In cross-border trade, electronic products, cosmetics, and battery-related products are classified as core categories of “sensitive goods” due to their involvement in multiple regulatory dimensions including safety, environmental protection, and health. The cross-border transportation of such goods not only faces the timeliness and cost pressures of conventional logistics but also needs to comply with differentiated import restriction policies of various countries—from certification qualifications and ingredient standards to packaging and labeling, any oversight in a single link may result in cargo detention, fines, or even permanent confiscation.
According to data from the World Customs Organization (WCO), the customs clearance failure rate for cross-border transportation of sensitive goods is as high as 12%, far exceeding the 3% rate for ordinary goods; among them, the three main causes are lack of certification, excessive ingredients, and non-compliant packaging. This article will systematically sort out the import restriction rules for electronic products, cosmetics, and batteries in major global trading countries, dissect the compliance key points and channel selection strategies in the transportation link, and provide actionable practical guidance for cross-border sellers and foreign trade enterprises.
I. Core Sensitive Goods Categories and Global Common Regulatory Requirements
(1) Definition and Risk Points of Three Core Sensitive Goods Categories
- Electronic Products: Covering mobile phones, computers, smart wearable devices, electronic components, etc. Core risk points include electromagnetic compatibility (EMC), radio frequency occupation, and lack of safety certification;
- Cosmetics: Including skin care, color cosmetics, and personal care products. Core risk points lie in excessive ingredients (such as heavy metals, hormones), non-standard labeling, and failure to complete filing/registration;
- Batteries and Battery-Powered Products: Including lithium batteries (lithium metal batteries, lithium-ion batteries), button batteries, etc. Core risk points are transportation safety (short circuit, fire), lack of UN38.3 certification, and packaging not meeting IMDG Code requirements.
(2) Global Common Regulatory Requirements
- Certification System: Most countries require sensitive goods to provide third-party testing and certification (such as CE and FCC certifications for electronic products, FDA and CPNP certifications for cosmetics);
- Document Completeness: Commercial invoices, packing lists, product manuals, certification certificates, and certificates of origin are required; some products need additional documents such as ingredient lists and Safety Data Sheets (SDS);
- Packaging Specifications: Battery products need short-circuit and leakage-proof packaging; cosmetics need to be labeled with Chinese/English ingredient lists and shelf life; electronic products need to be marked with voltage, frequency, and other parameters;
- Declaration Authenticity: False declarations are prohibited (such as falsely declaring “lithium batteries” as “ordinary electronic accessories”); the cargo value, product name, and quantity must be consistent with the actual goods.
II. Detailed Explanation of Import Restriction Policies in Major Countries (by Product Category)
(1) Electronic Products: Certification and Spectrum Compliance are Core
- European Union (EU)
- Core Restrictions: Must obtain CE certification (covering EMC, LVD, and RoHS directives); wireless products need additional RED certification;
- Special Requirements:
- The RoHS directive restricts the use of 6 hazardous substances including lead and mercury; electronic products must provide a Declaration of Conformity (DoC);
- The EU Customs Code implemented in 2021 requires advance import declaration, providing product serial numbers and certification numbers;
- Prohibited Scenarios: Equipment without CE certification, excessive radioactivity, or frequency not meeting EU spectrum standards.
- United States (US)
- Core Restrictions: FCC (Federal Communications Commission) certification is mandatory; electronic devices must comply with FCC Part 15 standards;
- Special Requirements:
- Medical electronic products (such as electronic blood pressure monitors) need additional FDA certification;
- Importers must register with CBP (Customs and Border Protection) and submit Importer Security Filing (ISF);
- Prohibited Scenarios: Wireless devices without FCC certification, electronic products that interfere with public communications.
