter the European, British, American or Canadian market only after customs clearance: an electronic declaration, payment or securing of duties and taxes, then release, which authorizes delivery.

The principles are similar, but ID numbers, calculation bases and timelines differ. This guide reflects the rules known as of late September 2026 and does not replace professional advice on your specific case. Acronyms are listed in our import glossary.

The five common steps

1. Identify yourself: obtain the importer number of the destination country.
2. Classify: assign each item its tariff code, which sets rates and formalities.
3. Value: calculate the customs value, the basis for duties and, depending on the country, for VAT.
4. Check origin and special measures: anti-dumping, surtaxes, licenses, product compliance.
5. Declare, pay, archive: submit the declaration, pay or secure the amounts due, keep the supporting documents.

The freight forwarder organizes transport; the customs broker (customs agent) files the declaration. In both the EU and the UK, they act in direct representation (in the name and on behalf of the importer, who alone is liable for duties) or indirect representation (in their own name on behalf of the importer: both are then liable).

Code, value, origin

The tariff code

The Harmonized System (HS) of the World Customs Organization sets the first six digits, common to most countries. Each country adds its own, and it is the full code, 10 digits in all four destinations, that must be declared: in the EU, the TARIC code of the integrated tariff of the Union (8-digit combined nomenclature, plus 2 digits specific to Union measures); in the US, the HTSUS code (Harmonized Tariff Schedule of the United States).

The code also triggers licenses, restrictions and anti-dumping duties. If in doubt, request an advance ruling that binds the administration: a binding tariff information (BTI) in the EU, an Advance Tariff Ruling in the UK, a binding ruling in the US, an advance ruling in Canada.

Customs value: freight included or excluded

The basis is everywhere the transaction value: the price paid or payable, adjusted for certain elements. The Union Customs Code (UCC) adds, for example, license royalties due as a condition of sale, and molds or tooling supplied by the buyer free of charge or at reduced cost.

The real difference lies in international transport: Europe taxes a CIF-type value (Cost, Insurance and Freight, freight and insurance included up to the port of arrival), North America an FOB-type value (Free On Board, goods loaded at the port of departure).

The Incoterms® rules (a trademark of the International Chamber of Commerce, ICC) allocate costs and risks between seller and buyer, without changing these bases: an FOB price is increased by freight for Europe, a CIF price is reduced by it for North America. See our complete guide to Incoterms® 2020.

Origin, the key to additional duties

In the EU, a product originates in the country where it was wholly obtained or where it underwent its last substantial transformation. A minimal operation (packaging, labeling), or assembly carried out to circumvent a measure, does not confer origin: transit through a third country does not erase "Made in China".

This origin triggers the additional duties detailed below. In the EU, these are mainly anti-dumping duties, targeting products sold below their "normal value": usually a percentage, for five renewable years. TARIC lists them, along with countervailing duties and safeguards.

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European Union: EORI, TARIC and import VAT

EORI. The Economic Operators Registration and Identification number (EORI) is mandatory for any customs operation. It is issued by the Member State of establishment or, for a company not established in the EU, by the Member State of its first operation. It does not expire, unless invalidated (business closure, for example).

Before arrival. The carrier files an Entry Summary Declaration (ENS) in the ICS2 (Import Control System 2), required for all shipments since June 1, 2026. Goods that have arrived must be placed under a customs procedure, or re-exported, within 90 days.

Duties. The declaration releases the goods into "free circulation" throughout the Union, at the rates in force on the date it is accepted. The representative must be established in the EU.

VAT. It applies to the customs value plus duties and costs up to the first place of destination, at the rate of the country of import (from 17% in Luxembourg to 27% in Hungary). Each Member State may allow it to be reported on the VAT return, with no cash outlay: in France, this reverse charge has been mandatory since January 1, 2022 for VAT-registered businesses.

Carbon. For iron and steel, aluminum, cement, fertilizers, electricity and hydrogen, the Carbon Border Adjustment Mechanism (CBAM) has been in its definitive regime since January 1, 2026: above 50 tonnes per year, the importer must be an authorized CBAM declarant.

Small shipments. The €150 (≈ $165) duty exemption disappeared on July 1, 2026. Until July 1, 2028, distance sales to consumers (B2C) up to €150 (≈ $165) pay €3 (≈ $3.30) per tariff line, regardless of quantity, and their VAT can go through the IOSS (Import One-Stop Shop). Other small shipments, including business-to-business samples, pay the normal duty, and small-parcel handling fees are announced by November 1, 2026.

United Kingdom: GB EORI, UKGT, PVA and CDS

Since January 1, 2021, the United Kingdom has applied its own tariff, the UK Global Tariff (UKGT), available in HMRC's (His Majesty's Revenue and Customs) Trade Tariff tool, the customs authority.

GB EORI. To import into Great Britain, you need an EORI starting with GB; one from an EU Member State is not enough. Northern Ireland may require an XI EORI.

