Compliance Strategy for Exporting Sensitive Goods to Europe

1. Definition and classification of sensitive goods

Common types of sensitive goods

Dangerous goods: lithium batteries, chemicals, flammable liquids (UN numbered goods)

Restricted goods: medical devices (CE certification required), food/cosmetics (EC No. 1223/2009 certification required), magnetic electronic products (such as speakers)

Intellectual property related: branded goods (authorization required), generic drugs

Others: animal and plant products (CITES certificate required), drones, protective equipment (such as bulletproof vests)

EU regulations

CLP Regulation (EC No. 1272/2008): Classification, labeling and packaging of chemicals

ADR/RID: Rules for dangerous goods transported by land

IMDG/ICAO-IATA: Rules for dangerous goods transported by sea/air

REACH Regulation: Registration and restriction of chemicals

2. Necessary steps before export
3. Accurate classification and certification

MSDS report (necessary for chemicals/batteries): issued by a professional organization, clearly stating the composition and transportation requirements.

UN38.3 test (lithium battery): required for air transport, and a test summary is required.

CE mark: medical devices, electronic appliances, etc. must comply with EU directives (such as EMC, LVD).

2. Packaging compliance

Dangerous goods: UN specification packaging (such as UN4G/X1.4), with nine types of hazardous labels.

Lithium batteries: single box net weight ≤ 30kg (IATA regulations), lined with anti-short circuit materials.

Document marking: The outer box is marked with “Lithium Ion Batteries in Compliance with PI 965”.

3. Document preparation list

Commercial invoice (specify HS code)

Packing list (gross weight/net weight, packaging material)

Transport declaration (DGD for dangerous goods)

Certificate of origin (Form A enjoys tariff concessions)

Special license (such as drugs need EMA approval)

III. Logistics solution selection

1. Channel comparison

Transport mode Applicable goods Advantages Risks Air transport High value, urgent goods Fast timeliness (3-5 days) High inspection rate, expensive Ocean transport Large quantity, low timeliness Low cost (LCL/FCL) Need to declare in advance IMDG China-Europe train Balanced type Faster than sea transport, cheaper than air transport Railway embargo list needs to be checked

2. Key points

Consequences of concealment: fine up to 50,000 euros, inclusion in the customs blacklist.

Pre-declaration: Submit ENS (Entry Summary Declaration) 48 hours in advance.

Agent selection: Confirm that the freight forwarder has DG Cargo qualification (dangerous goods transportation license).

4. Customs clearance avoidance guide

HS code precision

Lithium battery: 85076000 (Wh capacity must be indicated)

Chemicals: check CAS number to avoid misclassification into “other” category.

Pre-clearance strategy

Use DDP terms (delivery duty paid), and let the freight forwarder handle EU VAT (tax rate 19%-27%).

Apply for EORI number (EU Economic Operator Registration Identification) in advance.

Inspection response

Prepare electronic version of test report (such as RoHS, LFGB) and respond quickly to customs requirements.

Sensitive goods are recommended to go through Rotterdam, Netherlands or Liege, Belgium, where customs clearance efficiency is higher.

5. Risk control and emergency plan

Insurance must be purchased

Insure All Risks, with additional war insurance and strike insurance (especially sea transportation).

Lithium battery value is increased by 20% (e.g., value of goods is 100,000, insured 100,000, insured 120,000).

Return plan

Specify in the contract the clause “When the goods are detained by the customs, the buyer shall assist in providing the import license”.

Cooperate with overseas warehouses in advance and prepare transit inventory to deal with unexpected inspections.

VI. Practical skills

Low-sensitivity goods: mixed general goods export (such as battery products, the battery ratio is less than 30%).

Labeling skills: Avoid directly labeling “dangerous goods” on the outer box, and use neutral descriptions such as “Engine Parts” instead (compliance required).

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