China Import Requirements: The 2026 Compliance Checklist

Most first-time importers discover the requirements in the worst possible order: after the container has sailed. The supplier was great, the price was great, the samples were great — and then a customs broker emails asking for a bond, an HTS code, an FCC declaration, and confirmation that the entity on the commercial invoice is actually registered to export. Nobody mentioned any of it during negotiation, because nobody on the Chinese side had a reason to.

This guide is the checklist that should exist before you place the order. It is not a walkthrough of sourcing, negotiation, or freight — for the end-to-end process, see our complete guide to importing from China. This article covers a narrower and more consequential subject: the compliance requirements that attach to a China shipment, on both sides of the water, and who is legally responsible for each one.

There are two sets of them, and confusing the two is the most expensive mistake in this space. Your destination country's requirements are what the United States (or EU, UK, Australia) demands of you as the importer — non-negotiable, penalty-backed, and your legal obligation rather than your supplier's, no matter what the Incoterm says. China's export-side requirements are what your supplier must be licensed and registered to do in order to legally put goods on a vessel; if they cannot, your order gets routed through a third party you never vetted, on paperwork you cannot reconcile.

We will work through both in the order a real shipment encounters them, and finish with the part most guides skip: how to verify that the Chinese company on your purchase order actually holds export rights before you pay a deposit.

The Two Sides of One Shipment

Every China import has a Chinese-side compliance chain and a destination-side chain, joined at the vessel. Each has its own regulator, paperwork, and responsible party.

The gap between these two chains is where importers get hurt. Clean paperwork in China tells you nothing about whether your entry is clean in the US, and vice versa. You need both — and only one of them is anybody's job by default.

Side A: What the United States Requires of You

1. You Need an Importer of Record — and It Is Probably You

The importer of record (IOR) is the party legally responsible for the entry: declaring the goods accurately, paying duties and fees, and keeping records. Everything else in this section flows from that designation. The IOR must be the owner, purchaser, or a licensed customs broker acting on their behalf — which, for a US company buying from a Chinese factory, means your company. That stays true when the supplier quotes DDP ("delivered duty paid") and offers to handle everything: a DDP quote transfers the logistics cost, not US legal liability, and typically leaves your company named as IOR on an entry you never reviewed.

To act as IOR you need an importer number — for a US business, your IRS employer identification number, filed with CBP on Form 5106. Foreign companies without a US presence can be assigned a CBP number but face additional bond and liability complications; most non-US buyers are better served by a US subsidiary or an established IOR service.

2. You Need a Customs Bond

A customs bond is a financial guarantee to CBP that duties, taxes, and fees will be paid. Per CBP's bonds guidance, bonds are required for nearly all formal entries and for some informal and temporary-importation entries. You obtain one from a surety, usually via your broker, on CBP Form 301. Two types matter:

• Single Transaction Bond (STB) — covers one importation, generally written for the value of the merchandise plus duties, taxes, and fees. Fine if you import once or twice a year.
• Continuous Bond (CB) — covers all entries for a year and renews until cancelled. Typically 10% of duties, taxes, and fees paid in the previous twelve months, with a floor. If you import monthly, this is almost always cheaper than stacking STBs, and it also covers your Importer Security Filing obligations.

CBP publishes its methodology in A Guide for the Public: How CBP Sets Bond Amounts. One consequence of the current tariff environment: as your duty bill rises, CBP can require you to increase your bond mid-year. Importers who moved into high-tariff categories and did not adjust received insufficiency notices and had entries held.

3. You Need a Customs Broker (Practically Speaking)

Nothing legally requires a licensed customs broker — you can file your own entries. Almost nobody does. A broker files the entry through the Automated Commercial Environment, advises on classification, and manages your bond and agency filings. You appoint them with a customs power of attorney.

