Country：德国 · Trade, Supply Chain & Exit
Germany · Trade, Supply Chain & Exit
Germany belongs to the EU Customs Union and single market; goods move freely within the EU, and external tariffs follow the EU common tariff. China-Germany trade is close, with China an important German trading partner. Germany's Supply Chain Due Diligence Act (LkSG) requires large companies to conduct human-rights and environmental due diligence. Exit can be by share transfer, deregistration or insolvency liquidation. Note the EU CBAM carbon-border mechanism.
Key points
- EU single market: free movement of goods, EU common external tariff
- LkSG supply-chain act: large companies must conduct human-rights/environmental due diligence
- CBAM carbon-border adjustment mechanism affects high-carbon imports
- Exit: share transfer, deregistration, insolvency liquidation
- No exchange control within the EU; profits freely repatriated
- Chinese home-law anchor (pkulaw verification 2026-07): outbound trade must comply with China's Foreign Trade Law (2025 Revision) (Presidential Order No. 67, effective 2025-12-27) — import/export operating rights use a filing-and-registration system; dual-use items/technology imports and exports are subject to control lists and the Unreliable Entity List; trade with specific countries/regions must also meet Chinese export-control and sanctions compliance.
Procedure
- Assess supply chain and EU compliance (LkSG/CBAM)
- Customs clearance and VAT compliance
- Lay out EU warehousing and distribution
- Fulfill supply-chain due diligence
- Plan share transfer or deregistration at exit
Hard requirements
- EU tariff/VAT compliance; LkSG due diligence (large companies); CBAM (high carbon)
Costs
Tariff/VAT; compliance and due-diligence cost; deregistration/liquidation fee⏱ ⏱ Timeline：Trade immediate; exit weeks to months⚠ Common risks
- LkSG due-diligence gap faces penalties
- CBAM increases high-carbon product cost
- Exit deregistration tax clearance; complex EU compliance
Handbook
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to：Chinese capital using Germany as the gateway to the EU Customs Union and single market for trade; must meet LkSG supply-chain due diligence and CBAM, as well as share-transfer/deregistration/insolvency-liquidation exit scenarios.
Prerequisites
- Chinese parent completed MOFCOM import/export operating-rights filing (see legal_review anchor)
- Company set up in Germany with an EU EORI number
- Large companies must build an LkSG human-rights/environmental due-diligence system
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | China-side filing and dual-use-item pre-assessment The parent completes the MOFCOM filing; screen dual-use items for export control and apply for Chinese permits and EU authorizations as needed. | Trade compliance | Filing 1–2 weeks | Government fee per official publication | MOFCOM filing; dual-use export authorization | Dual-use items controlled bilaterally. Penalty：Unauthorized export penalized by home country and EU. |
| 2 | EORI and customs registration Obtain an EORI number at German Customs (Zoll) and make customs declarations for non-EU imports, under the EU common tariff. | Customs agent | Days | EU common tariff + import VAT | EORI registration + customs declaration (ATLAS) | Free movement within the EU. Penalty：No EORI, cannot clear customs. |
| 3 | Origin and EU FTA preferences Use EU FTA preferences for imports from outside the EU; use EU rules of origin for exports. | Trade compliance | Ongoing | Per official publication | Certificate of origin / preference declaration | Export VAT refundable. Penalty：False origin loses preferences. |
| 4 | Customs compliance, CBAM and valuation Classify, value and duty-pay under the EU HS nomenclature; for high-carbon imports, account for CBAM carbon-border cost. | Customs agent | Per shipment | Tariff/VAT/CBAM | Customs declaration / CBAM declaration | CBAM raises high-carbon cost. Penalty：Misclassification back-tax. |
| 5 | LkSG supply-chain due diligence Large companies conduct human-rights and environmental due diligence, building a supply-chain due-diligence system and remediation process. | Compliance/ESG | Ongoing | Due-diligence and system cost | LkSG due-diligence report | Gap faces penalties. Penalty：LkSG due-diligence gap penalized. |
| 6 | Exit: share transfer / deregistration / insolvency liquidation Prefer share transfer or commercial-register deregistration; insolvency liquidation if balance-sheet insolvent, with tax settled first. | Director / liquidation team | Weeks to months | Deregistration/liquidation fee | Commercial-register deregistration / insolvency application | Tax clearance is a prerequisite. Penalty：Uncleared tax imposes personal liability. |
✅ Self-check list
⚠ Common pitfalls
LkSG due-diligence gap影响：Penalty and reputational risk规避：Build supply-chain human-rights/environmental due diligence.
CBAM raises high-carbon cost影响：Profit margin narrows规避：Calculate carbon cost and optimize.
Uncleared tax at exit影响：Personal liability规避：Settle tax before liquidation.
False origin影响：Lose preferences规避：Build a genuine evidence chain.
Ignoring home-country export control影响：Home-country penalty规避：Screen dual-use items before export.
📅 Ongoing post-incorporation obligations
- Ongoing EU customs declaration and VAT/CBAM compliance
- LkSG supply-chain due diligence (large companies)
- Commercial-register deregistration and record retention after exit
🔗 Official portals
📎 Source：德国海关；欧盟关税同盟；欧盟供应链法(LkSG)；商业登记注销 ; https://www.mofcom.gov.cn ; https://www.customs.gov.cn
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