Sdoganamento merce dalla Cina: come funziona, i documenti e la bolletta doganale

Customs clearance in Italy for goods from China: how it works, the documents and the customs entry

SATURDAY, 17 OCTOBER 2026

From the entry summary declaration to release: who files what, the documents to prepare, the four inspection channels and the summary that has replaced the customs entry for recording import VAT.

Customs clearance in Italy for goods from China is the sequence of steps that turns a container arriving at an Italian port into goods free to circulate in the European Union: presentation to customs, the import declaration, any inspection, payment of duty and VAT, and release. In practice a customs representative almost always handles it, but much of the responsibility for the data and the documents stays with the importer.

This guide follows the goods from the moment the ship is at sea until the import VAT is recorded in the purchase ledger. It does not explain how duty is calculated, which has its own guide, but everything around it: who files what, which documents are needed, how inspections work, what has replaced the old paper customs entry and which deadlines are best not missed.

Before arrival: the entry summary declaration

Customs clearance starts before the ship berths. For all goods bound for the EU, an entry summary declaration, the ENS, must be sent to customs before arrival. For sea freight, since 3 June 2024 it goes through the EU's ICS2 system, which asks for more precise data than before: a commodity code of at least 6 digits, a complete description, the parties' addresses and the EORI number of the consignee established in the EU.

The ENS is normally filed by the carrier or the forwarder, not by the importer. But the data come from the Chinese supplier's invoice and packing list: a generic description such as "parts" or "accessories" can hold a shipment up at loading. It is worth asking the supplier for descriptions consistent with the ones that will end up in the import declaration.

Presentation to customs and temporary storage: the 90 days

When the goods arrive, they must be presented to customs at the port where they are unloaded. From that moment they are non-Union goods in temporary storage: they stay at the terminal or in an authorised warehouse, under customs supervision, until they are placed under a procedure.

Article 149 of the Union Customs Code sets the limit: goods in temporary storage must be placed under a customs procedure or re-exported within 90 days. If the deadline passes, customs take the steps needed to settle the situation, up to selling or destroying the goods at the declarant's expense. The legal limit is not what weighs most, though: at the port, container storage charges start running much earlier, and terminal free time is measured in days, not months.

Who files the declaration: direct and indirect representation

The importer can lodge the import declaration itself, but nearly always uses a customs representative, usually a customs broker. Article 18 of the Union Customs Code provides two forms:

Direct representation: the representative acts in the name and on behalf of the importer, who remains the declarant and the duty debtor.
Indirect representation: the representative acts in its own name but on behalf of the importer, and under Article 77 both the representative and the importer are debtors.

The choice matters for liability, not just for the quote. In both cases, anyone who supplied data they knew, or should reasonably have known, to be false can also become a debtor. It makes sense to sign the mandate before the goods leave, together with a check of your own EORI number.

Customs clearance in Italy: the documents you need

Article 163 of the Code requires the supporting documents to be in the declarant's possession, and available to customs, when the declaration is lodged. For a container from China the typical file includes:

The supplier's commercial invoice, with value, currency, Incoterm and a detailed description of the goods.
The packing list, with the number of packages, gross and net weights and the contents of each package.
The transport document: the ocean bill of lading or the air waybill.
Documents for the customs value: freight and insurance invoices up to the EU border, when they are not already in the price.
Certificates and licences required for those goods: origin, product conformity, any authorisations.

The TARIC code is not a document, but it is the data point that determines duty, anti-dumping measures and controls: it is best settled before ordering, not at the port. Once clearance is complete, Article 51 requires documents and information to be kept for at least 3 years, running from the end of the year in which the declaration for release for free circulation was accepted.

The import declaration in AIDA and the MRN

In Italy the declaration is sent to AIDA, the customs system of the Italian Customs and Monopolies Agency. Since 9 June 2022 the new EU data model applies: release for free circulation uses the H1 dataset, the exchange of electronic messages constitutes the declaration and the old paper SAD is no longer printed. One declaration can hold up to 999 items, against 40 in the previous system.