What a broker will not do is verify your supplier. Brokers work with the documents you hand them. If the commercial invoice names a company that does not exist, or exists but has no import/export scope, your broker files it as given and the problem surfaces later — during a CBP request for information, or when you try to enforce a contract against an entity that turns out not to be your counterparty. That gap is the subject of the last section of this guide.

4. HTS Classification Is Your Legal Obligation

Every article entering the US must be classified under the Harmonized Tariff Schedule of the United States. The ten-digit HTS code determines your duty rate, whether trade remedies or quota apply, and which partner agencies get notified. Two things importers consistently get wrong:

Classification is yours, not your supplier's. Chinese suppliers routinely put an HS code on the invoice. It is a six-digit international code chosen for Chinese export purposes — sometimes chosen to optimise the supplier's VAT rebate — and it is not a US classification. Adopting it uncritically is how misclassification happens.

"Reasonable care" is the standard. CBP operates on informed compliance: you are expected to exercise reasonable care in declaring classification, value, and origin. Getting it wrong is a violation even without intent, and the penalty exposure under 19 U.S.C. 1592 is substantial. Documented reliance on a broker's advice, a binding ruling from the CROSS rulings database, or a written classification analysis is how you demonstrate that care. If two plausible codes carry materially different duty, request a binding ruling before the first shipment — it is free, and it converts an open exposure into a documented position.

5. Section 301 and the Stacked Tariff Layers

For China-origin goods, your landed duty is rarely just the HTS general rate. Several layers stack, and the composition changes with policy.

Section 301 tariffs — imposed following USTR's investigation into China's technology transfer practices — apply to a large share of China-origin goods at rates that vary sharply by category. According to USTR's Section 301 tariff actions page, rates set through the statutory four-year review include 100% on electric vehicles, 50% on solar cells, and 25% on tungsten products, with natural graphite moving to 25% in 2026. A December 2025 determination set an initial 0% level on semiconductors from China, scheduled to increase on June 23, 2027 to a rate announced at least 30 days in advance. Certain exclusions — machinery and solar manufacturing equipment — were extended following the November 2025 US–China understanding, through November 10, 2026.

All of these figures are as of August 2026 and are the most volatile numbers in this guide. Lists, rates, and exclusion windows have been modified repeatedly, and further Section 301 investigations were opened in 2026 on separate grounds — USTR announced findings and proposed actions in 60 investigations relating to forced labor goods in June 2026. Never price a sourcing decision off a tariff figure in a blog post, including this one. Check the current HTS and CBP's Section 301 FAQ, then confirm with your broker.

Beyond Section 301, watch for antidumping and countervailing duty (AD/CVD) orders — product-and-country specific, sometimes triple-digit, and the most common source of catastrophic surprise duty bills. If your category has any history of AD/CVD orders against China (steel, aluminium extrusions, furniture, tires, solar, quartz surfaces, hardwood plywood, and dozens more), get a written scope determination before committing to volume. A supplier's assurance that the product is "outside the scope" has no legal weight.

6. De Minimis No Longer Rescues Small Shipments

For years importers used the $800 de minimis threshold under 19 U.S.C. 1321 to bring small parcels in duty-free — the model underpinning much direct-from-China e-commerce. That is over. Following Executive Order 14324, "Suspending Duty-Free De Minimis Treatment for All Countries," effective August 29, 2025, duty-free de minimis treatment is indefinitely suspended for imports valued at $800 or less, from all countries and across all modes of entry including international mail. Those goods are now subject to all applicable duties, taxes, and fees; CBP's e-commerce FAQ covers the operational detail. Samples, replacement parts, and small trial orders now carry duty. Budget for it.

7. Product Compliance: The Agency Layer

CBP enforces at the border on behalf of roughly four dozen partner government agencies. Clearing customs is not the same as being legally sellable. The four that catch most consumer-goods importers:

FDA — food, beverages, supplements, cosmetics, medical devices, lasers, food-contact materials. Requirements can include facility registration, prior notice of food shipments, device listing and possibly 510(k) clearance, and labeling compliance. FDA can place products or manufacturers on import alert, meaning detention without physical examination — check whether your manufacturer appears on one before you order.

