During the China Homelife Poland 2018, specialized seminars and workshops were held. Experts shared knowledge, practical experience from cooperation with Chinese partners, they responded to specific, sometimes very specific questions. One of the lectures concerned issues related to import from China. They were presented by Paulina Kiełbus-Jania, the president of the board of BigChina. Below are selected business questions and expert answers.
When are the original commercial documents, specifically invoices, required to be cleared?
Commercial invoice is not required in the original. Just a copy.
I would like to bring to Poland an electronic product that requires a CE certificate. How can I check whether the certificate issued by my contractor is legal and that the product will be released for sale in the EU?
The first step is to check the requirements and regulations for placing the product on the market in the EU. You need to know which documents to require – which directives and product regulations and the process of its production should meet.
Then check whether the selected manufacturer has documents confirming compliance with these regulations. In the case of CE it will be primarily a test report on the product’s compliance with the required standards. The certificate itself does not constitute sufficient confirmation of the tests carried out.
Both the certificate and the test report should be checked in terms of the numbers of directives and standards specified in it. Verify their correctness and timeliness. It is also worth paying attention to the connection with the imported product (check the conformity of the name, serial number or model).
For customs clearance, you will need the CE Declaration of Conformity issued and signed by the manufacturer. The declaration is prepared based on the CE certificate and test report.
How long do you wait for the WIT?
No longer than 120 days from the acceptance of the complete application.
(BTI, binding tariff information is a decision determining the tariff classification of goods, i.e. determining the appropriate Tariff code for a particular good – ed note)
Can the user manual print in Poland and attach only after customs clearance?
Lack of instructions may form the basis for detaining the goods. However, it sometimes happens that the Customs Office accepts the importer’s statement on the inclusion of instructions after receiving the products, but before placing them for sale or use. It is then necessary to present the draft instructions. However, it depends on the decision of the customs officer. In the absence of such a solution, it will be necessary to initiate the procedure of refining the products, and thus to attach the instructions to the customs warehouse before making the check-in.
Should the instructions be applied to each product or is it enough for a batch, for example?
Instructions (if required) should be included with each product.
Do I need documents (CE and test results) if I am a retailer and I have bought goods badly labeled from an importer who somehow passed control?
The retail seller is not obliged to keep the CE documentation. The documentation should have a company that places the product on the market in the EU.
The questions concerned very specific issues
The questions concerned very specific issues
Is it possible to write on the packaging that it was produced in a different country than it really was produced?
No, it is misleading the consumer.
What about promotional items / guarantee items / giveaway – can they have a “nil” value?
No item on the commercial invoice may have a “nil” value. The value of the product does not have to be the same as its price. All products included in the shipment free of charge (spare parts, samples or other freebies) should be specified on the invoice, and their value should be specified. Next to the value should be added FOC (Free Of Charge), informing that these are products attached free of charge.
Is it possible to use PI if we have not received CI from the supplier?
A commercial invoice – Commercial Invoice is necessary to check in. The pro forma invoice is not a confirmation of the transaction.
If we modify the product in Poland, can you write that the country of origin is Poland? For example, if I bring a product and change its color, I need to re-prepare all certificates and test reports?
The change in the color of the product does not affect the country of production and does not change the properties of the product being tested for compliance. However, if the product (and in principle then the intermediate product) is modified in a significant way, which will change the country of production, it will require a new certification.
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