EU Dairy Import: Compliance Path and Operation Practice Under Direct Agency Mode

In 2026,China’s total import volume of dairy products is expected to exceed 4 million tons,of which EU countries account for more than 35% stably.Products such as infant formula,butter and cheese from Germany,the Netherlands,France and other countries are continuously favored by the domestic market.However,the complexity of links such as overseas production enterprise registration,formula registration,label review,and commodity inspection sampling makes direct import face practical challenges such as long cycle,high return risk,and difficult control of compliance cost.Zhongshen has been deeply engaged in import agency services for more than 20 years,and has formed a full-process solution covering document pre-examination,port customs declaration and commodity inspection coordination in the dairy sector.

Document Pre-examination Stage: Access Qualification and Document Compliance Review

The first threshold for dairy import is the access qualification of overseas production enterprises.In 2026,the General Administration of Customs of China has further strengthened the implementation of the Administrative Provisions on Registration of Overseas Production Enterprises of Imported Food.EU production enterprises must be in the registration list published by the General Administration of Customs,and the registration scope must cover specific product categories.The enterprise where Ms.Tao works once planned to import a batch of mozzarella cheese from Italy.Because the production enterprise only registered the liquid milk category,the goods were judged as unlicensed production after arrival at the port,and finally faced return shipment.

Zhongshen has established a three-level review mechanism in the document pre-examination link.The first level verifies the validity of the production enterprise registration number,and compares the matching degree between the registration scope and the HS code of the proposed imported product in real time through the official website of the General Administration of Customs.The second level reviews formula compliance,and for special products such as infant formula,confirms whether the formula registration certificate from the State Administration for Market Regulation has been obtained.The third level is pre-examination of label samples,and conducts compliance screening according to the National Food Safety Standard General Standard for Labeling of Prepackaged Foods (revised GB 7718-2026) and the General Standard for Nutrition Labeling of Prepackaged Foods.

In March 2026,a client served by Manager Kang planned to import a batch of adult milk powder from the Netherlands,and the label was marked with the functional claim of "rich in immunoglobulin".Zhongshen pointed out in the pre-examination stage that such a claim belongs to the category of health food,and ordinary food cannot be marked.It suggested that the client modify the label expression to "contains immunoglobulin",which avoided the risk of subsequent commodity inspection failure.

Port Customs Declaration Stage: Classification,Price Examination and Application of Rules of Origin

HS code classification of dairy products directly affects tariff rate and regulatory conditions.Under the 2026 most-favored-nation tariff,the tariff of whey powder (0404.10) is 6%,while the tariff of infant formula (1901.10) is 5%,but the latter needs to submit a formula registration certificate.Manager Wen once handled a case of skimmed milk powder imported from France.The client initially declared under 0402.21.After recheck by Zhongshen,it was found that the product was actually modified milk powder with added vitamins,which should be classified into 1901.90.Although the tariff rose to 15%,it avoided administrative penalties caused by classification errors.

The price examination link is the focus of customs supervision.EU dairy products generally have non-trade payments such as brand licensing fees and technology licensing fees,which may be included in the dutiable value by customs.Zhongshen assists clients to prepare complete price composition descriptions,distinguishes royalty from the actual transaction price of goods,and reasonably protects the rights and interests of enterprises.In January 2026,for the client imported organic infant formula from Germany that Mr.Zhang acted for,customs questioned the declared price.Zhongshen submitted the cost composition analysis of the overseas producer,the breakdown of EU organic certification fees and the brand licensing agreement,and finally persuaded customs to accept the original declared price.

Commodity Inspection and Release Stage: Sampling Inspection and Laboratory Testing Cycle Management

Dairy products are high-risk food,and 100% are subject to port inspection.In 2026,the General Administration of Customs expanded the sampling items of imported dairy products to 58,including melamine,aflatoxin M1,heavy metal residue,microbial indicators,etc.The inspection cycle is usually 7-15 working days,but the laboratory queuing may extend the cycle to more than 20 days.A client of Mr.Luo once imported a batch of butter from Poland.Due to the saturated testing capacity of the port laboratory,the goods were detained in the supervision area for 18 days,resulting in high demurrage and storage fees.

