> Intro: Used Japanese machine tools are an important equipment source for China’s manufacturing industry. Pre-Shipment Inspection (PSI) is a mandatory pre-import procedure for high-risk used electromechanical products. Based on a real trade case, GQ Global Quality Technology Group sorts out compliance procedures and frequent risks for importing used metal-cutting machine tools from Japan, warning foreign trade companies not to take chances of “remedying after arrival”.
A used machine tool trader in Dongguan, China signed a contract in March 2025 to buy 5 sets of used vertical machining centers from Osaka, Japan, with a CIF Shekou value of 580,000 USD. The broker reminded the enterprise of inspection requirements for used electromechanical goods at the contracting stage. However, eager to secure downstream orders from mold factories, the company ignored the reminder and shipped the goods directly, which eventually led to heavy financial losses and customer churn.
How to Judge Whether Equipment Is Used Electromechanical Product and Requires Pre-Shipment Inspection
In accordance with the **Measures for the Supervision and Administration of Inspection of Imported Used Electromechanical Products (General Administration of Customs Order No.243)**, a product is defined as used electromechanical equipment if any of the following applies: previously used but still functional with usable value; unused yet out of warranty period; unused but with physical component deterioration caused by long-term storage; assembled with mixed new and old parts; refurbished or modified. **Visual appearance condition shall not be the judgment standard.**
Imported used electromechanical products are subject to port inspection and destination inspection. Products listed in the high-risk catalogue must complete Pre-Shipment Inspection (PSI) overseas before departure.
Referring to Annex of AQSIQ Announcement No.145 of 2014, *Catalogue of Inspection and Supervision Measures for Imported Used Electromechanical Products, Measure Table 2*, 17 categories of goods are subject to mandatory overseas PSI. Closely related to China-Japan machine tool trade: metal-cutting machine tools, used construction machinery, used printing & packaging equipment, used medical devices. Most complete production lines assembled with CNC equipment are also under control.
Goods listed in Measure Table 1 are prohibited from import. Before signing purchase contracts, enterprises shall check HS codes to confirm the category of goods. A short pre-check can avoid troubles lasting for months.
> Reminder from GQ Global Quality Technology Group: PSI cannot be conducted at domestic ports. It must be finished before cargo leaves the warehouse in Japan.
Selection of PSI Inspection Bodies, Certificates and Practical Notes
The General Administration of Customs does not designate inspection agencies. Enterprises can select service providers independently. Overseas branches of CCIC are mainstream service suppliers for PSI of Japanese used machine tools, with offices in Japan, South Korea, Europe and America.
Enterprises shall not select third-party agencies merely by price. If certificates issued fail to meet regulatory requirements, customs may issue a warning notice and refuse recognition of all reports from that agency for up to 3 years, which will severely affect import business. GQ recommends verifying three points before authorization: historical inspection cases of similar equipment, whether each piece of equipment is fully documented in reports, and availability of on-site inspectors at Japanese warehouses.
The validity period of the Pre-Shipment Inspection Certificate is determined by the issuer according to equipment condition, generally 6 to 12 months. Reports for construction machinery have the strictest requirements: each unit shall record name, HS code, model, origin, serial number, manufacturing year, operating hours, maintenance records, etc. Missing information will cause customs clearance block.
The so-called “used electromechanical filing certificate” has long been abolished. Announcement No.76 of 2015 jointly issued by AQSIQ, MOFCOM and GAC cancelled the administrative approval for filing used electromechanical products. Currently “used electromechanical product” will only be marked in the remarks of import customs declaration document.
The whole process includes two parts:
1. Single Window for International Trade: Pre-Shipment Inspection Supervision System for Imported Used Electromechanical Products**: Enterprises submit information and documents online and apply for inspection. After inspection, the agency feeds back certificate number. Applications with incomplete documents will be returned for revision.
2. After cargo arrival, declare to local customs and arrange destination inspection.
Documents required for PSI application in Japan: import contract, commercial invoice, packing list, equipment schedule (name, model, manufacture date, serial number, quantity), photos of whole machine and nameplate, equipment manual, maintenance records, certificate of origin, business license, power of attorney.
Time reference: On-site inspection for single machine tool overseas takes about 2 working days; complete production lines take 3–5 working days; certificate issuance takes another 3–5 working days; port inspection takes 1–2 working days; destination inspection is scheduled by local customs. **All PSI procedures must be completed before shipment from Japan.**
For machine tools listed in the *Catalogue of Key Used Electromechanical Products Subject to Import Control*, an import license issued by MOFCOM is required in addition to PSI for customs clearance.