- Japan
- Core Restrictions: Must obtain PSE certification (divided into S-mark for specified electrical products and N-mark for non-specified electrical products);
- Special Requirements:
- Voltage must be compatible with Japan’s 100V standard; product manuals must include Japanese safety warnings;
- Wireless products need to obtain MIC (Ministry of Internal Affairs and Communications) certification, complying with Japan’s Radio Act;
- Prohibited Scenarios: Products without PSE certification, substandard insulation performance, or electromagnetic interference.
- India
- Core Restrictions: Must obtain BIS (Bureau of Indian Standards) certification; some products need ISI mark certification;
- Special Requirements:
- Importers must register with Indian Customs, providing product test reports and BIS certification certificates;
- Electronic products must be marked with “Indian Standard” and certification numbers;
- Prohibited Scenarios: Products without BIS certification or not meeting India’s voltage (230V) standard.
(2) Cosmetics: Ingredients and Filing are Key
- European Union (EU)
- Core Restrictions: Must complete filing on CPNP (Cosmetic Products Notification Portal), complying with Regulation (EC) No 1223/2009;
- Special Requirements:
- Ingredients must conform to the EU Cosmetic Ingredients Database (CosIng); 26 substances including glucocorticoids and hydroquinone are prohibited;
- Labels must include ingredient lists (INCI names), production batch numbers, shelf life, and responsible person information;
- Sunscreen and whitening products must be declared as “special cosmetics” and provide additional safety assessment reports (SCCNFP);
- Prohibited Scenarios: Excessive ingredients, unfiled products, or false labeling.
- United States (US)
- Core Restrictions: Regulated by FDA (Food and Drug Administration), complying with the Federal Food, Drug, and Cosmetic Act (FD&C Act);
- Special Requirements:
- Ingredients must be included in the FDA’s list of permitted cosmetic ingredients; substances such as chlorofluorocarbons and asbestos are prohibited;
- Submit an application for the Voluntary Cosmetic Registration Program (VCRP) before import; some products (such as sunscreens with SPF values) need FDA approval;
- Labels must include net weight, ingredient lists, and the name and address of the importer/distributor;
- Prohibited Scenarios: Harmful ingredients, non-standard labels, or misleading advertising.
- China
- Core Restrictions: Ordinary cosmetics need to complete filing; special cosmetics (hair dyeing, perming, freckle removal and whitening, etc.) need to obtain registration certificates;
- Special Requirements:
- Ingredients must comply with the Safety and Technical Standards for Cosmetics; 42 glucocorticoids and 35 antibiotics are prohibited;
- Imported cosmetics must be labeled with Chinese labels, including ingredient lists, production batch numbers, shelf life, and filing/registration numbers;
- Certificate of origin, test report, and safety assessment report are required;
- Prohibited Scenarios: Unfiled/unregistered products, excessive ingredients, or non-compliant Chinese labels.
- Southeast Asia (Indonesia, Malaysia, Thailand)
- Indonesia: Must obtain BPOM (National Agency of Drug and Food Control) certification; ingredients must comply with Indonesian National Standards (SNI); harmful substances such as mercury and arsenic are prohibited;
- Malaysia: Must register with NPRA (National Pharmaceutical Regulatory Agency); labels must include Malay/English ingredient lists; whitening products need to provide whitening ingredient test reports;
- Thailand: Must obtain FDA certification; hydroquinone and glucocorticoids are prohibited; labels must be marked with “Thai FDA Certification Number” and shelf life.
(3) Batteries and Battery-Powered Products: Transportation Safety and Certification Go Hand in Hand
- Common Requirements of the United Nations (UN) and International Air Transport Association (IATA)
- All lithium batteries must pass UN38.3 test certification and provide test reports;
- Lithium metal batteries: Maximum 1g of lithium per cell; lithium-ion batteries: Rated energy ≤100Wh (approval from the airline is required for exceeding this limit);
- Packaging must adopt short-circuit prevention design (such as individual packaging, insulation treatment), marked with “lithium battery” warning signs and UN numbers (such as UN3090, UN3091);
- Safety Data Sheet (SDS) for lithium battery transportation is required.
