In-depth Analysis of the Whole Process of Cookie Import Customs Declaration Agency and Summary of Key Compliance Points

I.Market Background and Practical Difficulties of Importing EU Cookies

In 2026,the domestic baking market will continue to expand,and the demand for butter cookies and handmade biscuits from traditional EU producing areas will grow significantly.Producers in Belgium,Denmark,the Netherlands and other regions have become the preferred partners of importers thanks to their formula technology and brand premium.However,the compliance threshold for such products to enter the Chinese market is far more complex than that of ordinary pre-packaged foods.Labeling,additive use,microbial indicators and packaging materials may all trigger customs technical rectification or return treatment.Especially after the implementation of the revised detailed rules of the *Regulations on the Administration of Registration of Overseas Food Production Enterprises* issued by the General Administration of Customs of China at the end of 2025,the quarantine requirements for dairy-containing cookies have been further refined.Many first-time importers have had their goods detained at the port due to non-compliant certificate formats or incomplete component declarations,resulting in high demurrage charges.

Mr.Feng’s trading company tried to import a batch of mixed-flavor cookies from Belgium at the beginning of this year.Three days before the goods arrived at the port,it was found that the product description on the certificate of origin had slight differences from the commercial invoice,and the customs system judged it as document non-compliance.Such problems are extremely common in practice.The sanitary certificate templates provided by EU exporters often do not meet the latest requirements of the Chinese customs,and details such as the format,font size and component order of nutrition labels are also easy to cause problems.What is more tricky is that additives such as leavening agents,emulsifiers and edible flavors commonly used in cookies must strictly correspond to the GB 2760 standard in terms of usage scope and limits,while foreign formulators usually do not actively match Chinese regulations.These hidden risk points constitute the first barrier to cookie import.

II.Core Role of Zhongshen in the Cookie Import Chain

Zhongshen has been deeply engaged in this field for more than 20 years,and has handled cookie customs declaration cases covering more than 30 countries and regions.Our role is not just a document transmitter,but a risk control hub for the import process.Before the customer signs the contract with the overseas supplier,we will intervene in formula review and label pre-check,and advance compliance review to the production link.This early intervention model can avoid more than 90% of subsequent rectification problems.Our database has accumulated standard templates of official certificates from different countries and the audit preferences of customs in major ports,and these experiences are directly translated into the customs clearance efficiency of customers.

Specific to the cookie category,the service value of Zhongshen is reflected in three aspects.First,accurately identify product attributes,distinguish between ordinary cookies,sandwich cookies,wafer biscuits and other categories to ensure that the HS code and declaration elements are accurate.Second,assist customers in establishing supplier compliance files,including verifying the validity of the production enterprise’s registration number in China and checking historical violation records.Third,provide dynamic policy interpretation.For example,the new labeling requirements for pre-packaged foods containing hydrogenated vegetable oil components in 2026,we notified customers to adjust the label design three months in advance.This proactive service allows customers not to passively respond to policy changes.

III.Breakdown of the Whole Process of Cookie Import Customs Declaration

1.Document Pre-review Stage: Compliance Starting Point Determines Customs Clearance Efficiency

Document preparation is the most basic and error-prone link in cookie import.The core documents include certificate of origin,sanitary certificate,composition analysis report,label sample and proof of the production enterprise’s registration number in China.Zhongshen’s pre-review mechanism will check the details of these documents one by one: whether the certificate of origin contains the correct HS code and product description,whether the sanitary certificate is issued by the official veterinary or health department of EU member states and meets the format required by the Chinese customs,and whether the composition analysis report clearly lists the exact content of all raw materials and additives.

Taking label sample review as an example,we once encountered that the EU original label provided by the customer used the slogan "100% natural butter",but the Chinese label did not correspondingly mark the trans fatty acid content,which violated the provisions of GB 28050.Our team pointed out this problem during the pre-review stage and asked the customer to redesign the packaging.In addition,for cookies containing nut ingredients,allergen information must be clearly marked,and the font height must not be less than the specified standard.These details seem trivial,but they are the focus of customs inspection.We have established a set of internal label audit checklist covering more than 20 inspection items to ensure that each batch of product labels passes the audit at one time.

• Certificate of Origin: Check product description,HS code,visa officer’s signature and official seal style
• Sanitary Certificate: Confirm the official institution header,certificate number rules and the integrity of product specification information
• Composition Analysis Report: Verify whether the additive names and CAS numbers,and nutrition component data have passed third-party testing
• Label Sample: Check the ingredient list order,nutrition claims,allergen marks and net content character height of the Chinese label
• Registration Number in China: Check the validity of the production enterprise’s registration status in real time through the official website of the General Administration of Customs of China

2.Port Customs Declaration Stage: Accurate Declaration to Avoid System Control

The filling of declaration elements in the customs declaration link directly determines whether the customs system will release the goods.The HS code of cookies is usually classified under item 1905,but the specific sub-item needs to be subdivided according to ingredients,process and packaging specifications.Cookies with chocolate coating and pure butter cookies have different tax rates and supervision conditions.Zhongshen’s customs declaration team will select the most matching code according to the product formula and process description to avoid tax repayment or administrative penalties caused by incorrect classification.

