Core Basis for Classification

Key Declaration Elements

Due to the functional diversity of smart devices, classification needs to be combined with the core functions and technical characteristics, mainly involving the following HS codes:

• 8517.62.00Smartphones, smart watches (with communication functions)
• 8543.70.90Smart home devices (such as smart speakers, smart lights)
• 9031.80.90Smart sensors (temperature and humidity, motion sensors, etc.)
• 8471.30.00Industrial intelligent terminals (including edge computing modules)

Examples of breakdown by major countries/regions:

II. Full - process and Function Analysis of Smart Device Export Agency Services

• Function definition:
  Whether it has data processing capabilities (such as equipped with an AI chip)
  Whether it supports wireless communication (Bluetooth/Wi-Fi/5G)
• Technical parameters:
  Computing power (e.g., if NPU computing power ≥ 4 TOPS, special declaration is required)
  Storage capacity (if ≥ 128GB, consumer - grade/industrial - grade needs to be distinguished)

Technical Compliance Pre - review

II. Smart devicesExport RepresentationAnalysis of the whole service process and its functions

Special Logistics Solution Design

• Export control screening:
  The agent checks whether the equipment involves encryption technology (e.g., if SSL/TLS algorithm is used, it needs to match ECCN 5A002) and assists in applying for the Commercial Cryptography Export License.
• Data security compliance:
  Identify whether the equipment complies with the data regulations of the destination country (such as EU GDPR, Chinas Measures for the Security Assessment of Cross - border Data Transfers).

Export Control and Customs Declaration Key Points

• Core document listSpecial requirements for document types: The commercial invoice indicates the MAC address and IMEI number of the equipment (communication equipment), and the packing list marks the electromagnetic interference shielding measuresIt is recommended to verify through the following methods:Apply for the China - ASEAN Free Trade Area Form E tariff reduction
• Boundary of certification supportCertification type, scope of agency services: FCC certification (USA), guide pre - review test reports (Part 15B electromagnetic compatibility); CE - RED (EU), assist in preparing technical documents (including radio frequency parameter test data); SRRC certification (China), connect with the laboratory designated by the Ministry of Industry and Information Technology to complete type approval

III. High - risk Control and Precautions

• Transportation specifications for high - value equipmentRisk type, protective measures: Electrostatic damage, anti - static packaging + humidity control (40% - 60% RH); Data leakage, full - disk data erasure before transportation (in line with NIST 800 - 88 standard); Theft risk, GPS tracker + full - process armed escort (single - ticket value ≥ $500,000)
• Special insurance clauses:
  Add the data recovery insurance to cover the database reconstruction costs caused by equipment loss
  Exclusion clause: Leakage of sensitive information caused by the failure to enable hardware encryption

Technical Compliance Risks

• Verification of sensitive technologies:
  • Check whether the equipment has the following restricted functions:
    • End - side AI training capabilities (such as supporting TensorFlow Lite)
    • Military - grade encryption algorithms (such as AES - 256)
• Infrared thermal imaging function (resolution ≥ 320×240)
  If the above functions are involved, submit the Statement of End - User and End - Use to the Ministry of Commerce
• Key points of customs price review:
  Separate declaration of software license fees (such as pre - installed professional version of the operating system)
  Tax treatment of OTA service fees (declared as royalties or technical service fees)

Transportation and Customs Clearance Risks

Intellectual Property Protection Measures

• Lack of wireless certification: Mandatory certification test items for target markets. For the United States, FCC ID RF radiation, SAR value; for the European Union, CE - RED radio frequency bandwidth, spurious emissions; for Japan, TELEC certification for specific low - power wireless devices
• Cross - border data violation:
  • When exporting devices with face recognition functions to the European Union, the default biometric templates need to be deleted
  • When exporting devices to Russia, local encryption modules (such as the Russian GOST algorithm) need to be pre - installed

IV. Typical Cases and Solutions

• Technical barriers in the destination: Special requirements of countries/regions. For Brazil, ANATEL certification requires radio frequency compliance testing in local laboratories. For India, WPC certification for 2.4GHz/5GHz band devices requires separate approval. For Saudi Arabia, SASO certification requires an Arabic - language user agreement + proof of compatibility with the Islamic calendar
• Return transportation emergency plan:
  1. Enable the bonded maintenance mode for firmware upgrade
  2. Replace the certification label through an overseas warehouse (such as affixing the CE mark)
  3. Apply for temporary customs storage to avoid the accumulation of warehousing fees

V. Industry Trends and Early Warning Items (Updated in 2024)

• To be completed before export:
  Obfuscation processing of firmware code (such as using Arm Compiler for encryption)
  Anti - cloning processing of hardware design (add a physical unclonable function PUF chip)
  Sign an NDA agreement to restrict overseas distributors

Dynamics of International Regulations

Case 1: Incomplete FCC certification led to the seizure of goods by the US Customs
A company exported smart door locks to the United States and was seized due to incomplete FCC Part 15C testing. Emergency handling by the agent:

1. Coordinate with the UL laboratory to expedite the radiation disturbance test
2. Submit an electronic record of the test report to the US Customs
3. Enable the temporary release procedure with a security deposit
   Finally, the customs clearance was completed within 48 hours, avoiding a demurrage fee of $5000 per day

Case 2: Data compliance triggered an EU investigation
Smart cameras exported to Germany were investigated by GDPR due to the default activation of face recognition. Remedial measures by the agent:

1. Urgently push a firmware update to turn off the biometric function
2. Hire an EU - certified DPO (Data Protection Officer) to issue a compliance certificate
3. Reach a settlement agreement with the regulatory agency (a 70% fine reduction)

Upgrade of Regional Technical Barriers

Green Compliance Pressure

• EU AI Act (EU) 2024/0012:
  High - risk AI devices (such as medical diagnostic robots) need to pass third - party conformity assessment
• Expansion of the US Chip Act:
  Smart devices using advanced - process chips (≤7nm) need to apply for a special license from BIS

Due to the functional diversity of smart devices, classification needs to combine the core functions and technical characteristics, mainly involving the following HS codes:

• Localization requirements in Southeast Asia:
  Thailands TISI mandates an energy efficiency label for smart home appliances (5 - level standard)
  Vietnam requires smart devices to pre - install local - language voice assistants
• African Cybersecurity Law:
  The African Union has adopted the Cybersecurity Convention for Smart Devices, mandating that devices support local data storage

Green Compliance Pressure

• Energy efficiency label:
  When exporting metal jewelry to the EU, especially during sample customs clearance, the requirements are often diverse. Especially in the current international environment, the EU has carried out more reviews and supervision of the origin of raw materials. The non - Russian material declaration you mentionedThe energy efficiency class according to the ERP directive needs to be provided (for example, smart lamps should be at least Class B)
• Circular economy:
  Frances EPR regulations require producers of smart devices to bear the recycling costs (charged by weight)