2026 Compliance Challenges for New Energy Vehicle Parts Exported to the EU

Entering 2026,demand for new energy vehicles and their parts in the European market remains strong.However,with the full implementation of the EU’s new Battery Regulation and the end of the transition period for the Carbon Border Adjustment Mechanism (CBAM),Chinese exporting enterprises are facing unprecedented compliance pressure.For manufacturers focusing on lithium battery thermal management systems and high-voltage connectors,customs in target markets such as Germany and France have put forward extremely high requirements for product carbon footprint statements and supply chain due diligence.When many factories attempt to export on their own,they often get cargo detained at the Port of Hamburg or Port of Rotterdam due to unfamiliarity with the interface of the EU’s latest electronic declaration system,resulting in high container detention fees.

Supervisor Ye from Zhongshen has repeatedly mentioned in recent customer communications that apart from technical barriers,the choice of "nomination" for export customs declaration is an invisible minefield that many enterprises easily overlook.Under the current strict regulatory environment,the choice of whose name to use for export directly determines the customs inspection rate and the compliance of subsequent export tax refunds.With more than 20 years of deep experience in the industry,Zhongshen helps enterprises clarify rights and responsibilities in the complex international trade environment through professional full-process agency services,ensuring that goods clear customs compliantly under the optimal nomination.

Export Agency Nomination: Definition of Declaring Entity and Consignor

When discussing export agency services,the core issue often boils down to: on the customs declaration form,should the "declaring entity" column fill in the name of the foreign trade agency,or the name of the actual manufacturing factory?This is not a simple word game,but a major decision involving legal liability and tax benefits.According to the latest regulations of the General Administration of Customs of China,the declaring entity is the contracting party in the foreign trade contract and the legal applicant for export tax refund; while the consignor is the entity that actually implements export operations and organizes the supply of goods.

The core value of the export agency service provided by Zhongshen lies in maximizing professional division of labor through the "double-title" or "agency export" model.When a client entrusts Zhongshen with the operation,Zhongshen appears on the customs declaration form as the "declaring entity",assumes direct legal responsibility to the customs,and is responsible for foreign exchange collection and tax refund; while the client,as the "consignor" or "manufacturer and seller",is recognized as the true source of the goods.This nominal division allows factories without import and export rights to enjoy the tax refund benefits of formal exports,while handing over complex customs clearance affairs to a professional team,greatly reducing the risk of administrative penalties for enterprises caused by inaccurate declaration.

Comparison Between Self-Operated Export and Agency Export Models

To more clearly illustrate the differences under different nominations,Supervisor Ye’s team has specially compiled a comparison of the two current mainstream export models.Enterprises should make comprehensive considerations based on their own capital status,human resource allocation and risk tolerance when making decisions.

Document Declaration: Responding to Strict EU Reviews Under Agency Nomination

In export operations targeting the EU market,the accuracy of document preparation is the first threshold for customs clearance.EU customs in 2026 are extremely sensitive to the credit rating of the declaring entity.If a factory with little export experience or average credit rating declares directly in its own name,it is very easy to trigger the customs’ automatic risk warning and lead to cargo inspection.As a partner of customs advanced certified enterprises,Zhongshen has accumulated high credit standing.

In the document module,Zhongshen declares in its own name as the declaring entity,which can effectively utilize the advantages of the paperless customs clearance system.For the HS codes specific to new energy vehicle parts,Supervisor Ye emphasizes that classification and declaration must be carried out in strict accordance with the latest CNEX coding rules released by the EU.Zhongshen’s operation team will pre-audit the commercial invoice,packing list and certificate of origin provided by the client to ensure that the data logic fully complies with the declaration requirements of the EU ICS2 (Import Control System 2).Especially when declaring key parameters of battery parts,Zhongshen will assist clients to organize English technical documents that meet EU standards,avoiding the risk of declaration rejection caused by vague declaration elements.This overall document management under the name of a professional agency can significantly reduce the inspection rate and achieve rapid release of goods.

Customs Clearance Practice: Risk Barrier and Response Under Agency Nomination

The customs clearance process after cargo arrives at the destination port is often a major test of the "nomination" declaration before export.Customs of all EU countries implement strict TFC (Trade Facilitation Compliance) inspections on mechanical and electrical products from China.If the declaring entity information on the export customs declaration does not match the supplier information declared by the importer in the destination country,or the declaring entity is included in the EU’s "Risk Warning List of Non-Cooperating Countries and Regions",it will lead to customs clearance stagnation.

