Webinar: “Belgian Customs and its activities in China” – 16 October 2025

The Flanders-China Chamber of Commerce (FCCC) organized a webinar focused on 'Belgian Customs and its activities in China' on 16 October 2025.

Ms. Gwenn Sonck, Executive Director, Flanders-China Chamber of Commerce, introduced the topic and the speakers. Mr. Emmanuel Geronnez, the Customs Attaché at the Embassy of Belgium, who was appointed to his post in Beijing earlier this year, and Mrs. Annabel Schreiber, the Agricultural Attaché. Doing business has become more complex. Shifting alliances, evolving supply chains, rising trade tensions, and recent tariffs, have all made the landscape more challenging. According to a recent survey of European companies in China, more and more firms are now onshoring also their operations within the country. China is a fast-changing market, and that's why it's important to respond quickly and flexibly to new opportunities and challenges as they come up. Understanding the Chinese market is absolutely essential for success. According to a new global ranking of 139 economies by the World Intellectual Property Organization, Germany is no longer among the 10 most innovative countries in the world. It is China that has taken its place, and that's one of the reasons why more and more of our companies are in China to be part of its strong drive for innovation. So, to be successful, companies need to adapt and update their China strategies proactively and in a timely manner.

Mr. Emmanuel Geronnez, Customs Attaché in Beijing, gave a presentation on Procedures and regulations of the Chinese customs and other institutions related to import or export. There has been a Custom Attaché in China since 2008, the very beginning of the program, because China is a very important partner. The Customs Attaché in China is covering also Hong Kong and Macao. We try to nurture strong ties with the local customs administration, and we have a strong focus on the facilitation of legitimate trade. The current Customs Attaché is your servant to help individuals, but also economic operators with customs-related operations. We provide technical information about procedures, duties, taxes, and so on. We also try to assist whenever you have an emergency and a blocked shipment, for example. We cooperate with the Belgian representation in China, meaning, for example, Flanders Investment and Trade and AWEX, but also with the Ministry of Foreign Affairs that's coordinating all the efforts. We can play the intermediary for you with the Chinese Customs whenever you have questions, issues, and so on. What we will not do is be your lawyers, of course, and we will not act as your Customs brokers, and for example provide you with a Chinese commodity code. Our local counterpart is the General Administration of Customs of China (GACC). The Customs Attaché also takes part in trade missions, Mr. Geronnez explained.

The Customs Attaché also fights against fraud and illegitimate trade in order to ensure a level playing field for economic operators and against drug smuggling and so on. There are two very important instruments with China: the Mutual Administrative Assistance Agreement between the EU and China that is very useful, and also the Mutual Recognition of Authorized Economic Operators. Mr. Geronnez said he noticed when he arrived in March this year, the deep digitalization in the country. Everything goes through internet, and therefore, China also has a very developed cross-border e-commerce going from China and to China. This is the main market for the live streaming e-commerce, which is something we don't know really well in Europe. But in China, this is very important. There are very innovative and emerging industries with a lot of creativity. Whenever it comes to investments, import, export, or sourcing your products to China, it often involves a custom aspect.

There are some very important attention points in China. In China, everything has to be done by the book. Do not think that you can make a small mistake in a declaration and correct it later. It doesn't work that way. Here, the information and the prevention are of the essence, and there are other things that should not be overlooked, like the language and cultural barriers. Another attention point are the procedures before import and at the border. A simple example of that is the registration you need. If you are a food manufacturer, you need to register at the GACC and make sure you have all the necessary documentation before you arrive at the border. Another important issue is the fast changing legislation, especially on export control. The Chinese Customs are a very important partner because they act as a true gatekeeper. Actually, they control all the aspects of customs.

When you look at the figures of the commerce between Belgium and China that are provided by the Belgian Foreign Trade Agency, you can see that China is the 10th client of Belgium and the fifth supplier. The GACC is one of the main and key players you will meet in China whenever you're doing business here. This is a full ministerial level agency directly under the State Council. The Director General of Customs has the rank of a Minister. The commodity code is something very simple, but something very important. These are the building bricks of international trade. Without them, you cannot do anything. The International Harmonized System of the World Customs Organization ensures that the commodity codes of the products in the entire world almost are always the same up to six digits. After the six digits, it will differ, but up to six digits, it will be the same. This is a system that is revised every five years. The last revision was from 2022, and the next one will come in 2027. Since the reorganization in 2018 in China, the Chinese commodity code has 13 digits. So it is important to always check the correct Chinese code.

In China, there is a three-tier tax rate system with three different rates, 13%, 9%, and 6%. These VAT rates on imported goods decreased over the last years. There will be a new VAT law as from January 1, 2026. This new law will modernize the VAT system in China. It will retain the three-tier tax rate system with these three main rates and also clarify the dutiable place of consumption for cross-border e-commerce, which is very useful, and also provide some clarification about dutiable transactions. There is also a consumption tax applicable on particular categories of products, like those that are considered harmful to health, for example, tobacco, or luxury items, or high-end products. Every year you need to check the tariff because it is changing, and you can have regular tariff cuts to show openness or raise consumption. On some raw materials, you will have exemptions of duties and VAT from time to time.