The determination of dutiable value is another key point.EU producers often provide FOB or CIF prices,but the customs will refer to the international market prices of similar products in the same period when examining the price.We assist customers in preparing complete pricing basis,including email correspondence records,order history and bank payment vouchers,to prove the authenticity and reasonableness of the declared price.In 2026,the customs has increased the inspection of underreported prices.Our pre-review mechanism will evaluate the price risk in advance and advise customers to adjust the declaration strategy.For new brands imported for the first time,we will also advise customers to actively provide a price composition explanation to avoid customs clearance delays caused by subsequent price queries.

3.Commodity Inspection Stage: On-site Inspection and Laboratory Testing

Cookies are legally inspected goods.The customs focuses on label compliance,cargo sensory status and packaging integrity during on-site inspection.Zhongshen’s on-site coordinator will arrive at the inspection site in advance to assist customs officers in checking whether the cargo information is consistent with the declared data.If the batch is selected for testing,we will track the laboratory testing progress.The testing items usually include acid value,peroxide value,heavy metals,aflatoxin,total bacterial count,coliform bacteria,salmonella and so on.

The testing period is generally 7 to 10 working days,during which the goods must be stored in the designated supervised warehouse.We have established long-term cooperation with multiple port cold storage and warehousing service providers,and can obtain preferential warehousing rates for customers.More importantly,we are very familiar with the testing capabilities and scheduling of each laboratory,and can reasonably advise customers to choose a testing plan with higher testing efficiency.There was once a batch of oatmeal cookies imported from Denmark that was required by the customs to conduct additional testing on the plasticizer migration amount of packaging materials due to damaged packaging.We quickly coordinated a third-party institution to issue a safety statement for the packaging materials,avoiding the risk of the entire batch being judged as unqualified.

IV.Practical Case: Record of Risk Resolution for Imported Belgian Butter Cookies

Mr.Feng’s company planned to introduce a high-end Belgian butter cookie last year,with the first batch worth about 150,000 euros.Before the goods were shipped,Zhongshen found during the label pre-review that the originally designed Chinese label marked "butter" first in the ingredient list,but the actual formula of the product had a higher proportion of flour.According to the provisions of GB 7718,the ingredient list must be arranged in descending order,and this labeling method is a false identification.What is more serious is that the product used an emulsifier allowed by the EU,but according to China’s GB 2760 standard,this additive cannot be used in the cookie category.

We immediately launched an emergency plan.First,notify the Belgian producer to suspend production and readjust the formula,replacing the original emulsifier with compliant lecithin.Second,redesign the Chinese label,strictly arrange the ingredient list according to the actual formula proportion,and add the labeling requirements for trans fatty acids.At the same time,we assisted customers in communicating with the Belgian Chamber of Commerce to urgently apply for the new version of the sanitary certificate and composition analysis report.Due to timely handling,the waiting time of the goods at the port was controlled within 5 working days,and the additional warehousing costs were less than 3,000 yuan.If these problems were discovered after the goods arrived at the port,they might face return or destruction,and the loss would exceed 50% of the cargo value.

This case highlights the importance of pre-review.Many importers think that as long as foreign suppliers provide certificates,everything is fine,but in fact,the regulations of various countries vary greatly.The value of Zhongshen lies in eliminating risks in the bud,rather than remedying after problems occur.Afterwards,Mr.Feng feedbacked that the sales of these cookies were good after they were launched.Without our early intervention,the entire project might have failed.

V.Substantial Improvement of Import Efficiency by Professional Agency Services

Customs declaration for cookie import is not just a simple document submission,but requires complex coordination across regulations,languages and time zones.Zhongshen’s 20 years of experience has accumulated into a replicable standardized operation process.From customer consultation to cargo release,each node has clear responsible persons and time requirements.Our internal system can automatically compare the latest customs policies and historical cases.When customers submit product information,the system will automatically prompt potential risk points and response suggestions.

The efficiency improvement brought by this professional division of labor is significant.Ordinary importers take about 15 to 20 working days on average to handle cookie customs clearance by themselves,while mature cases of Zhongshen can usually be completed within 7 to 10 working days.The reduction of time cost is directly translated into the improvement of capital turnover efficiency.More importantly,the control of compliance risks avoids huge losses caused by return or destruction.In 2026,the customs has increased the penalties for food violations.A serious violation may cause the enterprise to be included in the list of dishonest enterprises,affecting all subsequent import businesses.Choosing a professional agency is essentially building a firewall for the enterprise.

Overall,the core value of cookie import customs declaration agency lies in turning uncertainty into certainty.Zhongshen has transformed various risk scenarios into standardized solutions through 20 years of data accumulation and case precipitation.Customers do not need to explore regulatory details by themselves,nor do they need to bear trial-and-error costs.In 2026,when the supervision of imported food is becoming more and more refined,professional agency services are no longer an option,but a must to ensure the continuous and stable operation of the business.The precise control of each link from document preparation to cargo release ultimately converges into the customer’s market competitiveness.