How to Optimize Packaging for Commercial Refrigerator Spare Parts to Reduce Import Costs

Cooluma notes that trading enterprises face high export costs. By bundling after-sales spare parts for commercial refrigerators with complete units in the same container for unified declaration as complete equipment, consolidating multi-category components into dedicated repair kits declared under a single HS code, and combining small orders to exceed the €150 low-value threshold, businesses can compliantly avoid the EU’s fixed tariff on low-value parcels and effectively reduce the overall import cost of spare parts.

Effective July 1, 2026, the EU officially implements Council Regulation (EU) 2026/382, which abolishes the nearly 20-year-old tariff exemption for low-value parcels under €150. A temporary fixed duty of €3 per item will be levied on all imported goods originating from non-EU countries with a value of €150 or less, charged by HS tariff heading. This policy is a transitional arrangement valid until June 30, 2028, after which taxation will fully shift to official commodity tariff rates.

Core Rules:

1. Charging rules: Duty is calculated by HS tariff heading (product category). Goods under the same tariff heading in a single parcel incur only one €3 charge, while goods under different headings are charged separately, regardless of quantity;
2. Scope of application: All low-value goods with a value of €150 or less, covering all entry channels including commercial express, postal parcels, and LCL (less than container load) shipments;
3. Compliance liability: The importer is the statutory taxpayer, while e-commerce platforms and logistics service providers bear withholding and joint liability;
4. Penalty mechanism: For under-declaration of value or malicious splitting of parcels to evade taxes, customs authorities may seize the goods and impose a fine of up to three times the declared value.

Direct Impact on Exports of Commercial Refrigerators & Display Cabinets

For B2B exports of commercial refrigeration equipment, the new policy does not affect conventional full-container shipments of complete units. However, separately shipped after-sales spare parts, replacement components, and small supplementary orders will face dual impacts on cost and lead time, making them the core affected segment under this policy.

1. Significant Cost Increase for Separate Shipments of Low-Value Spare Parts

Common wear-and-tear parts for commercial refrigerators (thermostats, door locks, sealing strips, condenser fans, control panels, etc.) are mostly classified under HS 8418.99 (parts dedicated to refrigeration equipment), with an EU MFN (Most Favored Nation) base tariff rate of approximately 2.2%–9% (varying slightly by subheading).
Following the implementation of the new policy, single shipments of low-value spare parts will incur an additional €3 fixed duty on top of base tariffs and import VAT. Combined with customs clearance processing fees charged by member states such as Germany and France, the overall import cost per shipment of spare parts can increase by 15%–30%.

2. Tax Evasion via Split Shipments Is No Longer Feasible

Previously, some importers split a batch of spare parts into multiple parcels under €150 to reduce costs. Under the new policy, split shipments will instead generate multiple €3 fixed charges — the more the shipment is split, the higher the additional tax costs. Meanwhile, EU Customs has launched a full-chain traceability system for low-value goods, and multiple shipments of the same product category to the same address and recipient will be combined for tax calculation.

3. Longer After-Sales Clearance Times and Diminished Service Experience

The inspection rate for low-value parcels has risen from approximately 5% before the policy to 18%. Clearance time for separately shipped spare parts has increased from the original 3–5 days to 7–10 days, directly delaying after-sales maintenance for end customers in supermarkets and catering businesses and weakening service competitiveness.

Compliant Optimization Solutions: Packaging Strategies Based on Customs Classification Rules

All solutions below strictly follow the WCO General Interpretative Rules for the Harmonized System and established EU customs case law. They are fully compliant, risk-free, and ready for immediate implementation.

Solution 1: Ship Spare Parts Together with Complete Units in One Container, Declare as “Complete Equipment” (Top Recommendation)

Legal Basis

Pursuant to HS General Interpretative Rule 2(a): goods referred to in a heading shall be deemed to include unassembled or disassembled goods, provided they present the essential character of the complete article upon importation, and may be classified uniformly as the complete product.
The ECJ judgment (Case C-107/22) further clarifies that components imported in the same shipment, under the same contract, and intended for assembly into a fully functional piece of equipment shall be treated by customs as a single article, declared under the complete unit’s HS code, with no separate taxation of individual parts.