- European Union (EU)
- Core Restrictions: Batteries must comply with REACH Regulation and Battery Directive (2006/66/EC); mercury content ≥0.0005% and cadmium content ≥0.002% are prohibited;
- Special Requirements:
- Must be marked with battery capacity and recycling logo, providing a recycling commitment letter;
- Battery-containing products need additional CE certification (EMC + LVD directives);
- Prohibited Scenarios: Lack of UN38.3 certification, excessive harmful substances, or non-compliant packaging.
- United States (US)
- Core Restrictions: Regulated by DOT (Department of Transportation), complying with 49 CFR regulations; lithium batteries must pass UN38.3 certification;
- Special Requirements:
- Imported batteries need to submit a “Battery Import Notification”, providing test reports and safety declarations;
- Air transportation must comply with IATA DGR requirements, marked with “Cargo Aircraft Only” or “Passenger/Cargo Aircraft” signs;
- Prohibited Scenarios: Failure to pass UN38.3 tests, non-compliant packaging with safety standards, or false declaration of battery type.
- Japan
- Core Restrictions: Batteries must comply with JIS standards, pass UN38.3 certification, and provide test reports;
- Special Requirements:
- Battery-containing products need to obtain PSE certification, marked with “PSE Certification Mark”;
- Packaging must be marked with battery type, rated energy, and UN number; bulk transportation is prohibited;
- Prohibited Scenarios: Lack of UN38.3 certification, non-compliance with JIS standards, or packaging without warning signs.
- Australia
- Core Restrictions: Batteries must obtain ACMA (Australian Communications and Media Authority) certification, complying with AS/NZS standards;
- Special Requirements:
- Register with ACMA before import, providing UN38.3 test reports and safety declarations;
- Battery-containing electronic products need additional EMC certification;
- Prohibited Scenarios: Lack of ACMA certification or excessive battery energy (lithium-ion batteries >100Wh).
III. Compliance Operation Guide for Sensitive Goods Transportation
(1) Before Transportation: Three Core Preparation Tasks
- Complete Qualification Certification
- Inquire about the certification requirements of the destination country in advance; entrust third-party institutions to handle required certifications (such as CE, FCC, FDA, UN38.3, etc.) to ensure the certification certificates are within the validity period;
- Cosmetics need to complete filing/registration in advance (such as EU CPNP, China filing certificate) to avoid detention caused by “transportation before filing”;
- Keep original and electronic versions of certification certificates and test reports, which need to be provided at any time during customs clearance.
- Complete Documentation
- Basic Documents: Commercial invoice (truthfully mark product name, specification, quantity, unit price, cargo value, and indicate “sensitive goods type” such as “containing lithium batteries” or “cosmetics”), packing list (consistent with actual goods, indicating packaging method, weight, and dimensions), bill of lading/air waybill;
- Special Documents:
- Electronic Products: Certification certificates (CE/FCC/PSE, etc.), product manuals, certificate of origin;
- Cosmetics: Ingredient lists (INCI names), safety assessment reports, filing/registration certificates;
- Batteries: UN38.3 test reports, SDS, lithium battery transportation declaration;
- Document Consistency: The product name, cargo value, and quantity in all documents must be consistent to avoid customs suspicion due to information contradictions.
- Standardized Packaging and Labeling
- Electronic Products: Adopt shockproof packaging (bubble wrap, EPE foam), mark “fragile” signs to avoid damage during transportation; for battery-containing products, separate the battery from the main unit (if detachable) and perform insulation treatment;
- Cosmetics: Adopt leakage-proof packaging (sealed bags + foam filling); liquid products: maximum 100ml per bottle (for air transportation); mark ingredient lists, shelf life, and filing numbers;
- Batteries: Strictly follow IATA DGR requirements; individual packaging and short-circuit prevention; mark UN numbers, warning signs, battery type, and rated energy.