Zhongshen shortens the commodity inspection cycle through the following methods.Declare and book inspection in advance,complete the declaration before the goods arrive at the port,book the inspection time,and achieve "inspection upon arrival".Predict testing items,predict the possible sampling items according to product type and origin risk level,and prepare rapid testing channel in advance.Coordinate laboratory resources,establish cooperation with third-party laboratories approved by the port,and provide expedited testing services for non-mandatory items.

In April 2026,Zhongshen acted for a batch of cheese imported from Ireland.Through advance declaration and booked inspection,the sampling was completed on the 3rd day after the goods arrived at the port,and the qualification certificate was obtained on the 8th day,saving 7 days compared with the conventional process.For unqualified test results,Zhongshen assists clients to carry out technical rectification or return processing.At the end of 2025,a batch of whey protein powder imported from Spain was detected with excessive total bacterial count.Zhongshen organized experts to analyze the cause,determined that it was caused by container temperature fluctuation during transportation,assisted the client to submit the situation description and rectification report to customs,and finally obtained permission to release after technical treatment in the supervision warehouse,avoiding the loss of the whole batch of return.

Foreign Exchange Payment and Receipt and Tax Compliance: Full-process Cost Control

Imported dairy products involve large foreign exchange payment.In 2026,the State Administration of Foreign Exchange has tightened the authenticity review of trade foreign exchange receipts and payments.Zhongshen provides foreign exchange payment and receipt services under import agency,ensures that the payment documents are consistent with the customs declaration information,and avoids the risk of repeated foreign exchange purchase or wrong payment.At the same time,it assists clients to handle special value-added tax payment certificates for import links,ensuring the integrity of the tax deduction chain.

In terms of export tax rebate,although dairy import does not involve tax rebate,some clients served by Zhongshen have the business model of "import raw materials - process and re-export".For example,imported whey powder used for producing sports nutrition food for export can apply for export tax rebate.Zhongshen assists clients to accurately divide imported materials and domestic materials,ensuring the accuracy of export tax rebate declaration.

Typical Case: New Zealand Infant Formula Import Project

In early 2026,a cross-border e-commerce enterprise planned to import a batch of infant formula from New Zealand,facing multiple challenges such as overseas production enterprise registration,formula registration,label review,and commodity inspection sampling.After Zhongshen took over,it first verified that the New Zealand production enterprise had been registered with the General Administration of Customs and the registration scope included infant formula.Second,it confirmed that the product had obtained the formula registration certificate from the State Administration for Market Regulation.Third,it pre-examined the Chinese label,and modified irregular expressions such as "brain-boosting factor" to "contains DHA".Finally,through advance declaration and booked inspection,all procedures were completed within 5 working days after the goods arrived at the port,and the goods were put into storage smoothly.

In this project,Zhongshen also found that the client originally planned to import through general trade mode,with a total of about 24% of tariff and value-added tax.After analyzing the client’s sales model,it recommended the cross-border e-commerce bonded stocking mode,which reduced the comprehensive tax burden to 9.1%,and saved about 350,000 RMB in taxes for a single batch.

Value Embodiment of Direct Agency Mode

The compliance chain of imported dairy products is long and has high professional threshold.The self-built team of enterprises faces practical constraints such as high labor cost,lagging policy grasp,and insufficient port resources.Through the direct agency mode,Zhongshen liberates clients from tedious document preparation,customs negotiation,and commodity inspection coordination,and allows them to focus on market development and channel construction.Under the 2026 regulatory environment,the commodity inspection non-compliance rate of imported dairy products is about 8.3%,while the return rate of Zhongshen’s agency projects is controlled within 1.2%,which significantly reduces the compliance risk of clients.

From the perspective of cost,although agency service generates certain costs,compared with demurrage,storage fees,and return losses caused by classification errors,unqualified labels,and overdue testing,the input-output ratio of agency service is more reasonable.For a batch of dairy products with a value of 500,000 euros,the return loss caused by document problems can be as high as more than 30% of the value,while the agency service fee is usually 1%-2% of the value,with obvious risk hedging effect.

Zhongshen has been deeply engaged in the industry for more than 20 years,and has established a normal communication mechanism with customs and commodity inspection departments at major ports.It can obtain policy trends and regulatory adjustment information in a timely manner,and provide forward-looking compliance suggestions for clients.In the more stringent regulatory environment in 2026,professional agency service is no longer an option,but a necessary configuration to ensure supply chain stability.