When the declaration is accepted, the system assigns it an MRN, the number that identifies the operation at every later step. The date of acceptance is the one that counts for the rules of the procedure, including the applicable rates, and under Article 77 it is also when the customs debt, the liability for duty, is incurred.

Inspections: green, yellow, orange and red

Every declaration goes through the customs control circuit, which routes it to one of the channels based on risk profiles:

Green, automated control (CA): no check on the goods or the documents, the goods can be released.
Yellow, documentary control (CD): the office examines the declaration and the attached documents.
Orange, scanner control (CS): documentary check plus an X-ray of the container or vehicle.
Red, physical inspection (VM): documentary and physical check, with the container opened.

Risk profiles combine origin, goods, value, packaging and the operator's history. A documentary check can be escalated to a scan or an inspection if the documents raise concrete doubts. A red channel is not an accusation, but it adds time: the container has to be moved to the inspection point and opened, and every extra day at the terminal has a cost.

Paying the duties and releasing the goods

Release is the moment the goods leave customs supervision and become Union goods. Under Article 194, customs release the goods as soon as the particulars of the declaration have been verified or accepted without verification, provided the conditions of the procedure are met and the duty due has been paid or guaranteed.

There are two rules for payment. As a rule, Article 108 provides that duty and other charges are paid within the period set by customs, which cannot exceed 10 days from notification of the debt. Holders of a deferred payment authorisation, backed by a guarantee, get 30 days instead under Article 111. In practice, importers without a deferment account usually advance duty and VAT to the customs broker, who pays them and then re-invoices them.

From the customs entry to the accounting summary: recording import VAT

The bolletta doganale, as Italian businesses still call the customs entry, used to be the copy of the SAD that the broker handed over at the end. With H1 declarations it no longer exists: the Agency provides two different documents, defined by circular 22/D/2022.

The declaration summary, available from acceptance, which shows the MRN and the main data of the operation.
The accounting summary, approved by directorial decision 234367 of 3 June 2022, generated after release and available since 21 July 2022.

The accounting summary shows duty, VAT and other taxes broken down by rate, and is the one used for the books. It is downloaded from the Agency's single portal, through the "Gestione documenti – dichiarazioni doganali" service, after requesting consultation rights; both the importer and the declarant can access it. Article 25 of Presidential Decree 633/1972 requires the customs entry to be recorded in the purchase ledger to deduct the VAT paid at import, by the periodic VAT settlement in which the deduction is claimed and in any case by the annual return: today the document to record is the accounting summary. It is worth having your accountant receive it directly, rather than waiting for the broker's copy.

Worked example: a container of homeware in Genoa

A hypothetical Italian company imports a 40-foot container of homeware, loaded in Ningbo on FOB terms, and uses a Genoa customs broker under direct representation. Dates and amounts are chosen for the example:

25 days before arrival, at loading: the carrier files the ENS in ICS2 with the 6-digit codes and the company's EORI number, taken from the packing list.
10 days before arrival: the broker receives the invoice, packing list, bill of lading and freight and insurance invoices, and checks the TARIC codes.
Day 0: the ship unloads and the container enters temporary storage at the terminal.
Day 1: the H1 declaration is accepted and receives its MRN; the circuit routes it to the yellow channel.
Day 2: with the documentary check closed, the goods are released. Duty of 1,800 euros and import VAT of 9,400 euros are advanced by the broker.

A few days later the accounts team downloads the accounting summary from the portal and records it in the purchase ledger before the month's VAT settlement. Had the same container gone to the red channel without the freight invoice, the inspection and the request for more documents could have added days of storage. Fast customs clearance is almost always the one where the documents were ready before the ship arrived.

With La Merce, customs clearance for goods from China is prepared when the order is signed: descriptions and codes consistent across invoice, packing list and ENS, documents with the broker before arrival and the accounting summary ready for the VAT ledger, so the container leaves the port well within the 90 days of temporary storage.