(2) During Transportation: Channel Selection and Risk Monitoring
- Channel Selection Strategy
- Countries with High Compliance Requirements (EU, US, Japan): Prioritize commercial couriers (DHL, FedEx) or cross-border e-commerce dedicated lines (Cainiao Sensitive Goods Dedicated Line, 4PX Sensitive Goods Channel); these channels have rich customs clearance experience and can provide “certification pre-review” services;
- Emerging Markets (Southeast Asia, Africa): Choose local dedicated lines (such as J&T International, J&T Sensitive Goods Dedicated Line); confirm in advance whether the channel supports sensitive goods transportation and provides customs clearance assistance;
- Prohibited Scenarios: Avoid using postal small parcels for high-value sensitive goods (high loss rate, no customs clearance assistance); battery products are prohibited from using ordinary air transportation channels (logistics providers with “dangerous goods transportation qualifications” must be selected).
- Risk Monitoring and Emergency Handling
- Track the logistics trajectory in real time and pay attention to customs clearance nodes; if “customs clearance delay” or “inspection notice” occurs, contact the logistics provider immediately to understand the reason;
- If detained due to lack of certification, supplement the certification certificate in a timely manner or apply for return (to avoid cargo confiscation);
- If penalized due to excessive ingredients, evaluate the fine amount and cargo value to decide whether to pay the fine or abandon the goods (fines in some countries may exceed the cargo value).
(3) After Customs Clearance: Document Retention and Follow-Up Optimization
- Properly retain all customs clearance documents (certification certificates, customs declarations, tax receipts, inspection records) for at least 3 years for subsequent customs verification;
- Record problems during transportation (such as missing certifications, packaging damage, customs clearance delays) and optimize subsequent operation processes;
- Regularly update the import policies of the destination country (such as EU REACH Regulation updates, US FDA ingredient restriction adjustments) and adjust product compliance plans in a timely manner.
IV. Typical Cases: Compliance and Violation Consequences of Sensitive Goods Transportation
(1) Successful Case: Compliance Operation of an Electronic Enterprise Exporting to the EU
An enterprise exported a batch of lithium battery-containing smart watches to Germany and achieved smooth customs clearance through the following measures:
- Completed CE certification (EMC + LVD + RED directives) and UN38.3 certification in advance, providing complete test reports;
- Documents included commercial invoice, packing list, CE certificate, UN38.3 report, SDS, and certificate of origin, with consistent information;
- Adopted shockproof + insulation packaging design, marked UN3091 number, warning signs, and rated energy;
- Selected DHL Sensitive Goods Channel, submitted certification documents for pre-review in advance; customs clearance took only 2 days without delay.
(2) Failed Case: Violation Consequences of a Cosmetic Enterprise Exporting to the US
An enterprise exported unregistered whitening cream to the US and the goods were confiscated due to the following problems:
- Failed to complete VCRP registration with FDA and had no filing certificate;
- Ingredients contained excessive hydroquinone (prohibited by FDA);
- Labels did not include ingredient lists or importer information;
- Consequences: The goods were confiscated by FDA; the enterprise was included in the “US Customs Blacklist” and prohibited from exporting cosmetics to the US for 1 year; the fine amount was twice the cargo value.
V. Summary: Core Principles of Sensitive Goods Transportation
The core of cross-border transportation of sensitive goods is “compliance first, advance preparation, and precise matching”—compliance is the premise (certification, documents, and packaging are indispensable), advance preparation is the key (avoid temporary certification supplement and hasty packaging), and precise matching is the guarantee (select channels and adjust product compliance plans according to the policies of the destination country).
For cross-border enterprises, it is necessary to establish a “sensitive goods compliance management system”: regularly update the import policies of the destination country, standardize certification and document management, optimize packaging and labeling standards, and select compliant logistics channels. Only in this way can customs clearance risks be effectively reduced and the smooth cross-border transportation of sensitive goods be realized.
