——20 Years of Senior Agency Service Experience Practical Guide

As a senior consultant with 20 years of experience in theExport RepresentationWith 20 years of experience as a professional service provider in the industry, we deeply understandAutomotive partsThe Complexity and Professionalism of Import. This article will systematically analyze the entire process of importing automotive parts from a practical operational perspective, and propose risk prevention and control recommendations targeting industry pain points, to assist enterprises in achieving efficient and compliant imports.

I. Preliminary Preparation Phase: Compliance Access and Cost Calculation

1.Triple Verification of Product Qualifications

• Accurate classification of HS codes: Distinguish between key components (such as the 8708 series engines) and general accessories (e.g., wipers 8512.40) by considering their intended use (OEM production/after-sales maintenance) to determine classification, thereby avoiding tariff discrepancies due to incorrect HS codes (e.g., transmission oil classified under 3403.19 incurs a 6% tariff, while misclassification under 8708 would result in a 10% tariff).
• Accessibility certification verification:
  • EU market: e-mark certification (ECE R90 brake pad certification), REACH regulation (heavy metal content in rubber components);
  • US Market: DOT certification (FMVSS 108 standard for vehicle lights), CARB certification (emission-related components);
  • China Market: CCC certification (47 categories of products such as seat belts and tires), special scenarios requiring prior application for the "Exemption Certificate for CCC" (e.g., limited imports for maintenance purposes).
• Application of rules of origin: To fully leverage free trade agreements (such as RCEP, which offers 0% tariffs on Japanese pistons), verification is required.It is recommended to verify through the following methods:Format (Back-to-back Certificate of Origin is applicable to transit trade).

2.Dynamic Calculation Model of Tariff Costs

• Basic taxes and fees: Tariff + 13% VAT (New energyVehicle parts are eligible for tax reduction policies) + consumption tax (for displacement-related components);
• Cost optimization strategy:
  • Advance classification ruling (Announcement No. 14 of the General Administration of Customs in 2018) requires application three months in advance to lock in tariff code risks;
  • Summary taxation (the "one guarantee for multiple uses" model reduces capital occupation);
  • Free Trade Zone Warehousing and Distribution (Deferred Taxation + Order Splitting and Consolidation Optimization).

II. Customs Clearance Practices: Full-Process Node Control

1.Key actions in the declaration process

• Completeness of Declaration Elements: Brand/Model/Applicable Vehicle Models (must be precise to the first 8 digits of the VIN code), Material (percentage of metal components), Functional Principle (for Electronic Control Unit ECU, specify the programming method);
• Key Points of Document Management:
  • The commercial invoice must indicate the terms of trade (CIF/FOB adjusted dutiable value);
  • Original Manufacturer Authorization Letter (to prevent trademark infringement, especially for highly sensitive brands such as Mercedes-Benz and BMW);
  • Technical parameter booklet (pressure ratio and flow rate data must be provided for turbochargers).

2.Handling Common Issues During On-Site Inspections

• Label Compliance Rectification:
  • Missing Chinese warning labels (e.g., airbags should be labeled "Store below 40°C before installation").
  • The tire must display the production week number (in DOT XXYY format, where YY represents the year);
• Sampling and submission for inspection and disposal:
  • When the friction coefficient test of brake pads (GB 5763-2018 standard) fails, a re-inspection or return shipment can be requested;
  • The deviation in lubricating oil flash point testing can be appealed by providing the original manufacturer's MSDS.

3. Back-end Supply Chain Management: Delivery Timeliness and Risk Closure

1. **Specialized Storage Solutions**

• Precision components (ECU module): Constant temperature and humidity chamber (temperature 22±2°C, humidity 45%-60%);
• Hazardous goods category (airbags classified as UN0503): Store independently in Class A hazardous chemical warehouse;
• JIT Delivery: Leveraging bonded warehouses to achieve "Hong Kong warehouse inventory + Shenzhen factory hourly-level delivery."

2.Quality Dispute Resolution Mechanism

• On-site arrival inspection: According to the AQL sampling standard (GB/T 2828.1), a test report will be issued within 72 hours upon discovery of batch quality issues;
• Return for Repair Operation: Apply for the "Declaration Form for Outbound Repair Goods," and ensure the repair period is controlled within 6 months to avoid taxation;
• Warranty Claim Coordination: Coordinate with overseas suppliers to initiate the RMA process while simultaneously preparing force majeure documentation (e.g.Maritime TransportationDampness causes oxidation of the wiring harness).

IV. Industry-Specific Risk Alerts

1.Intellectual property red line

• OEM manufacturing scenario: It is necessary to verify the validity of the "Parallel Import Authorization Letter" (with special attention to the BMW v. Ningbo Free Trade Zone case);
• Design patent conflicts: Before importing components such as wheels and grilles, search China's design patent database (as of 2023, Tesla has registered 21 wheel design patents).

2.Upgrading Environmental Regulations in Response

• EU New Battery Regulation (effective in 2027): Requires the provision of battery carbon footprint declarations, involving the import of start-stop battery packs.
• China's National VI Emission Standard: Catalytic converters must obtain the type test report in advance.

5. Review of Classic Cases

Case 1: A company's imported Mercedes-Benz drive shaft was detained by customs.

• Issue: Not authorized as a secondary distributor by Daimler Group.
• Solution: Initiate the customs protection procedure for intellectual property rights (general guarantee filing), and release the goods after supplementing the submission of the trademark use consent letter.

Case 2: Dispute over the Return of Imported New Energy Vehicle Motors from South Korea

• Issue: The rare earth composition of the magnet does not comply with the "Regulations on the Management of Ozone-Depleting Substances."
• Disposal: Apply for pre-shipment inspection (compliance certificate issued by the Korean KTC agency), and proceed with customs clearance after re-declaration.

Conclusion

The import of automotive parts involves complex technical regulations and stringent quality control requirements. Choosing an agency service provider with qualifications for importing electromechanical products (Customs AEO Advanced Certification), an overseas inspection team (such as a TüV cooperation agency in Germany), and self-operated bonded warehousing can significantly reduce supply chain risks. It is recommended that enterprises establish an import compliance management system (referring to the ISO 37301 standard) to achieve full-cycle control from order to delivery.

(Note: The data in this article is as of Q3 2023. Please refer to the latest regulations for specific operations.)

To obtain the "China Automotive Parts Import Compliance White Paper" or to customize a supply chain solution, please contact our professional advisory team.