FCC — anything that radiates radio frequency energy, intentionally or not. Bluetooth speakers, LED drivers, chargers, IoT devices, and most modern electronics require FCC equipment authorization (certification or Supplier's Declaration of Conformity) and correct labeling. A supplier's "FCC certificate" is frequently a test report for a different model, an expired grant, or a grant held by an unrelated company. Verify the FCC ID in the FCC's public grant database yourself.

CPSC — children's products, toys, cribs, mattresses, apparel flammability, and much of general consumer goods. Children's products require third-party testing at a CPSC-accepted lab, a Children's Product Certificate, and tracking labels; lead and phthalate limits are strictly enforced.

EPA and USDA — pesticides and devices making pesticidal claims (including many "antibacterial" products), engines, refrigerants, wood packaging, plant material, animal products.

Additionally, UFLPA (Uyghur Forced Labor Prevention Act) creates a rebuttable presumption that goods made wholly or in part in Xinjiang, or by listed entities, are made with forced labor and barred from entry. Rebutting it requires documented supply-chain tracing back to raw material — a burden that has stranded shipments in cotton, tomato, polysilicon, and aluminium. Tier-2 and tier-3 mapping is now a requirement, not a best practice; our Chinese company due diligence guide covers building the entity-level map tracing depends on.

8. Country of Origin Marking and Labeling

This requirement is old, simple, and violated constantly. Under Section 304 of the Tariff Act of 1930 (19 U.S.C. 1304), as summarized in CBP's informed compliance publication on marking, every article of foreign origin imported into the US must be marked in a conspicuous place, as legibly, indelibly, and permanently as the nature of the article permits, with the English name of the country of origin, in a manner that indicates origin to the ultimate purchaser.

Three points importers miss. The marking must give the English country name — "Made in China," not a Chinese-character mark, a city, or a supplier logo. Origin determination sits in 19 CFR Part 102 and marking requirements and exceptions in 19 CFR Part 134, and the exceptions are narrower than importers assume. Unmarked goods can be detained, and CBP can assess additional marking duties or require marking under supervision at your expense.

Ask for a photograph of the actual marking on a production unit and on retail packaging before shipment; "we will add it" is where this fails. Then check product-specific labelling: FTC textile and care labelling, energy labels, warning statements, net-quantity declarations, and California Prop 65 if you sell into that state.

9. Recordkeeping

As IOR you must retain entry records for five years from the date of entry — invoices, packing lists, bills of lading, entry summaries, payment records, classification support, agency certifications. CBP can issue a request for information (Form 28) or notice of action (Form 29) years later, and "our supplier has the documents" is not a response. This is also why you should keep a dated verification record of your supplier's legal status at the time of each order.

Requirements to Import From China Into the EU

If your destination is the European Union, the structure is similar but the vocabulary and the burden distribution differ.

EORI number. An Economic Operators Registration and Identification number is mandatory for all customs operations in the EU customs territory — import, export, and transit. Per the European Commission's EORI page, it is unique to your business and does not expire, and you obtain it from the member state where you are established.

Duty and VAT. Duty is assessed under the EU Combined Nomenclature, and import VAT is charged at the destination member state's rate. VAT is a large component of landed cost and generally recoverable if you are VAT-registered — treat it as cash flow, not cost.

CE marking and importer obligations. This is the biggest structural difference from the US: EU product legislation puts on the importer obligations that in the US often sit with the manufacturer. The Commission's guidance for importers and distributors is explicit — importers must check that products fulfil all EU safety, health, and environmental requirements before placing them on the market; must verify the non-EU manufacturer has taken the necessary steps; must ensure the EU Declaration of Conformity and technical documentation are available on request; and must be able to contact the manufacturer at any time. If you place a product on the market under your own name or trade mark, you are legally treated as the manufacturer and assume its full obligations, including holding the technical file. Certain categories also require a responsible economic operator established in the EU.