Import Restrictions by Country: Shipping Guide for Sensitive Goods such as Electronic Products, Cosmetics, and Batteries
In cross-border trade, electronic products, cosmetics, and battery-related products are classified as core categories of “sensitive goods” due to their involvement in multiple regulatory dimensions including safety, environmental protection, and health. The cross-border transportation of such goods not only faces the timeliness and cost pressures of conventional logistics but also needs to comply with differentiated import restriction policies of various countries—from certification qualifications and ingredient standards to packaging and labeling, any oversight in a single link may result in cargo detention, fines, or even permanent confiscation.
According to data from the World Customs Organization (WCO), the customs clearance failure rate for cross-border transportation of sensitive goods is as high as 12%, far exceeding the 3% rate for ordinary goods; among them, the three main causes are lack of certification, excessive ingredients, and non-compliant packaging. This article will systematically sort out the import restriction rules for electronic products, cosmetics, and batteries in major global trading countries, dissect the compliance key points and channel selection strategies in the transportation link, and provide actionable practical guidance for cross-border sellers and foreign trade enterprises.
I. Core Sensitive Goods Categories and Global Common Regulatory Requirements
(1) Definition and Risk Points of Three Core Sensitive Goods Categories
- Electronic Products: Covering mobile phones, computers, smart wearable devices, electronic components, etc. Core risk points include electromagnetic compatibility (EMC), radio frequency occupation, and lack of safety certification;
- Cosmetics: Including skin care, color cosmetics, and personal care products. Core risk points lie in excessive ingredients (such as heavy metals, hormones), non-standard labeling, and failure to complete filing/registration;
- Batteries and Battery-Powered Products: Including lithium batteries (lithium metal batteries, lithium-ion batteries), button batteries, etc. Core risk points are transportation safety (short circuit, fire), lack of UN38.3 certification, and packaging not meeting IMDG Code requirements.
(2) Global Common Regulatory Requirements
- Certification System: Most countries require sensitive goods to provide third-party testing and certification (such as CE and FCC certifications for electronic products, FDA and CPNP certifications for cosmetics);
- Document Completeness: Commercial invoices, packing lists, product manuals, certification certificates, and certificates of origin are required; some products need additional documents such as ingredient lists and Safety Data Sheets (SDS);
- Packaging Specifications: Battery products need short-circuit and leakage-proof packaging; cosmetics need to be labeled with Chinese/English ingredient lists and shelf life; electronic products need to be marked with voltage, frequency, and other parameters;
- Declaration Authenticity: False declarations are prohibited (such as falsely declaring “lithium batteries” as “ordinary electronic accessories”); the cargo value, product name, and quantity must be consistent with the actual goods.
II. Detailed Explanation of Import Restriction Policies in Major Countries (by Product Category)
(1) Electronic Products: Certification and Spectrum Compliance are Core
- European Union (EU)
- Core Restrictions: Must obtain CE certification (covering EMC, LVD, and RoHS directives); wireless products need additional RED certification;
- Special Requirements:
- The RoHS directive restricts the use of 6 hazardous substances including lead and mercury; electronic products must provide a Declaration of Conformity (DoC);
- The EU Customs Code implemented in 2021 requires advance import declaration, providing product serial numbers and certification numbers;
- Prohibited Scenarios: Equipment without CE certification, excessive radioactivity, or frequency not meeting EU spectrum standards.
- United States (US)
- Core Restrictions: FCC (Federal Communications Commission) certification is mandatory; electronic devices must comply with FCC Part 15 standards;
- Special Requirements:
- Medical electronic products (such as electronic blood pressure monitors) need additional FDA certification;
- Importers must register with CBP (Customs and Border Protection) and submit Importer Security Filing (ISF);
- Prohibited Scenarios: Wireless devices without FCC certification, electronic products that interfere with public communications.