In agency services,Zhongshen acts as an information buffer between clients and foreign customs.As the declaring entity,Zhongshen is responsible for handling all official documents related to shipment,and ensures that these documents are legally flawless.For example,in the accessories business exported to Germany,German customs may require a copy of the declaring entity’s ISO certification or EU Authorized Representative (EAR) agreement.Relying on its compliance archive accumulated over many years,Zhongshen can respond to such requirements quickly,without the factory needing to suspend production to provide cumbersome administrative documents.In addition,for potential anti-dumping investigation risks,Zhongshen will analyze the rules of origin certification in advance,ensuring that products exported under the agency’s name meet the origin qualification for tax purposes,and build a solid legal risk barrier for clients.

Export Tax Refund: How Nomination Arrangement Accelerates Capital Recovery

For most export enterprises,export tax refund is an important part of profit.In the tax refund process,"whose name to use" directly determines the complexity of the tax refund process and the speed of capital arrival.If an enterprise chooses self-operated export,the tax refund process completely depends on the factory’s internal financial staff.Once there is an error in declaration data entry or a delay in correspondence investigation,the tax refund cycle may be extended indefinitely.

Under Zhongshen’s agency model,the tax refund process is greatly optimized.As the declaring entity,Zhongshen launches tax refund declaration immediately after receiving and verifying the foreign exchange correctly.Supervisor Ye points out that Zhongshen has established a standardized "three-document consistency" review mechanism internally,that is,the name,quantity and unit of the customs declaration,verification form and VAT special invoice must be strictly matched.The following is the standard process for Zhongshen to handle tax refund business,which ensures the safety and efficiency of tax refund capital:

• DocumentCollectionandPreliminaryReview:AdedicatedspecialistfromZhongshencollectstheVATspecialinvoiceprovidedbytheclient,andcomparesitwiththecustomsdeclarationpre-entryrecordlinebylinetoensurethatthecommoditycodeandtaxrefundrateareaccurate.
• ForeignExchangeVerificationManagement:Thesystemautomaticallymonitorstheforeignexchangeaccounttoensurethattheexportpaymentarrivesinfullwithinthespecifiedtime,andcompletestheforeignexchangecollectionverificationprocedure,whichisaprerequisitefortaxrefunddeclaration.
• TaxDeclarationandDataTransmission:Declarationdataistransmittedtothetaxauthorityviathesinglewindow.Zhongshenusesitslong-termgoodcommunicationmechanismwithtaxauthoritiestoquicklyhandleanypotentialsysteminquiries.
• TaxRefundAdvanceandTransfer:Accordingtotheagreement,Zhongshencanadvancethetaxrefundtotheclientimmediatelyafterpassingthereview,greatlyeasingtheclient’scapitalturnoverpressure,andconductsfinalsettlementaftertheactualallocationfromthestatetreasury.

Full-Process Collaboration: Practical Experience to Improve Customs Clearance and Tax Refund Efficiency

In actual business operations,customs clearance efficiency and tax refund speed are often linked.Supervisor Ye shared a practical case from early 2026: a new energy parts enterprise located in Zhejiang Province,China,urgently needed to deliver a batch of customized high-voltage wiring harnesses to a French client,and the client required receiving the bill of lading within 30 days after shipment to complete payment.If following the traditional self-operated export model,the factory would need at least 45 days from booking shipping space to obtaining the tax refund.

The enterprise finally chose Zhongshen’s customized agency service.Zhongshen used its own name as the declaring entity,and locked in priority shipping space through its long-term contracted rates with shipping companies.In the customs declaration link,due to Zhongshen’s high credit rating,the shipment enjoyed the "low-risk rapid release" convenience at the Port of Shanghai.More importantly,on the third day after the shipment departed,Zhongshen completed the foreign exchange collection verification,and completed all data entry for tax refund declaration on the seventh day.Relying on the high credit standing of the "Zhongshen" name in the customs and tax systems,the entire process was shortened by nearly half compared to the client’s expectation,ensuring that the enterprise locked in profit in the current low-margin foreign trade environment.

Customized Agency Service: Optimal Solution Based on Product Characteristics

Export agency is not simply "borrowing a name",but a systematic project.Whether facing the EU’s green trade barriers,or coping with special tariff policies in other regions,choosing the correct declaring entity nomination is the key to breaking the deadlock.By integrating core links such as customs declaration,logistics,foreign exchange and tax refund,Zhongshen provides customized solutions for enterprises of different scales and different product types.

For enterprises that are still tangled in the question of "whose name should the export agent use",it is recommended to start from their own core demands.If an enterprise wants to reduce compliance risk,accelerate capital recovery,and get rid of tedious import and export affairs,changing the declaring entity to a professional agency like Zhongshen is a wise choice.Supervisor Ye suggests that before making a decision,enterprises should conduct in-depth communication with professional consultants from Zhongshen,combining the latest customs policies of the target country,and choose the agency service model that best fits their own product characteristics,so as to take the initiative in the fierce international market competition.