Overview of the Energy Efficiency Labeling System

China's energy efficiency labeling system has clear stipulations for imported energy-consuming products. According to the "Energy Efficiency Labeling Management Measures," 38 categories of products are currently included in the scope of compulsory energy efficiency labeling management.

These 38 categories include various motor products such as unitary air conditioners, small and medium-sized three-phase asynchronous motors, permanent magnet synchronous motors, and high-voltage three-phase squirrel-cage asynchronous motors.

Under the new implementation rules, the energy efficiency labeling requirements for permanent magnet synchronous motors take effect from January 1, 2026, and for high-voltage three-phase squirrel-cage asynchronous motors from April 1, 2026. Products manufactured or imported before these dates have a two-year grace period to comply with the new labeling requirements.

Detailed Interpretation of Exemption Clauses

While most imported motors need to complete energy efficiency labeling filing, several exemption scenarios do exist. According to relevant regulations, there are eight categories of situations where products can be exempted from bearing energy efficiency labels and filing:

1. Self-use items for foreign embassies/consulates or international organizations stationed in China and their diplomatic personnel.

2. Self-use items for the official institutions of the Hong Kong and Macao Special Administrative Region governments stationed in mainland China and their staff.

3. Personal belongings carried by individuals entering the country.

4. Items provided as foreign government aid or gifts.

5. Products required for scientific research and testing purposes.

6. Components needed for the assessment of a technology-introduction production line.

7. Products required directly for end-user repair purposes.

8. Equipment and components (excluding office supplies) needed for the supporting of factory production lines or complete production lines.

For enterprises engaged in the business of importing motors for re-export, the application of these exemption clauses is subject to strict limitations. The key lies in proving that the motors are not for sale or use within China but are intended for re-export.

Key Conditions for Exemption Application

To successfully apply for exemption from energy efficiency labeling filing for imported motors intended for re-export, companies must meet several key conditions.

The core condition is providing clear and compelling proof, including a "Company Statement" and relevant trade documents, demonstrating that the products are indeed intended for re-export and will not be sold or used in the Chinese domestic market.

Regarding the preparation of commercial documents, companies need to provide import and export contracts, bonded logistics or bonded warehouse records (if used), documentation for the re-export destination, etc. These documents should corroborate each other, forming a complete chain of evidence.

It is important to note that customs inspections of such cases are typically stringent. Companies should ensure the consistency and authenticity of all documents to avoid unnecessary scrutiny or delays due to contradictory information.

Practical Operations and Risk Warnings

In practical operations, companies should proactively declare to customs during import that the motors are for re-export and provide corresponding supporting documents. If operating through a bonded zone, energy efficiency labeling requirements generally do not apply, but it is necessary to ensure the goods remain under bonded supervision.

Regarding compliance management, companies should note two points: even if an exemption applies, other import regulations, such as product safety standards, may still need to be followed; if re-export plans change and the goods are shifted to domestic sales, energy efficiency labeling filing must be completed immediately.

Corporate Response Strategies

To ensure smooth customs clearance, companies should communicate with customs authorities in advance. It is advisable to confirm required documents and procedures with relevant local customs departments before the goods arrive, especially during policy adjustment periods.

Companies should establish a robust internal record-keeping system, maintaining complete documentation for the entire process from the procurement to the re-export of imported motors. This is not only a requirement for customs inspection but also a crucial aspect of internal corporate management.

As global trade increasingly emphasizes energy efficiency and environmental protection, energy efficiency labeling systems are continuously updated. Companies need to stay informed about relevant policy changes both domestically and internationally, and adjust their business strategies promptly. For example, the EU has explicitly listed products such as steel, aluminum, and textiles among the first batch subject to its eco-design and energy labeling requirements.