- Japan
- Core Restrictions: Must obtain PSE certification (divided into S-mark for specified electrical products and N-mark for non-specified electrical products);
- Special Requirements:
- Voltage must be compatible with Japan’s 100V standard; product manuals must include Japanese safety warnings;
- Wireless products need to obtain MIC (Ministry of Internal Affairs and Communications) certification, complying with Japan’s Radio Act;
- Prohibited Scenarios: Products without PSE certification, substandard insulation performance, or electromagnetic interference.
- India
- Core Restrictions: Must obtain BIS (Bureau of Indian Standards) certification; some products need ISI mark certification;
- Special Requirements:
- Importers must register with Indian Customs, providing product test reports and BIS certification certificates;
- Electronic products must be marked with “Indian Standard” and certification numbers;
- Prohibited Scenarios: Products without BIS certification or not meeting India’s voltage (230V) standard.
(2) Cosmetics: Ingredients and Filing are Key
- European Union (EU)
- Core Restrictions: Must complete filing on CPNP (Cosmetic Products Notification Portal), complying with Regulation (EC) No 1223/2009;
- Special Requirements:
- Ingredients must conform to the EU Cosmetic Ingredients Database (CosIng); 26 substances including glucocorticoids and hydroquinone are prohibited;
- Labels must include ingredient lists (INCI names), production batch numbers, shelf life, and responsible person information;
- Sunscreen and whitening products must be declared as “special cosmetics” and provide additional safety assessment reports (SCCNFP);
- Prohibited Scenarios: Excessive ingredients, unfiled products, or false labeling.
- United States (US)
- Core Restrictions: Regulated by FDA (Food and Drug Administration), complying with the Federal Food, Drug, and Cosmetic Act (FD&C Act);
- Special Requirements:
- Ingredients must be included in the FDA’s list of permitted cosmetic ingredients; substances such as chlorofluorocarbons and asbestos are prohibited;
- Submit an application for the Voluntary Cosmetic Registration Program (VCRP) before import; some products (such as sunscreens with SPF values) need FDA approval;
- Labels must include net weight, ingredient lists, and the name and address of the importer/distributor;
- Prohibited Scenarios: Harmful ingredients, non-standard labels, or misleading advertising.
- China
- Core Restrictions: Ordinary cosmetics need to complete filing; special cosmetics (hair dyeing, perming, freckle removal and whitening, etc.) need to obtain registration certificates;
- Special Requirements:
- Ingredients must comply with the Safety and Technical Standards for Cosmetics; 42 glucocorticoids and 35 antibiotics are prohibited;
- Imported cosmetics must be labeled with Chinese labels, including ingredient lists, production batch numbers, shelf life, and filing/registration numbers;
- Certificate of origin, test report, and safety assessment report are required;
- Prohibited Scenarios: Unfiled/unregistered products, excessive ingredients, or non-compliant Chinese labels.
- Southeast Asia (Indonesia, Malaysia, Thailand)
- Indonesia: Must obtain BPOM (National Agency of Drug and Food Control) certification; ingredients must comply with Indonesian National Standards (SNI); harmful substances such as mercury and arsenic are prohibited;
- Malaysia: Must register with NPRA (National Pharmaceutical Regulatory Agency); labels must include Malay/English ingredient lists; whitening products need to provide whitening ingredient test reports;
- Thailand: Must obtain FDA certification; hydroquinone and glucocorticoids are prohibited; labels must be marked with “Thai FDA Certification Number” and shelf life.
(3) Batteries and Battery-Powered Products: Transportation Safety and Certification Go Hand in Hand
- Common Requirements of the United Nations (UN) and International Air Transport Association (IATA)
- All lithium batteries must pass UN38.3 test certification and provide test reports;
- Lithium metal batteries: Maximum 1g of lithium per cell; lithium-ion batteries: Rated energy ≤100Wh (approval from the airline is required for exceeding this limit);
- Packaging must adopt short-circuit prevention design (such as individual packaging, insulation treatment), marked with “lithium battery” warning signs and UN numbers (such as UN3090, UN3091);
- Safety Data Sheet (SDS) for lithium battery transportation is required.
