A Guide to Common Causes and Remedial Measures for Customs Clearance Failures for Sensitive Goods

A Guide to Common Causes and Remedial Measures for Customs Clearance Failures of Sensitive Goods
In international trade, sensitive goods (such as dangerous goods, lithium batteries, pharmaceuticals, and high-value electronic products) face a higher risk of customs clearance failure due to strict regulations. This guide analyzes common causes of customs clearance failures and provides quick remedial solutions to help businesses minimize losses and improve customs clearance efficiency.

I. Six Common Reasons for Customs Clearance Failure of Sensitive Goods
Reasons for Failure Specific Issues Examples of High-Risk Goods

1. Incomplete or Incorrect Documentation – Missing MSDS, UN38.3 (lithium batteries)

• Inconsistent Invoice/Packing List Information
• Missing Authorization Documents (e.g., Brand Authorization Letter) Lithium Batteries, Chemicals, Branded Goods

1. Unsatisfactory Packaging/Labeling – Failure to Use UN-Certified Packaging (Hazardous Goods)

• Missing GHS Label or UN Number
• Lithium Batteries Not Labeled with “Cargo Aircraft Only” Labels Hazardous Chemicals, Lithium Batteries, Biological Products

1. Dishonest Declarations (Understatement/Misdeclaration) – Understatement of Goods Value (Suspected Tax Evasion by Customs)

• Incorrect HS Code (e.g., lithium batteries mistakenly declared as ordinary electronic products) High-value electronic products, controlled materials

1. Restrictions or Bans in the Importing Country – Goods are Prohibited (e.g., drones exported to the Middle East)

• Missing Import Permits (e.g., Pharmaceuticals, Medical Devices) Military Supplies, Pharmaceuticals, Goods from Sanctioned Countries

1. Prohibited Ingredients Found During Inspection – Contains banned chemicals (e.g., some countries prohibit asbestos-containing products).

• Undeclared built-in lithium batteries (e.g., electronic products with batteries). Chemical products, battery-containing equipment.

1. Logistics provider qualification issues. – Carrier lacks hazardous goods transportation qualifications (e.g., ordinary express delivery of lithium batteries).

• Lack of IATA/IMDG certification. Hazardous goods, cold chain cargo.
  II. Four remedial measures for customs clearance failures.

1. Documentation issues → Submit or correct documents.
   Steps:

Immediately contact the customs broker or customs office to confirm missing documents (e.g., UN 38.3, MSDS).

Resubmit the correct commercial invoice and packing list (ensure the value, product name, and HS code are consistent).

Applicable scenarios:

Missing test reports for lithium batteries, or lack of MSDS for chemicals.

2. Packaging/labeling issues → Replace or re-label.
   Steps:

If the packaging is unqualified (e.g., non-UN box), replace it with compliant packaging at the customs-supervised warehouse.

Re-submit missing labels (e.g., UN number, GHS pictogram).

Applicable Scenarios:

Hazardous goods packaging lacks UN markings, lithium batteries lack shipping labels.

3. Declaration Discrepancies → Modify Declaration or Pay Fines
   Steps:

Proactively apply to modify the HS code or value (repay the difference in customs duties).

If deemed “intentional under-declaration,” you may be subject to a fine (e.g., US Customs fines up to 10 times the value of the goods).

Applicable Scenarios:

Under-declaration of high-value goods, incorrect HS code leading to tax rate discrepancies.

4. Import Restrictions → Apply for a Permit or Return/Destroy
   Steps:

Emergency application for an import permit (e.g., FDA approval for pharmaceuticals).

If customs clearance is unsuccessful, choose to return the goods (return shipping fee required) or destroy them on-site (customs approval required).

Applicable Scenarios:

Pharmaceuticals lacking import permits, drones exported to regulated countries.

III. Special Procedures for Different Countries
Country
Common Customs Clearance Obstacles
Remedial Recommendations
US
Lack of FDA/FCC Certification, ITAR Regulation: Submit FDA Pre-Declaration, Apply for DSP-83 (Military Products)
EU
REACH/CE Certification Non-Compliances, Missing CLP Label: Perform CE Testing, Update GHS Label
China
Lack of “Export Dangerous Goods Packaging Use Permit”: Contact a third-party testing agency (such as CCIC) to obtain a replacement
Middle East
Religiously/Culturally Sensitive Items (such as alcohol, drones): Apply for import permits in advance or change the destination
IV. How to Avoid Customs Clearance Failures?
✅ Prepare Documents in Advance: Ensure all documents, including MSDS, UN 38.3, and Brand Authorization Letter, are complete.
✅ Compliant Packaging and Labeling: Follow UN/IATA/IMDG standards to avoid last-minute adjustments.
✅ Accurate Declaration:

Reasonable value (comparable to peer quotes).

Accurate HS Code (refer to the Harmonized System or consult a customs broker). ✅ Choose a professional logistics provider:

For dangerous goods transport, choose an IATA/IMDG-certified company (such as DHL Hazardous Goods Service).

For high-value cargo, purchase transportation insurance.

V. Typical Cases and Solutions
Case 1: Lithium batteries detained by US Customs
Reason: Lack of UN3480 label and UN38.3 report.

Solution: Applied label at the customs warehouse, submitted test report by email, and released within 3 days.

Case 2: Chemical products returned to the EU due to CLP label failure
Reason: GHS pictogram size did not meet EU standards.

Solution: Re-labeled and re-declared, paying a storage fee of €500.

Case 3: Pharmaceutical exports to India rejected
Reason: Lack of import license from the Drug Controller General of India (CDSCO).

Solution: Urgently applied through a local agent, resulting in a 2-week customs clearance delay.

VI. Summary
Problem Type Quick Fix Long-Term Preventive Measures
Missing Documents: Submit electronic copies/originals
Create an Export Document Checklist
Unqualified Packaging: Replace or re-label the customs warehouse
Purchase UN-certified packaging and pre-label
Declaration Errors: Modify declarations and pay taxes
Train customs clearance teams and use HS code lookup tools
Import Restrictions: Apply for a license or return shipment
Investigate destination country regulations (e.g., FDA/REACH) before exporting
Tip: If your shipment has been detained, contact customs or a professional customs clearance agent immediately to avoid incurring high storage fees!