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Documents for Importing Machinery from China

1. What differs from general goods

Machinery imports add four document categories to the ordinary set.

Technical documentation.

Conformity certification.

Installation and commissioning documents.

Spare parts and warranty terms.

2. The ordinary set

Commercial invoice.

Packing list, with the machine’s dimensions and weights per unit.

Bill of lading, or for large equipment, the charter party bill or the multimodal document.

Certificate of origin.

3. The technical documentation

Operating manuals.

Electrical diagrams.

Installation drawings.

Maintenance schedules.

Spare parts catalogues.

The destination authority may require these in the local language for regulated machinery.

4. The conformity certification

Most destinations regulate machinery.

European Union

The Machinery Directive, now the Machinery Regulation, requires CE marking.

The conformity route depends on the machine’s risk category: self-declaration for most machinery, notified body involvement for the Annex I high-risk list.

The technical file must be available, and the EU declaration of conformity accompanies the machine.

The United States

OSHA requirements for industrial machinery.

NRTL certification for certain electrical equipment, from a Nationally Recognized Testing Laboratory.

China’s own exports

Machinery exported from China may need a Chinese conformity assessment for the destination, and the exporter’s certificates may be to Chinese standards rather than the destination’s.

5. The pre-shipment inspection

Some destinations require pre-shipment inspection for machinery, verifying the machine’s condition and specifications before shipment.

The inspection certificate is part of the entry set.

6. The electrical and safety documentation

For electrically powered machinery, the destination may require:

Electrical safety certification.

Electromagnetic compatibility documentation.

Radio equipment approval, where the machine contains radio modules.

These are separate regimes from the machinery directive in some jurisdictions.

7. The installation and commissioning

For large equipment, the contract often provides for seller-side installation.

The documents: the installation plan, the commissioning report, the acceptance certificate.

Personnel visas and work permits for the installing engineers, which is a separate and often overlooked requirement.

8. The spare parts question

The entry classification of spare parts differs from the machine’s.

Spare parts shipped with the machine are usually classified with the machine if presented together under GIR 2(a) or, where the machine is complete, separately.

Spare parts shipped later are classified separately.

The documents reference the original machine where the spare parts are for a specific installation.

9. Common errors

No CE or equivalent certification

The machine cannot be placed on the market.

Technical documentation in the wrong language

Required in the destination’s language for regulated machinery.

Classification of the machine at the machine heading

Where the machine is a combination, the classification may differ.

No installation documents

Commissioning delayed.

Spare parts classified as the machine

Separate classification applies.

Overlooking the engineers’ work permits

Installation cannot proceed.

10. Closing view

Machinery is the product category where the documentary burden extends furthest beyond the trade documents, into technical, regulatory and personnel matters.

Exporters who treat machinery like consumer goods discover the gap when the machine arrives.

*This article is based on destination product regulation for machinery, including the EU Machinery Regulation and US requirements, and on standard trade documentation. Exporters should confirm requirements with the destination regulator.*

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