Practical Implementation

1. Pack replacement wear-and-tear parts purchased by the customer (sealing strips, thermostats, door locks, backup fans, etc.) together with the corresponding model of commercial refrigerator/display cabinet in the same container and ship them as a single consignment;
2. Declare uniformly under the HS code for the complete unit during customs declaration. On the commercial invoice, list the parts as “complimentary spare parts” with their value included in the total value of the complete unit, without separately itemizing the value of spare parts;
3. On the packing list, mark the parts as “dedicated components for Model XX refrigerator”, corresponding one-to-one with the complete unit model.

Cost Benefits

• Completely avoids the €3 fixed tariff and additional clearance handling fees for separately shipped spare parts;
• EU tariff rates for complete commercial refrigerators and their dedicated parts are largely equivalent, so unified declaration will not create additional tax burden;
• Clearance proceeds in parallel with the complete units with no delay, ensuring customers have spare parts available immediately upon delivery.
  [To be supplemented: HS codes of your main complete unit products and corresponding EU tariff rates; actual case studies of cost savings per cabinet can be added]

Solution 2: Consolidate Multi-Category Parts into “Dedicated Repair Kits” Declared Under a Single HS Code

Legal Basis

According to EU Customs Guidelines on the classification of goods put up in sets, when multiple components are combined for a clear, single specific purpose (e.g., “Model XX refrigerator repair kit”), packaged for配套 delivery and not intended for separate retail sale, they may be classified under the HS code corresponding to the core component that gives the kit its essential character.

Practical Implementation

Consolidate various after-sales parts for the same customer (e.g., thermostat + fan + door lock + sealing gasket) into a single package labeled as “Dedicated Repair Kit for Model XX Commercial Refrigerator”;

Declare under the HS code of the highest-value, most functionally core component in the kit, avoiding multiple €3 fixed charges from separate taxation under different tariff headings;

Clearly mark the outer packaging with “Dedicated equipment support kit – not for individual retail sale”, and clear customs together with the same shipment batch.

Applicable Scenario

For customers who place bulk orders for complete units and then purchase a batch of after-sales spare parts in a single order, where the total value of the parts remains below €150.

Solution 3: Combine Small Orders to Exceed the Low-Value Threshold and Use Standard Trade Clearance

For spare parts orders with a single shipment value exceeding €150, standard trade clearance rules apply directly and the shipment falls outside the scope of the low-value parcel new policy. Only base tariff and import VAT are payable, with no €3 fixed duty.

Practical Compliance Red Lines (Non-Negotiable Rules)

1. Prohibition of under-declaring value: EU Customs has established a price benchmark database for refrigeration equipment spare parts. Declared prices deviating more than 30% from the industry average will trigger manual inspection, resulting in demurrage charges and heavy fines;
2. Prohibition of mixing generic parts: Parts declared together with complete units must be dedicated components for the corresponding model. Generic hardware and electronic components cannot be included in the classification of complete equipment sets;
3. Three-document consistency: The product name, quantity, and model of spare parts on the commercial invoice, packing list, and purchase contract must fully match. For set declarations, the contract must include a clause stating “spare parts delivered together with complete units”.

Our Supporting Services

As a professional exporter of commercial refrigerators and beverage display cabinets, we provide complimentary customized packaging and customs declaration solutions tailored to each customer’s procurement plan and after-sales needs:

• For customers purchasing complete units, standard wear-and-tear parts can be shipped complimentary with the cabinets at no extra clearance cost;
• For after-sales replacement part requests, we can assist with order consolidation and optimized shipment batches to minimize tariff expenses;
• We provide full compliance document support, including certificates of origin, declarations of conformity, and set declaration documentation to ensure seamless customs clearance.

For a tailored cost optimization calculation based on your specific procurement list, please contact our sales team for a customized quote.

References

1. Council Regulation (EU) 2026/382 of 11 February 2026, EUR-Lex Official EU Legal Database
2. Guidance on temporary flat fee on low-value imports, European Commission Directorate-General for Taxation and Customs Union, 2026-06-08
3. Harmonized System General Interpretative Rules, World Customs Organization (WCO)
4. ECJ Judgment Case C-107/22 X BV, Court of Justice of the European Union
5. Guidelines on the classification of goods put up in sets for retail sale, European Commission