So a Chinese supplier's "CE certificate" is often a self-declared document from a commercial test house with no notified-body status, in a category where a notified body is required. Ask for the Declaration of Conformity, the harmonised standards it cites, and the test reports — and check any notified body number against the Commission's NANDO database.

Documents Needed to Import From China

Here is the working document set for a typical containerised US import. Your broker will tell you which apply to your entry.

Commercial documents (from your supplier)

• Commercial invoice — full goods description, quantity, unit and total value, currency, Incoterm, country of origin, and buyer and seller names and addresses. This is what CBP relies on for value; vague descriptions like "gift items" invite scrutiny.
• Packing list — carton count, dimensions, gross and net weight, marks and numbers.
• Sales contract or PO — the enforceable agreement. Must name the exact legal entity, not a brand.

Transport documents

• Bill of lading (ocean) or air waybill (air), plus the carrier's arrival notice. Original BLs are documents of title; telex release and surrender change who controls the cargo.
• Importer Security Filing (ISF, "10+2") — for ocean cargo, ten data elements filed with CBP at least 24 hours before lading at the foreign port. Late or inaccurate filings carry liquidated damages. This is your obligation even when your broker transmits it: you must supply the data, including manufacturer and ship-to details.

Customs documents

• Entry summary (CBP Form 7501) — filed by your broker; your permanent record of what was declared, alongside the customs bond (Form 301) and your broker power of attorney.
• Certificate of origin — for China-origin goods entering the US there is no preference program to claim, but origin still governs Section 301 and AD/CVD scope, and banks often require it.

Product and payment documents

• Agency certifications as applicable: FCC grant or SDoC, CPSC Children's Product Certificate and test reports, FDA registration and prior notice confirmations, EPA establishment numbers.
• Safety data sheet for chemicals, batteries, and aerosols; lithium batteries have their own declaration and packing rules. Fumigation certificate or ISPM 15 stamp on wood pallets and crating — non-compliant wood packaging is a leading cause of cargo being refused or re-exported. Inspection certificate from your third-party QC provider, if you use one; you should — see China factory audit.
• Wire confirmations, letter of credit documents, or Trade Assurance records substantiate value. If you pay by bank transfer, read our guide to T/T payment risk with Chinese suppliers: payment to an account name that does not match the invoiced entity is both a fraud signal and a customs-valuation documentation problem.

Side B: What China Requires of Your Supplier

Now the side almost nobody checks. In order for your goods to legally leave China, the exporting entity must clear several hurdles. If your supplier cannot, someone else exports on their behalf — and that changes your legal counterparty, your paper trail, and your recourse.

Foreign Trade Operator Record Filing

Under China's Foreign Trade Law, an enterprise that wants to engage in import or export must complete foreign trade operator record filing (对外贸易经营者备案登记) with the commerce authorities. It is a registration, not a discretionary licence — but it is a real gate, and a large number of Chinese manufacturers, especially smaller domestic-market factories, have never completed it.

Customs Consignor/Consignee Registration

Separately, the enterprise must register with China Customs as a consignor or consignee of imported or exported goods. China Customs' registration guidance describes the process: applicants submitting complete, conforming materials are issued a Customs Declaration Registration Certificate for Consignees or Consignors of Imported or Exported Goods, valid for three years, by which they may handle customs declaration business. Required materials include the foreign trade dealer record-filing form, articles of association, and tax registration documentation; foreign-invested enterprises also submit their establishment approval certificate.

Two implications. First, the certificate expires — a supplier who exported fine two years ago may have lapsed, so this is a live status rather than a permanent attribute. Second, customs brokers are separately registered under their own regime, which means the company filing your export declaration is often neither your supplier nor your freight forwarder.

