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Import from China: the document route from negotiations to sale

Most problems with documents are created not at customs but at negotiations — when no one is thinking about documents yet. By the time the container leaves, some decisions are already irreversible.

Most problems with documents in import are created not at customs but at negotiations — when no one is thinking about documents yet. By the time the container has left the port, some decisions are already irreversible. Below is the route in the order in which it must be followed.

Step 0. Before choosing a supplier

The most underestimated stage. Until you know which regulations the product falls under, you know neither the budget, nor the timing, nor what to request from the factory.

If at this step it turns out that state registration is needed, not a declaration, the whole plan shifts by months. It is better to find this out before the prepayment. How to determine the applicability of regulations is covered in the article on product lists.

Chinese certificates do not replace our documents The factory confidently answers “everything of ours is certified” and sends documents of its own system. They have no force on the territory of the Union. They do have a value, but a different one: they show which tests have already been carried out and which standards were applied — this shortens the selection of tests here, but does not cancel the issuing of documents.

Step 1. What to request from the factory before the contract

After payment, the supplier’s interest in correspondence drops sharply. Everything needed is requested at the stage when the supplier is still interested in the deal.

What to requestWhy
Full specification: composition, materials, dimensionsWithout the composition it is impossible to select the tests
Technical diagrams and drawingsNeeded for equipment and machinery
List of the standards appliedDetermines how far the existing test reports can be reused
Factory test reportsReduce the amount of work here
Data for labelling: model, manufacturer, addressWill be needed in the documents and on the label
Operating manual in the original languageThe basis for a translation, not for a retelling
Readiness to apply a Russian label at the factoryCheaper than stickering at a warehouse
Consent to receive experts when a series is certifiedOtherwise a scheme with analysis of production is impossible

It makes sense to include the last two items directly in the contract and tie them to payment. The wording “provided on request” does not work in practice.

Step 2. Samples

Testing is carried out here, so the samples must be physically brought in — before the main batch.

More on the rules of selection is in a separate article.

Step 3. Who will be the applicant

The moment at which almost all newcomers stumble. A Chinese factory cannot be the applicant. The document is issued to a person registered in the Union: to you as the importer or to a person authorised by the manufacturer.

It follows that:

“We already have a declaration” — check whose it is An intermediary or a previous importer could have issued the document to themselves. Such a document is valid, but has nothing to do with your delivery. It is checked in a minute in the register: look at the applicant, the manufacturer and the list of models.

Step 4. Labelling: at the factory or at the warehouse

Russian-language labelling must be applied before the goods are released into circulation — that is, before sale, not after a request from the platform.

Printing at the factoryStickering at the warehouse
CostLower for a print runHigher, manual labour
QualityThe label is part of the packagingThe sticker may peel off
Risk of errorThe error is replicated across the whole batchCan be corrected as you go
TimingRequires the layout to be agreed in advanceDelays shipment to the warehouse

The best option: agree the layout in advance and print at the factory, but be sure to check a trial batch before the print run is launched. The sticker must not cover the mandatory information on the original packaging.

Step 5. Mandatory labelling with codes

If the product falls into a group under mandatory labelling, the codes are applied before the border is crossed. This is a separate system, not connected with conformity confirmation, and it cannot be satisfied with a declaration.

The calendar by product group is in the article on labelling.

Step 6. Customs clearance

By this moment the documents must be ready: their numbers are stated in the declaration for the goods. What is checked at the junction:

A discrepancy on any item means a request for additional information and the cargo standing at a temporary storage warehouse. What to do in a dispute over the code is covered in the article on classification.

How much time to allow

The exact timing depends on the product, but the order of stages and their relative duration are stable.

StageWhat determines the duration
Determining the regulations and the formDays, if the product is clear
Receiving documents from the factoryDepends on its readiness; a frequent point of delay
Delivery of samplesLogistics from China
TestingThe main part; microbiology and stability take the longest
Rework if indicators failReturn to production, a repeat cycle
Issuing and registrationDays if the set of documents is ready
State registration instead of a declarationMonths, if applicable

The most frequent planning error is to count the time from the arrival of the container. You need to count from the date when the product must appear on sale, and go backwards.

Typical traps

Checklist before prepayment

Eight items, each of which costs one letter before the deal and weeks of dispute after it.

Check your product Describe your product in plain words — the system will show the HS code (TN VED), the applicable regulations and the form of confirmation even before negotiations with the factory. Start the check.
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