Common Pitfalls in Classification and Price Verification
HS code classification of used equipment depends on function and working principle rather than appearance. For example, used machining centers fall under tariff heading 8457.10. Enterprises cannot apply lower tariff codes simply because the machine is old, which carries high risk of retrospective verification.
Duty-paid value is based on actual transaction price. Customs will verify original invoices, new machine market price and bank payment records. Declared depreciated low price will not be accepted automatically. Freight, insurance premium and pre-shipment commissioning cost shall be included in dutiable value as required. It is advised to confirm with customs broker at contracting stage.
Loss Review of 23-Day Port Detention
The 5 used vertical machining centers arrived at Nansha Port on May 2. Customs declaration revealed that metal-cutting machine tools are under Measure Table 2 control and lacked mandatory PSI certificate.
Regulations stipulate that import-eligible used electromechanical goods without valid PSI shall be returned. Severe violations may incur fines up to 1 million RMB. There is no channel for supplementary PSI at domestic ports. The enterprise spent 22 days handling return formalities, and the cargo was shipped back to Osaka on the 23rd day.
Direct economic losses:
- Container detention fee and terminal storage fee: 97,680 RMB
- Round-trip ocean freight for return: 46,000 RMB
- PSI re-inspection cost after returning to Japan: 45,000 RMB
Total of above three items: 198,680 RMB
After returning to Osaka for inspection, safety defects were found: the safety interlock of protective door failed on one machining center, and insulation resistance failed on another. Both are non-rectifiable safety defects at domestic port. The Japanese seller spent another two weeks for repair and re-inspection. Downstream mold customer cancelled orders for two units due to delayed delivery. Profit loss from cancelled orders exceeded the direct expenses above. In total, the company lost more than 300,000 RMB for cutting inspection cost at the beginning, and the project was delayed for 5 months.
Top 5 Reasons for Return of Imported Used Machine Tools
1. Failed safety items**: malfunction of safety interlock and emergency stop, unqualified earthing and insulation resistance. Equipment failing safety inspection can only be destroyed or returned; on-site rectification at domestic port is not permitted. Only non-safety defects can be repaired under customs supervision.
2. Unqualified environmental indicators**: excessive noise, non-road machinery emission failing China standards, restricted refrigerant, which can be identified during PSI.
3. Shipment without PSI**: a basic mistake with serious consequence, almost leading to return.
4. Inconsistency between certificate and physical goods**: mismatch of model, serial number, manufacture year or quantity will trigger inspection interception.
5. Goods falling into prohibited import list**: used medical devices are high-risk items. Always check control list before signing contracts.
Practical Recommendations from GQ Global Quality Technology Group
The compliance sequence for purchasing used machine tools from Japan cannot be reversed:
Step 1: Check HS code and confirm whether PSI is mandatory.
Step 2: Insert PSI clauses into purchase contract, specifying responsibility for rectification, cost allocation and delivery extension for non-conforming goods.
Step 3: Complete third-party on-site inspection at Japanese warehouse and obtain valid PSI certificate before booking shipment.
Step 4: Complete port inspection after arrival and arrange destination inspection with local customs.
Equipment serial numbers must be stated in purchase contracts and commercial invoices for consistency check in the whole process. Do not judge compliance only by appearance. Inspection focuses on safety protection and electrical safety. Reserve a buffer period of more than 30 days, as import lead time of used electromechanical products is often longer than expected.
FAQ
Q: Is PSI required for all imported used electromechanical products?**
A: No. All used electromechanical products need port and destination inspection. Only 17 high-risk categories listed in Measure Table 2 of the *Catalogue of Inspection and Supervision Measures for Imported Used Electromechanical Products* require PSI before overseas departure. Supplementary inspection after arrival is not allowed, and violation leads to return.
Q: Does the PSI certificate have an expiry date?**
A: The validity period is determined by the issuer according to equipment condition, generally 6–12 months. Certificates must have traceable unique ID. Chinese version is the legally valid text for bilingual documents, attached with full inspection report including inspection basis, on-site verification records and authorized signature.
Q: Can PSI be supplemented after cargo arrives at China port?**
A: No. According to the Regulations for the Implementation of the Import and Export Commodity Inspection Law and supervision rules for used electromechanical products, PSI cannot be supplemented at port. The only solution is return shipment, and the importer shall bear all detention, freight and storage costs.
> GQ Global Quality Technology Group | Compliance News for Third-Party Inspection & Testing
> This article is for industry risk popularization only and shall not be regarded as legal advice for customs declaration. All operations shall follow the latest customs announcements.