Export Customs Declaration

Every export requires a customs declaration filed to GACC standards — China Customs publishes the standards for completion of customs declaration forms — naming the consignor, goods, HS code, quantity, value, and destination.

Ask for a copy of the export declaration for your shipment. This is the highest-signal document in China import compliance and almost no buyer requests it. It tells you three things you cannot learn any other way: which legal entity actually exported (compare to your invoice), what value was declared (compare to what you paid), and what HS code was used (compare to your US classification). Persistent refusal to provide it is meaningful.

Commodity Inspection and Product-Specific Export Controls

Certain exports are subject to statutory inspection by customs (the former CIQ function, now consolidated into GACC) — particularly food, agricultural products, and goods on the inspection catalogue. Where inspection applies the goods cannot be exported without it, and the certificate becomes part of your import documentation for FDA or USDA purposes at destination. A smaller set of goods requires an export licence or falls under dual-use and export-control regimes, including an expanding list of critical minerals, rare earths, and graphite. In those categories licence availability is a supply-continuity risk, not a paperwork item, and it belongs in your contract as a condition precedent.

Export VAT Rebates and the Entity Question

Chinese exporters recover input VAT through the export tax rebate system, which requires a matching document set: VAT special invoices from their own suppliers, the export declaration, and foreign exchange receipt records. That is why suppliers care intensely about invoice and declaration wording — and why some ask you to accept an invoice from a different entity or pay a Hong Kong account. Such requests usually have a tax-structuring explanation rather than a fraudulent one, but they always mean your commercial counterparty and your paying counterparty have diverged, which is exactly the condition under which disputes become unenforceable.

Relatedly, if your supplier is a manufacturer without export rights, your order gets exported through an agent or trading company. That is normal and often fine; what is not fine is not knowing. The entity on your export declaration and commercial invoice is the one you have a documented relationship with, and if the goods are defective, that is the entity your claim runs against — not the factory you visited. Our guide to trading company vs manufacturer covers how to tell them apart from registry data, starting with the business scope field.

Import Regulations China: Shipping Goods Into China

"Import regulations China" is also searched by companies selling into China. The mirror-image requirements:

• Your Chinese buyer, or your own Chinese entity, must be a registered consignee with China Customs, holding the same registration described above. If your customer is not registered, they will use an import agent — and you should know who.
• Documentation. As trade.gov's China import requirements guide notes, the Chinese importer generally handles document collection; requirements vary by product but typically include bill of lading, invoice, shipping list, customs declaration, insurance policy, and sales contract, plus product-specific items such as import quota certificates, licences, and inspection certificates. For food and agricultural products, trade.gov states that GACC requires the exporting facility or establishment to register with GACC prior to shipping, with different pathways by product type.
• Chinese labelling and CCC marking. Retail products require compliant Simplified Chinese labelling, and China Compulsory Certification applies to a catalogue of products including many electrical goods, requiring factory inspection and testing by a Chinese-designated body.

China's regime loads the burden onto the in-country importer and onto facility-level registration; the US and EU load it onto the importer of record's own diligence. Either way it lands on a party who needs to be verified.

How to Verify Your Supplier's Export Rights

This is where compliance meets counterparty risk, and it is the part of the checklist you can complete before wiring money. The Chinese corporate registry publishes, for every mainland company, the fields that answer five questions.

1. Does the legal entity exist, exactly as named on the invoice? The registered Chinese name is the only legally binding name; English names are optional, informal, and frequently invented for marketing. If the Chinese name on the business licence does not match the invoice and the contract, you do not yet know who your counterparty is. Our guide to verifying a Chinese company walks through the matching process.

2. Is it active? Operating status separates an active company from one whose licence has been revoked, one formally cancelled, and one flagged in the abnormal operations directory. A cancelled entity cannot legally issue tax-compliant invoices or enter contracts, which means it cannot legally export to you either.