- European Union (EU)
- Core Restrictions: Batteries must comply with REACH Regulation and Battery Directive (2006/66/EC); mercury content ≥0.0005% and cadmium content ≥0.002% are prohibited;
- Special Requirements:
- Must be marked with battery capacity and recycling logo, providing a recycling commitment letter;
- Battery-containing products need additional CE certification (EMC + LVD directives);
- Prohibited Scenarios: Lack of UN38.3 certification, excessive harmful substances, or non-compliant packaging.
- United States (US)
- Core Restrictions: Regulated by DOT (Department of Transportation), complying with 49 CFR regulations; lithium batteries must pass UN38.3 certification;
- Special Requirements:
- Imported batteries need to submit a “Battery Import Notification”, providing test reports and safety declarations;
- Air transportation must comply with IATA DGR requirements, marked with “Cargo Aircraft Only” or “Passenger/Cargo Aircraft” signs;
- Prohibited Scenarios: Failure to pass UN38.3 tests, non-compliant packaging with safety standards, or false declaration of battery type.
- Japan
- Core Restrictions: Batteries must comply with JIS standards, pass UN38.3 certification, and provide test reports;
- Special Requirements:
- Battery-containing products need to obtain PSE certification, marked with “PSE Certification Mark”;
- Packaging must be marked with battery type, rated energy, and UN number; bulk transportation is prohibited;
- Prohibited Scenarios: Lack of UN38.3 certification, non-compliance with JIS standards, or packaging without warning signs.
- Australia
- Core Restrictions: Batteries must obtain ACMA (Australian Communications and Media Authority) certification, complying with AS/NZS standards;
- Special Requirements:
- Register with ACMA before import, providing UN38.3 test reports and safety declarations;
- Battery-containing electronic products need additional EMC certification;
- Prohibited Scenarios: Lack of ACMA certification or excessive battery energy (lithium-ion batteries >100Wh).
III. Compliance Operation Guide for Sensitive Goods Transportation
(1) Before Transportation: Three Core Preparation Tasks
- Complete Qualification Certification
- Inquire about the certification requirements of the destination country in advance; entrust third-party institutions to handle required certifications (such as CE, FCC, FDA, UN38.3, etc.) to ensure the certification certificates are within the validity period;
- Cosmetics need to complete filing/registration in advance (such as EU CPNP, China filing certificate) to avoid detention caused by “transportation before filing”;
- Keep original and electronic versions of certification certificates and test reports, which need to be provided at any time during customs clearance.
- Complete Documentation
- Basic Documents: Commercial invoice (truthfully mark product name, specification, quantity, unit price, cargo value, and indicate “sensitive goods type” such as “containing lithium batteries” or “cosmetics”), packing list (consistent with actual goods, indicating packaging method, weight, and dimensions), bill of lading/air waybill;
- Special Documents:
- Electronic Products: Certification certificates (CE/FCC/PSE, etc.), product manuals, certificate of origin;
- Cosmetics: Ingredient lists (INCI names), safety assessment reports, filing/registration certificates;
- Batteries: UN38.3 test reports, SDS, lithium battery transportation declaration;
- Document Consistency: The product name, cargo value, and quantity in all documents must be consistent to avoid customs suspicion due to information contradictions.
- Standardized Packaging and Labeling
- Electronic Products: Adopt shockproof packaging (bubble wrap, EPE foam), mark “fragile” signs to avoid damage during transportation; for battery-containing products, separate the battery from the main unit (if detachable) and perform insulation treatment;
- Cosmetics: Adopt leakage-proof packaging (sealed bags + foam filling); liquid products: maximum 100ml per bottle (for air transportation); mark ingredient lists, shelf life, and filing numbers;
- Batteries: Strictly follow IATA DGR requirements; individual packaging and short-circuit prevention; mark UN numbers, warning signs, battery type, and rated energy.
