Importing ASIC miners into the EU: VAT, duty and conformity

Bringing mining hardware into the European Union is routine, and it catches out new importers in a specific place. It is not the duty, which is usually modest. It is the value added tax charged at import on the full landed value, and the conformity documentation that a customs authority can ask to see.

Who imports, and where

You need an entity established in the EU with an EORI number, the registration that identifies economic operators to customs. One EORI works across the whole union. If you have no EU entity, the practical routes are an indirect representative who imports in their own name, or a delivered duty paid arrangement where the seller handles the entry. Both cost more and both need to be agreed before the goods ship, not after.

You also choose where to clear. Goods cleared in one member state are in free circulation everywhere, so the port of entry does not have to be the destination country. That flexibility is genuinely useful and is also where inexperienced importers create problems for themselves, because the VAT treatment of a shipment cleared in one country and delivered to another has rules of its own. Take advice on that specific route before booking freight.

VAT, the number that surprises people

Import VAT is charged on the customs value plus duty plus freight, at the standard rate of the country of clearance. Rates across the union sit broadly in the high teens to mid twenties as a percentage. On a shipment worth six figures that is a large payment due at the border.

For a business registered for VAT it is usually recoverable, and several member states operate deferment or postponed accounting so that the import VAT is declared and reclaimed on the same return rather than paid in cash at the border. Whether you can use that depends on your registration and sometimes on a guarantee. Sorting it out beforehand is the difference between a cash flow item and a cash flow crisis.

Duty and classification

Every import is declared under a commodity code from the combined nomenclature, and that code determines the duty rate and whether any trade measure applies. Codes for mining machines have not always been applied consistently, and rates and measures change with policy.

So treat any specific figure you read anywhere, this article included, as out of date. Have a customs broker confirm the classification for your exact model against the current tariff before you build a figure for the landed cost. If a supplier quotes delivered duty paid, ask which classification they priced, because that assumption is the whole basis of their figure. The same discipline applies as in importing into the United States.

Conformity: CE, RoHS, WEEE

• CE marking with an EU declaration of conformity, covering the applicable electromagnetic compatibility and low voltage requirements. The importer carries responsibility for it being correct, not just the manufacturer.
• RoHS, restricting certain hazardous substances in electrical equipment.
• WEEE, waste electrical and electronic equipment. Whoever first places the goods on the market in a member state generally has to register with that country's scheme and finance eventual disposal. This is the requirement most often missed entirely, and it is per country.
• Packaging and battery rules where applicable, and increasingly reporting obligations on energy that are worth checking for your destination.

Ask the supplier for the declaration of conformity and the technical file reference before the goods ship. Getting it afterwards, from a factory in another timezone, while a container sits accruing storage, is a bad week.

Documents the entry needs

• Commercial invoice with an accurate description, quantity, unit value and country of origin.
• Packing list matching the invoice exactly.
• Bill of lading or air waybill.
• EORI number and, where used, the deferment or postponed accounting authorisation.
• Declaration of conformity and any origin documentation that supports a preferential rate.
• Proof of the customs value, including freight and insurance, on the basis of the agreed Incoterm.

How EU shipments actually get stuck

No EORI in place when the vessel arrives. Invoice and packing list disagreeing, which triggers an examination. Country of origin missing, which matters for trade measures. Import VAT not funded because nobody arranged deferment. And a delivered duty paid quote from a seller with no EU establishment, which cannot be executed as written.

Where the goods may legally go is a separate question again, covered in where mining hardware can and cannot go, and the term that decides who pays for all of the above is in Incoterms in plain words.