3. Does the business scope include import/export? The approved business scope is the registry's statement of what the company is licensed to do — import/export activity, and manufacturing versus wholesale trading, both appear here. A scope that omits import/export strongly suggests this is not the entity that will actually export your goods, and that you should ask who will.

4. Who controls it, and is there a record of trouble? Legal representative, shareholders, registered versus paid-in capital, administrative penalties, court records, blacklist listings. Recent legal representative changes, capital reductions, and penalty history are the signals that most often precede a dispute; our Chinese company due diligence guide covers how to weight them.

5. Does the trade evidence corroborate the story? Registry data tells you what a company is licensed to do; trade data tells you what it has shipped. Cross-referencing US import records for Chinese suppliers and China customs data against a supplier's claims is the cheapest reality check available — a "10-year exporter to the US" with no bill-of-lading history is telling you something.

What ChineseCheck does and does not do. We retrieve and translate the official Chinese registration record and public compliance records into an English report you can file with your entry documents, your bank, or your insurer — covering questions 1 through 4: identity, status, scope, ownership, and public risk records. We do not classify goods, calculate duties, act as your customs broker, file entries, or certify product compliance; those require a licensed broker and accredited test labs. Pair us with a broker for the customs layer, a test lab for the product layer, and a pre-shipment inspection for the goods. For the fraud patterns that survive a clean registry check, see avoiding scams when importing from China; if you are transacting on Alibaba, our Trade Assurance guide explains what that protection does and does not cover.

The Pre-Order Compliance Checklist

Run this before you send a deposit, not after the container sails.

Destination-side (your obligations)

1. Confirm which legal entity will be importer of record, with an importer number on file with CBP.
2. Get a customs bond sized to projected annual duty — continuous if you import more than a few times a year.
3. Appoint a licensed customs broker and execute a power of attorney.
4. Classify the product and keep a written classification position; request a binding ruling if the duty consequence is material.
5. Check Section 301 applicability and current rate, plus any AD/CVD orders in the category — get a scope opinion in writing if there is doubt.
6. Obtain the actual partner-agency certifications (FDA, FCC, CPSC, EPA, USDA), verified at source rather than as supplier-supplied images.
7. Specify origin marking and product labelling in the purchase order, and require pre-shipment photographs of a production unit and retail packaging.
8. Map the supply chain deep enough to answer a UFLPA inquiry, and set up five-year recordkeeping.

China-side (your supplier's obligations, your risk)

1. Verify the exact registered legal name and Unified Social Credit Code against the official registry.
2. Confirm operating status is active with no abnormal-operations or blacklist listings.
3. Confirm the business scope covers import/export and the activity you are buying (manufacturing vs trading).
4. Ask who will file the export declaration, and request a copy after shipment.
5. Confirm the contracting entity, the invoicing entity, and the bank account name are the same. If not, get the reason in writing before you pay.
6. Where statutory inspection or an export licence applies, make its issuance a condition precedent in the contract.

FAQ

Do I need a license to import from China to the US?

There is no general import license in the United States. What you need is to be a valid importer of record with an importer number on file with CBP, and a customs bond for formal entries. Beyond that, licensing is product-specific: FDA registration for certain foods and devices, EPA establishment numbers for pesticides, ATF licensing for firearms and ammunition, TTB permits for alcohol, and so on. The absence of a general license is why importers wrongly conclude there are no requirements — the requirements attach to your product, not to the act of importing.

What documents do I need to import from China?

At minimum: commercial invoice, packing list, and bill of lading or air waybill from the supplier; Importer Security Filing data for ocean cargo, filed at least 24 hours before lading; entry summary and customs bond on the US side; plus any partner-agency certifications your product requires. Add a safety data sheet for chemicals and batteries, ISPM 15-compliant wood packaging, and an inspection certificate if you use third-party QC. See the full document list above.

Who is responsible for customs clearance under FOB, CIF, and DDP terms?

