Three Major Compliance Pitfalls Hidden in Imported Equipment

A coastal city's environmental protection enterprise, while importing a German reverse osmosis system in early 2025, failed to verify the pH adjustment module of the equipment, resulting in...Material Certification Document, resulting in the entire batch of goods being detained for 28 days during customs inspection, incurring additional storage fees and breach of contract penalties totaling $120,000. This typical case reveals that special attention must be paid to the import of water treatment equipment:

• Technical Parameter Compatibility Risk
  • Differences in water quality standards among importing countries (e.g., comparison between China's GB/T 14848 and EU's 98/83/EC indicators)
  • Incorrect conversion of equipment working pressure units (precise conversion between psi and MPa)
• Risks of customs classification disputes
  • The difference in applicable scenarios between HS codes 8421.21 and 8421.29.
  • The tariff difference between complete sets of equipment and assembled parts

Comprehensive Compliance Operation Guide for the Entire Process

Based on Announcement No. 38 of 2025 from the General Administration of Customs, it is recommended to proceed with the import procedures according to the following steps:

• Pre-declaration stage (30 days before the arrival of goods at the port)
  • ObtainIt is recommended to verify through the following methods:Ming and CE/UL certification documents
  • Confirm that the equipment voltage parameters comply with domestic power grid standards (380V±5%).
• Key Points for Preparing Application Materials
  • The technical specifications document shall include the accuracy class of the flow meter (recommended 0.5 class or above).
  • Provide a filtration media composition test report (with a focus on heavy metal content).

New Strategies for Tariff Planning in 2025

According to the latest adjustments by the Customs Tariff Commission of the State Council, water treatmentEquipment ImportsPlease note:

• Rules for Separate Taxation of Core Components
  • The tariff rate for RO membrane modules has been reduced from 8% to 5% (proof of separate packaging is required).
  • The control system module is subject to a 13% value-added tax (originally levied at 17% based on the complete machine).
• Application of Regional Preferential Policies
  • Query Path for Tariff Concession List of RCEP Member Countries' Originating Equipment
  • Conditions for the Application of the 30% Tariff Exemption Policy on Processing Value-added Products in Hainan Free Trade Port

Professional Agency Service Value Assessment System

ChooseImport RepresentationThe following competency indicators should be prioritized during evaluation:

• Technical document review capability
  • Can the differences between ASME Section VIII and GB150 standards be identified?
  • Compliance verification of the Pressure Vessel Inspection Certificate (PVOC)
• Emergency Response Time Standard
  • Customs classification dispute response time (premium agents can achieve a 4-hour emergency response)
  • Coordination capability for on-site inspection (reducing customs clearance time by an average of 5.7 working days)

2025 policy change alert

Import enterprises need to pay special attention to two new regulations that are about to be implemented:

• Updates to the EU Environmental Directive for Water Treatment Equipment
  • The energy efficiency label grading system (EEEI≥0.85) will be implemented starting from July 2025.
  • Add new restrictions on the use of PFAS chemicals.
• China Customs Adjusts Inspection Priorities
  • Upgrade of Reverse Osmosis Membrane Element Lifespan Testing Standard (Flux Decline Rate ≤15%)
  • Implementation Specification for On-Site Rapid Testing of Residual Chlorine Content in Disinfection Devices