Representative. Most importers use a carrier or an agent. That representative must be established in the United Kingdom and receive written instructions specifying direct or indirect representation; in the latter case, agent and importer are jointly and severally liable.

Arrival and value. The carrier files an entry summary declaration via the S&S GB (Safety and Security GB) system. The value includes costs up to the port of import for a direct sea shipment.

VAT and PVA. Standard rate: 20%. A UK VAT-registered business may opt, without authorization, for postponed VAT accounting (PVA): it declares and deducts import VAT on the same VAT return. It informs its agent in writing and finds a monthly statement in the CDS (Customs Declaration Service), the UK's only customs declaration system since March 2024.

Small shipments. The duty exemption for shipments of £135 or less will be removed, by October 2028 at the latest.

United States: IOR, bond, ISF and additional duties

Importer of record. The importer of record (IOR), owner or buyer, declares itself or through a licensed customs broker, strongly advised for a first import. It must exercise "reasonable care."

Bond. Its obligations toward CBP (U.S. Customs and Border Protection) are secured by a customs bond, single-entry or continuous. The continuous bond is worth at least $50,000, or 10% of duties, taxes and fees over the last twelve months if that is more.

ISF. For ocean freight, the Importer Security Filing (seller, buyer, manufacturer, origin, tariff code…) must reach CBP 24 hours before loading at the foreign port; place of stuffing and consolidator, 24 hours before arrival. Each failure exposes you to $5,000 in liquidated damages.

Declaration. The entry is filed within 15 calendar days of arrival, via the ACE (Automated Commercial Environment) system, then the entry summary and estimated duties within 10 business days of the entry. Add the MPF (merchandise processing fee, 0.3464%, with a floor and a cap) and, for ocean freight, the HMF (harbor maintenance fee, 0.125%). No import VAT: sales tax is collected at retail.

Three "sections." Additional duties are named after their statutory provision: section 301, trade retaliation decided by the U.S. Trade Representative (USTR); section 232, national security (steel, aluminum, copper, timber, vehicles…); section 122, a surcharge of up to 150 days for a balance-of-payments imbalance.

Duties in 2026. On February 20, 2026, the Supreme Court (Learning Resources, Inc. v. Trump) ruled that the IEEPA (International Emergency Economic Powers Act) does not authorize these tariffs; those based on that law ended the same day. A 10% surcharge (section 122) followed, from February 24 to July 23, 2026 inclusive.

Since July 24, 2026, new section 301 duties, stemming from USTR investigations into forced labor, add +12.5% on almost all products from China and Hong Kong, excluding exemptions listed in an annex. They add to the 2018-2019 section 301 lists: +25% or +7.5%, raised to +50% or +100% for certain strategic products between September 2024 and January 2026. Products subject to section 232 escape the 12.5%, but pay their own duties. The framework moves fast: check chapter 99 of the HTSUS as of the date of import.

Small shipments. The "de minimis" exemption for shipments of $800 or less has been suspended for all countries since August 29, 2025 and is repealed by law as of July 1, 2027. The simplified procedure (informal entry) remains available up to $2,500.

Canada: BN15, CARM and release prior to payment

Number. The importer combines a 9-digit business number (BN9) with an import program account "RM": this is the BN15. A non-resident company first obtains its number from the Canada Revenue Agency.

CARM. Since October 21, 2024, declarations and payments go through CARM (CBSA Assessment and Revenue Management), the system of the Canada Border Services Agency (CBSA), whose client portal lets you delegate access to your customs broker.

Arrival and release. In ocean freight, the carrier transmits its data to the eManifest program 24 hours before loading. The most common release happens before payment (RPP, Release Prior to Payment), against a financial security calculated by CARM; without security, you pay at release.

Calculation. The GST (goods and services tax) of 5% applies to the customs value plus duties. An error is corrected within 90 days of the moment you have "reason to believe" it exists; documents are kept for six years.

Surtaxes. Several measures affect Chinese products:

• 25% on certain Chinese steels and aluminum since October 22, 2024;
• 50% on steel imported outside the quota, China included, since June 27, 2025 (no stacking with the other steel surtaxes since August 1, 2025);
• 25% on certain steel derivatives since December 26, 2025;
• 25% provisional safeguard on wooden cabinets and vanities since July 31, 2026.

The 100% surtax on Chinese electric vehicles was repealed on March 1, 2026.

Summary: four destinations side by side

Costed example: one order, two destinations

A product subject to section 232 (a steel derivative, for example) would escape the 12.5% but pay those duties instead. Added to the purchase price, freight and delivery, these amounts form the landed cost, the only reliable basis for setting a selling price.

Common mistakes

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Preparing the file from China

A declaration is decided before departure: precise descriptions, codes validated for the destination country, consistent documents, freight broken out, security data transmitted on time. That is the role of our logistics offering, from consolidation in China to customs clearance at destination by a licensed representative, and of our end-to-end service, all the way to your warehouse.