Under FOB and CIF, you are the importer and responsible for entry, duty, and compliance — the Incoterm allocates freight and risk, not regulatory liability. Under DDP the supplier arranges clearance, but this does not remove your exposure as owner or purchaser of the goods, and it frequently leaves you named as importer of record on entries you never reviewed. If you accept DDP, require copies of every entry summary. Incoterms are commercial terms; they do not rewrite customs law.

How do I know if my Chinese supplier is allowed to export?

Two checks. First, pull the official registration record and read the business scope — import/export activity appears there, and the registry also tells you whether the entity is active. Second, ask directly who will file the export customs declaration, and request a copy of the declaration after the shipment leaves. If the exporting entity differs from your invoicing entity, that is not automatically a problem, but you need to know it and document why. Chinese exporters also require foreign trade operator record filing and a customs consignor registration, the latter valid for three years and renewable.

What are the current tariffs on Chinese goods?

There is no single rate. Your duty is the HTS general rate for your ten-digit classification, plus any applicable Section 301 additional duty, plus any antidumping or countervailing duty order that covers your product, plus any other trade action in force. Section 301 rates vary from 0% to 100% by category — as of August 2026, USTR's published four-year-review levels include 100% on electric vehicles, 50% on solar cells, and 25% on tungsten, with certain exclusions extended through November 10, 2026. These change often. Confirm current rates against the HTS and CBP guidance with your broker before pricing anything.

Is the $800 de minimis exemption still available for shipments from China?

No. Duty-free de minimis treatment for imports valued at $800 or less was indefinitely suspended for all countries effective August 29, 2025, across all modes of entry including international mail. Low-value shipments are now subject to all applicable duties, taxes, and fees. If your model depended on duty-free parcels, it needs re-costing.

Do I need FDA or FCC approval before my goods ship, or can I fix it at the port?

Before they ship. Agency requirements are entry conditions, and a shipment that arrives without required certification can be detained, refused, or ordered re-exported or destroyed at your expense. FDA can also apply detention without physical examination to products or manufacturers on import alert, which means the burden of proof is on you before release. Verify certifications at the source — the FCC grant database for FCC IDs, an accredited lab report for CPSC testing — rather than accepting supplier-provided certificate images.

Do these requirements change if I import into the EU instead of the US?

Yes, materially. You need an EORI number rather than a CBP importer number, duty is assessed under the EU Combined Nomenclature, and import VAT applies. The bigger difference is product conformity: EU law places explicit verification obligations on the importer for CE-marked goods, and if you sell under your own brand you are legally treated as the manufacturer, assuming the full technical-file burden. Certain categories also require a responsible person established in the EU.

Bottom Line

China import requirements are not one list. They are two lists that meet at a vessel, and the failures cluster in the space between them.

Your destination country's list is enforceable against you: importer of record status, a bond, correct classification, the right trade-remedy treatment, the right agency certifications, correct origin marking, five years of records. None of it is your supplier's job, and no Incoterm changes that. China's list is enforceable against your supplier, but the consequences land on you — if they are not registered to export, someone else exports for them, and your contract, your invoice, and your recourse all quietly point at a party you never vetted.

The first list needs a customs broker and a test lab. The second needs fifteen minutes with the official registration record before you pay a deposit. Both are cheap relative to a detained container or an unenforceable claim, and only one of them is regularly skipped.

For the full sourcing process this compliance layer sits inside, start with our complete guide to importing from China. For the verification workflow, see how to verify a Chinese supplier.

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About the Author

Written by the ChineseCheck Research Team — specialists in Chinese business verification with access to 24+ official government databases.

Last reviewed: August 2026. Tariff rates, exclusion windows, de minimis treatment, and agency requirements referenced in this guide change frequently; every figure is dated and linked to its official source. Verify current requirements with CBP, USTR, and a licensed customs broker before making commercial decisions.