Analysis of Shanghai Imported Paint Agency Process and Compliance Difficulties

In 2026,the demand for imported eco-friendly paints in the Shanghai market continues to rise.The import volume of water-based industrial coatings from Europe and architectural coatings from Southeast Asia increased by 22% and 15% respectively compared with 2025.However,many enterprises encounter obstacles during import: the VOC test report provided by German suppliers does not comply with China’s newly revised 2026 *Limit of Harmful Substances in Interior Wall Coatings for Interior Decoration Materials*,and the hazardous chemical packaging labels of Southeast Asian paints lack Chinese instructions.The document rectification alone took nearly two weeks.Behind this are the unique compliance thresholds and process difficulties for imported paints.

Zhongshen,which has been established for more than 20 years,has long been familiar with every "obstacle" of imported paint at Shanghai Port.Director Lan said that among the imported paint businesses handled by their team last year,80% of enterprises encountered problems at the initial stage due to unfamiliarity with China’s latest compliance requirements.The core role of Zhongshen is to turn these "invisible thresholds" into implementable operation guidelines,and closely monitor every detail from document pre-examination to final foreign exchange settlement.

I.Core Process Breakdown of Imported Paint Agency: From Document Pre-Examination to Final Release

1.Document Pre-Examination: Guard the First Entry Pass

The document requirements for imported paints have 3 more types of core documents than ordinary goods.In 2026,Shanghai Customs added the pre-examination requirement for "Paint Product Risk Assessment Report".Director Lan said that last year,a customer imported art paint from Italy,and only provided commercial invoice and bill of lading at first,missing the EU VOC conformity declaration.If they declared directly,the lightest penalty would be cargo detention for rectification,and the heaviest would be return shipment.

Zhongshen carries out very detailed work in the document pre-examination stage:

• Verify supplier qualifications: Confirm whether it is on the white list of "Recommended Suppliers for Paint Import" of Shanghai Customs (new requirement in 2026);
• Review test reports: Compare with China’s *GB18582-2025 Limit of Harmful Substances in Interior Wall Coatings for Interior Decoration Materials*,focusing on three indicators: VOC,heavy metals (lead,cadmium) and benzene series;
• Complete Chinese labels: Require suppliers to add "China Import Compliance Mark" and Chinese ingredient description on product labels (new commodity inspection regulation in 2026).

Last year,a Zhejiang client commissioned Zhongshen to act as an agent for importing water-based wood paint from Germany.During pre-examination,it was found that the VOC report provided by the supplier was from 2025,while China lowered the limit from 50g/L to 40g/L in 2026.Zhongshen immediately contacted the German laboratory and assisted the client in supplementing the latest 2026 test data,avoiding the risk of customs clearance failure after the goods arrived at the port.

2.Port Customs Declaration: Accurately Match Customs Supervision Codes

Imported paints are "legally inspected goods" with customs supervision code "A".Meanwhile,some high-VOC paints need to be affixed with code "3" (other legally inspected goods except old mechanical and electrical products).In 2026,Shanghai Customs launched "smart customs declaration",but the subdivision of HS codes for paints (for example,the code difference between water-based paints and oil-based paints is two digits) often leads to declaration errors by enterprises.

The customs declaration team of Zhongshen has a "code verification list",which was updated in 2026 and covers mainstream imported paint types:

Last year,a local Shanghai decoration company imported Japanese art paint,and filled in the HS code as 3214100000 (code for ceramic coatings) when declaring by itself.The customs declarant of Zhongshen found the error 1 hour before declaration,modified the code after rechecking the product ingredients,and completed the customs declaration and release on the same day,3 days faster than the client’s expectation.

3.Commodity Inspection: Focus on Checking Dual Indicators of VOC and Hazardous Chemicals

In 2026,the sampling inspection rate of imported paints by Shanghai Commodity Inspection Bureau increased from 10% in 2025 to 15%,focusing on two points: first,whether VOC meets the standard,second,whether the packaging of hazardous chemicals complies with the *Regulations on Safety Management of Hazardous Chemicals*.Director Lan said that last year,a client imported oil-based paint from South Korea,and during commodity inspection,it was found that the "flammable mark" on the packaging barrel was in Korean without Chinese instructions,so on-site rectification was required.Zhongshen immediately coordinated with the warehouse to print and paste Chinese labels,and passed the commodity inspection on the same day.

Zhongshen’s assistance in the commodity inspection link includes:

• Communicate with commodity inspection institutions in advance: Confirm sampling batches and key indicators;
• Cooperate with sampling on site: Arrange special personnel to accompany commodity inspection personnel for sampling to ensure that samples meet testing requirements;
• Rectification follow-up: If the sampling inspection fails,assist the client to contact a third-party testing institution for re-inspection,or coordinate return shipment/destruction (according to the enterprise’s needs).

II.Real Case: Key Actions to Help Enterprises Avoid Return Shipment Risks

Last year,a Suzhou paint dealer commissioned Zhongshen to act as an agent for importing eco-friendly exterior wall paint from the Netherlands,with a total cargo value of 1.2 million yuan.The client was initially worried that the commodity sampling inspection would fail,because the Dutch testing standards are slightly different from those of China.During the document pre-examination,Zhongshen helped the client contact a local third-party testing institution in Shanghai to conduct pre-testing in advance,and confirmed that VOC (35g/L) and heavy metals (lead content 1mg/kg) all meet China’s 2026 new regulations.

After the goods arrived at the port,this batch was exactly selected for commodity inspection.With the pre-test report as reference,the commodity inspection personnel issued the qualification certificate on the same day,and the entire customs clearance cycle was shortened from the client’s expected 15 days to 8 days,saving nearly 20,000 yuan in port storage fees.Without pre-testing in advance,once the sampling inspection fails,the goods may be returned,and the freight loss alone will exceed 100,000 yuan.

III.Core Value of Zhongshen Agency: Reduce Risks and Improve Efficiency

Director Lan said that in 2026,the competition of imported paint agencies in Shanghai has changed from "whether we can do it" to "whether we can do it compliantly and quickly".The value of Zhongshen is reflected in three aspects:

• Zero tolerance for compliance risks: The team updates the latest policies of China Customs and commodity inspection every week,and has helped 12 enterprises avoid return shipments caused by compliance problems since 2026;
• Customs clearance cycle shortened by 30%: Through pre-positioned document pre-examination and accurate matching of declaration codes,the average customs clearance cycle is shortened from 15 days to less than 10 days;
• Controllable costs: Calculate tariffs (tariffs for some eco-friendly paints reduced from 5% to 3% in 2026),commodity inspection fees and storage fees in advance to avoid hidden costs.

For paint import enterprises in Shanghai,market opportunities and compliance challenges coexist in 2026.With more than 20 years of industry accumulation,Zhongshen has developed replicable solutions for every process node of paint import,so that enterprises no longer have to worry about documents,customs declaration and commodity inspection,and can focus on market sales.As General Shang said: "We are not ’intermediaries’,but ’full-service stewards’ for paint import,helping clients handle import affairs correctly,quickly and cost-effectively."