The Chinese compulsory certification (CCC) is the equivalent of the CE certification since 2002 and is mandatory for roughly 150 types of products or voluntarily in order to give confidence about your products on the market. This is valid for five years. In 2024, there was a new customs tariff law that entered into force on December 1, 2024 and is a consolidation of the rules and the regulations that existed before into one single administrative law. It enhances the government's power to impose retaliatory tariffs and introduced the notion of tariff withholding obligations for some cross-border e-commerce platforms, new customs law penalties, and criminal offenses for customs law violations. It clarified the rules of origin in China and strengthened the intellectual property protection. It also extended the period for tax refunds and back duty.

The hot topic of 2025 is export control. This is not something completely new. It started in 2020 with the new export control law. In 2023, there was a licensing requirement that was introduced for gallium and germanium. Then, in 2024, you had licensing requirements for drones and their equipments, but also antimony and ultra-hard materials. In 2025, we see that everything has sped up. Almost every month, we have new rules, and everybody has heard that on April 4 China announced a licensing requirement for seven rare-earth elements. So, you have to know that China is the global leader for rare-earth production, extraction, and processing, and therefore, they are unavoidable. On June 16, you had the announcement that introduced the Customs Challenge for Dual-Use Items Export Control, a procedure during which GACC will challenge companies whenever they try to export goods and they are unsure if they fall under the export control list or not, the licensing requirements. It will open a procedure that lasts seven days to provide information to the GACC in order to convince them that the goods are not under the licensing requirements. You can end up in three different situations. The first one would be that they conclude that the goods are not submitted to licensing requirements. The second is that you need to apply for a license. The third one is that they are unsure and then you have an appraisal period that begins and you need the opinion of an expert of the Ministry of Commerce (MOFCOM). On October 9, MOFCOM introduced new obligations and rules concerning five additional rare earth elements and licensing requirements for some technologies that are related to rare earths, mining, smelting, separating, refining, manufacturing, and recycling. Finally, whenever you have a transaction overseas between two foreign companies, and the items that are traded contain Chinese rare earths, accounting for 0.1% minimum of the total value of the finished item, then a license is also required, but nobody knows so far how it will be applied. But it is important to know that the context is getting more stringent. It is important to foresee enough time for the different procedures and applications, and for the licensing with MOFCOM. If you have a problem with the Chinese Customs or MOFCOM to get a license, please inform the Belgian Emabssy. “Sometimes we can help, sometimes we cannot, but at least we'll have a better understanding of the situation,” said Mr. Geronnez.

Ms. Annabelle Schreiber, Agricultural Attaché, Embassy of Belgium in China, introduced the Support given by the Federal Agency for the Safety of the Food Chain (FASFC) to local companies when exporting to China. FASFC integrates all control services that are competent for the entire food chain. The FASFC is not only competent for controlling food, feed, fertilizers and phyto-pharmaceuticals, but it is also responsible for sanitary and phytosanitary prevention and control measures. FASFC is also in charge of the implementation of European legislation in Belgium, like the official controls regulation, the animal and plant health laws, and to lay down operational rules on controls, certification, infrastructure standards to be complied with by food chain operators. FASFC is also competent for the import checks at the different ports and airports, for instance, in Antwerp, Ostend, Zaventem, Bierset and Gosselies. The type of border checkpoints depend on the animals or products imported into Belgium. The FASFC is also the competent authority for issuing export certificates for all commodities within the entire food chain, including live animals, plants, animal feed and all kinds of food. It also controls the exported goods and accompanying documents depending on the risk presented by the consignment to be certified and the requirements applied by the importing country. The three main departments involved in export are the local control units, the notification and certification cell, and the international affairs department. Export certification is carried out by FASFC certifying agents from one of the nine local control units. This certifying agent verifies that the exporting establishment and the exported goods comply with all the requirements of the EU food law and with the specific requirements of China. The international affairs department, the experts and the Attaché in China make specific trade agreements to clarify certification requirements for the exporting operators and for the FASFC certifying agents. For instance, this year FASFC published updated instruction manuals for dairy products, pork meat, pet food, mineral feed, feed additives and premix.

FASFC opened its office in Beijing at the Belgian embassy in 2021. It is the only FASFC office abroad. Mrs. Schreiber arrived in 2021 and focuses on all matters related to sanitary and phytosanitary measures, which means dealing with everything linked to food safety, animal and plant health that are absolutely essential for international trade and consumer protection, but she doesn't cover pure agricultural or economical aspects, which are the competence of the region. The Agricultural Attaché's mission is to act as a bridge between Belgium and China on SPS topics, helping both sides to communicate effectively, solve technical issues and develop strong cooperation. The goal is to facilitate smooth and safe trade between the two countries, ensuring that Belgian products reach the Chinese market while fully complying with Chinese regulations. A large part of the job is to support market access for Belgian agri-food products. That includes coordinating the negotiation and implementation of export protocols and MOU, following up inspections and audits, and ensuring that all requirements are met for all kinds of products.

This year, two protocols were signed, one for pork meat and by-products and another one for pet food. The role of the Attaché is also to negotiate to lift the ban related to animal disease, for instance, HPI, Newcastle disease, BSA, and so on. Each of these requires close coordination between the FASFC, the Embassy, and Chinese authorities to make sure the right procedures are in place and the trade can flow safely. Negotiation on sanitary and phytosanitary import conditions are extremely lengthy procedures. To open a new market actually needs years. Mrs. Schreiber is also assisting Belgian companies with the CIFER platform, the Chinese online system used for registration of foreign food establishments. This year it represents close to 100 cases.

A Q&A session concluded the webinar.

Interested to obtain the PTTs, please send an e-mail to info@flanders-china.be