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Restricted goods, such as controlled telecommunications equipment, medical devices, and pharmaceuticals, often require detailed documentation and permits when imported.
Unlike regular shipments, these goods require preparation to ensure compliance before they are cleared through customs.
In our previous discussion concerning the customs clearance instructions, we highlighted the significance of complete and accurate documentation when importing.
In this article, Blackthorne digs deeper into the customs clearance requirements, precisely for restricted goods, for a seamless customs clearance.
Restricted goods are items that can be legally imported into a country, but only under specific conditions and restrictions. These conditions are based on the nature, function, or potential impact of the goods on national security, public health, or the environment.
As a result, restricted goods require approval, which may be in the form of import permits, product quality certifications, and technical evaluations. These approvals must be verified before customs allow the goods to enter the destination country.
Unlike free-to-import goods, which can be cleared based on a commercial invoice and packing list, restricted goods may require in-country inspection.
During inspections, regulatory agencies may request testing reports, compliance certificates, or an end-user declaration to ensure that the products pose no harm.
Prohibited goods are items that are completely banned from leaving or entering a country. When imported or exported, they can disrupt public health, the environment, national security, or promote illegal activities.
Examples of prohibited goods include illegal drugs, counterfeit currency, certain weapons and explosives, and dangerous cars or toys.
While restricted goods can be imported under specific conditions, prohibited goods cannot be imported at all. Attempting import/export (smuggling) of prohibited goods is a criminal offense that warrants severe penalties.
Restricted items are high-risk shipments, requiring various approvals, licences, and permits, besides the shipping and commercial documentation.
Here are the essential requirements you must satisfy when clearing restricted goods:
Like any other shipment, restricted goods must be shipped to the destination country. The logistical and financial details of the shipment help communicate the route, value, quantity, and ownership of the goods.
These logistics and financial documents include:
Before shipping your goods, you must determine the quality, quantity, safety, and environmental regulations that govern them.
Here are the main categories of restricted goods, against the technical requirements that apply when importing:
Restricted Goods Category | Technical Requirement |
Telecom and wireless equipment | EMC and Radio Frequency (RF) testing, health and safety standards compliance, and electrical safety compliance |
Medical devices | ISO 13485 certification, device class registration, clinical evaluation certificates, and safety and performance standards compliance |
Pharmaceuticals | Good Manufacturing Practices (GMP) certifications, shelf life and storage compliance, quality control testing, and Good Clinical Practice (GCP) standards |
Lithium batteries | UN 38.3 transport safety certification |
Chemicals | Hazard datasheet (SDS), REACH, or TSCA compliance |
Industrial electronics | IEC 60950/62368 safety testing |
Your restricted products may fall under multiple categories, requiring compliance with all applicable standards and regulations.
While providing technical guidelines, regulatory authorities also provide labelling and compliance marking requirements. The requirements include safety and product performance instructions, such as warnings, storage, and associated risks.
These labels serve as proof of compliance with safety and performance regulations. They also guide the end-user on safe handling, usage, and quality of the item.
Here are some of the labelling requirements for various categories of restricted goods:
Restricted Goods Category | Labelling Requirement |
Electronics/ICT Equipment | CE/FCC/UKCA mark, serial/model numbers, voltage specifications, and user manuals |
Medical devices | UDI barcode, device class, manufacturer/importer address |
Pharmaceuticals | Batch number. Dosage instructions, expiry date |
Food supplements | Nutritional facts, expiration dates, allergen statements |
Chemicals | GHS hazard symbols, UN number, warnings |
Note: The manufacturer bears the primary responsibility of marking and labelling information. However, whether a manufacturer, supplier, or distributor, you must verify that imported goods align with applicable labelling requirements before shipping.
Customs authorities require compliance documentation to verify that your shipment adheres to national laws, safety requirements, and technical regulations before market entry.
The common types of compliance documentation across the globe include:
Once your restricted goods arrive at the destination country, you must clear them through customs. If proven compliant, they are released for last-mile delivery.
The customs authorities expect you to have checked several boxes to allow for timely clearance.
You can refer to this checklist of pre-clearance requirements:
Note: Customs clearance requirements for restricted goods vary from one country to another. If you are importing IT equipment, you can find detailed import requirements specific to your destination, including Germany, Thailand, and the USA.
Fulfilling the customs requirements for restricted goods can be costly due to avoidable mistakes.
Here are the five common mistakes to watch out for and how to avoid them:
HS classification determines your shipment’s import requirements, including licensing, duty rates, and regulatory compliance.
Assigning the wrong HS code translates to unexpected obligations, inaccurate duty or tax calculations, and, in many cases, compliance violations.
For accurate classification, always cross-check product descriptions and specifications against the updated HS code database of the importing country.
If you are unsure about your product category, collaborating with an importer of record in your industry would be helpful.
Compliance certificates can expire, be poorly formatted, or be issued by unrecognised bodies, making them invalid.
Also, applying for licences and permits at the last minute can result in a missing document, as some licences take time to process. And import documentation requires consistency for ease of verification.
Once you have determined the import requirements for a restricted item, preparing documentation in advance ensures completeness and accuracy. Additionally, consider utilising accredited and approved bodies when applying for conformity assessment.
Manufacturers may provide invalid conformity certificates, ship non-compliant products, or fail to disclose essential manufacturer information.
It’s important to vet a supplier’s compliance capability. Ensure they provide traceable documentation, including valid test reports, proof of accreditation, and certification details.
A product may be well labelled and demonstrate compliance with technical standards, yet fail to meet the regulatory standards of your destination market.
For instance, electronic equipment may comply with design standards of the country of origin, but lack specific approvals like CE marking for the EU or UL certification for the US market.
By conducting pre-shipment inspection, you ensure imported products meet all safety and performance requirements before shipping.
Handling customs paperwork, licensing, and compliance requirements for restricted goods demands experience.
Often, choosing DIY may be cost-saving. But if you lack the expertise, time, or experience in cross-border compliance for restricted goods, meeting regulatory requirements can prove a hurdle.
The process can get more complex if you have yet to establish a local presence in the destination country, compelling you to involve multiple service providers.
While involving multiple service providers may be a solution, it can increase the risk of export control diversion and the cost of importation. To lower the risk of non-compliance, cut costs, and ensure timely delivery, you may consider an IOR shipment.
You can learn more about the various professionals you can engage for customs clearance from our previous discussion on customs clearance instructions.
Restricted IT equipment is among the most regulated yet profitable imports in the global marketplace.
Technological advancements, including the Internet of Things, Big Data, and cloud computing, are driving demand worldwide. So why would you let geographical boundaries limit your profits?
The better part?
You don’t need to manage the entire global supply chain to import restricted IT equipment. A reliable technology IOR like Blackthorne will ensure your shipment reaches any destination, compliantly and hassle-free.
Whether you are delivering telecommunications equipment to an international data centre or exploring a new market, Blackthorne IOR has you covered.
We have a dedicated compliance and logistics team in over 200 import destinations, providing a door-to-door delivery of your equipment. That means you don’t have to worry about:
As such, you enjoy a risk-free, timely, and cost-efficient IT equipment importation.
Besides, our IOR’s role for goods subject to export licensing is invaluable. We identify licensing requirements, obtain relevant licences and permits, eliminate unnecessary licensing costs, and attend to any compliance issues that may arise.
So, what stops you from scaling your IT equipment imports globally?
You can let us know via call or email us at sales@blackthorneit.com. We are happy to fulfill customs clearance requirements on your behalf.
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