(2) During Transportation: Channel Selection and Risk Monitoring
- Channel Selection Strategy
- Countries with High Compliance Requirements (EU, US, Japan): Prioritize commercial couriers (DHL, FedEx) or cross-border e-commerce dedicated lines (Cainiao Sensitive Goods Dedicated Line, 4PX Sensitive Goods Channel); these channels have rich customs clearance experience and can provide “certification pre-review” services;
- Emerging Markets (Southeast Asia, Africa): Choose local dedicated lines (such as J&T International, J&T Sensitive Goods Dedicated Line); confirm in advance whether the channel supports sensitive goods transportation and provides customs clearance assistance;
- Prohibited Scenarios: Avoid using postal small parcels for high-value sensitive goods (high loss rate, no customs clearance assistance); battery products are prohibited from using ordinary air transportation channels (logistics providers with “dangerous goods transportation qualifications” must be selected).
- Risk Monitoring and Emergency Handling
- Track the logistics trajectory in real time and pay attention to customs clearance nodes; if “customs clearance delay” or “inspection notice” occurs, contact the logistics provider immediately to understand the reason;
- If detained due to lack of certification, supplement the certification certificate in a timely manner or apply for return (to avoid cargo confiscation);
- If penalized due to excessive ingredients, evaluate the fine amount and cargo value to decide whether to pay the fine or abandon the goods (fines in some countries may exceed the cargo value).
(3) After Customs Clearance: Document Retention and Follow-Up Optimization
- Properly retain all customs clearance documents (certification certificates, customs declarations, tax receipts, inspection records) for at least 3 years for subsequent customs verification;
- Record problems during transportation (such as missing certifications, packaging damage, customs clearance delays) and optimize subsequent operation processes;
- Regularly update the import policies of the destination country (such as EU REACH Regulation updates, US FDA ingredient restriction adjustments) and adjust product compliance plans in a timely manner.
IV. Typical Cases: Compliance and Violation Consequences of Sensitive Goods Transportation
(1) Successful Case: Compliance Operation of an Electronic Enterprise Exporting to the EU
An enterprise exported a batch of lithium battery-containing smart watches to Germany and achieved smooth customs clearance through the following measures:
- Completed CE certification (EMC + LVD + RED directives) and UN38.3 certification in advance, providing complete test reports;
- Documents included commercial invoice, packing list, CE certificate, UN38.3 report, SDS, and certificate of origin, with consistent information;
- Adopted shockproof + insulation packaging design, marked UN3091 number, warning signs, and rated energy;
- Selected DHL Sensitive Goods Channel, submitted certification documents for pre-review in advance; customs clearance took only 2 days without delay.
(2) Failed Case: Violation Consequences of a Cosmetic Enterprise Exporting to the US
An enterprise exported unregistered whitening cream to the US and the goods were confiscated due to the following problems:
- Failed to complete VCRP registration with FDA and had no filing certificate;
- Ingredients contained excessive hydroquinone (prohibited by FDA);
- Labels did not include ingredient lists or importer information;
- Consequences: The goods were confiscated by FDA; the enterprise was included in the “US Customs Blacklist” and prohibited from exporting cosmetics to the US for 1 year; the fine amount was twice the cargo value.
V. Summary: Core Principles of Sensitive Goods Transportation
The core of cross-border transportation of sensitive goods is “compliance first, advance preparation, and precise matching”—compliance is the premise (certification, documents, and packaging are indispensable), advance preparation is the key (avoid temporary certification supplement and hasty packaging), and precise matching is the guarantee (select channels and adjust product compliance plans according to the policies of the destination country).
For cross-border enterprises, it is necessary to establish a “sensitive goods compliance management system”: regularly update the import policies of the destination country, standardize certification and document management, optimize packaging and labeling standards, and select compliant logistics channels. Only in this way can customs clearance risks be effectively reduced and the smooth cross-border transportation of sensitive goods be realized.