A container from China reaches the port of Hamburg, but without a completed customs declaration, the goods can't be picked up. Buyers importing for the first time often underestimate what information has to be settled before arrival, even though the actual filing is usually handled by a customs agent or freight forwarder.
In brief: The customs declaration is the electronic statement to customs authorities, filed through the German IT system ATLAS, that states the goods' value, tariff code, country of origin, and other mandatory shipment data. You usually won't enter the declaration into ATLAS yourself, but you do need to supply your customs agent with everything required to file it, on time.
A customs declaration is the binding statement to customs authorities that places goods under a customs procedure such as release for free circulation. It includes, among other things, the goods description, tariff code, customs value, country of origin, and shipment quantity.
Today, declarations are filed electronically through the German customs system ATLAS (Automated Tariff and Local Customs Processing System). Whoever actually files the declaration in ATLAS, called the declarant, is either the importer themselves or, far more commonly in practice, a customs agent or freight forwarder acting on the importer's behalf.
The declarant is whoever files the customs declaration in their own name or as a representative, and is therefore responsible to customs authorities for the accuracy of the information. On most China imports, a customs agent or freight forwarder takes on this role on the importer's behalf, not the importer directly.
Legally, though, the importer generally remains the debtor of the customs debt even when a third party technically filed the declaration. Under indirect representation, the customs agent can additionally become liable, since they act in their own name on the importer's behalf there. Incorrect or incomplete information therefore usually still comes back to the importer in the end, even if the mistake originated with the declarant.
Task | Responsible |
|---|---|
Supplying goods value, tariff code, and origin | Importer |
Filing the declaration in ATLAS | Declarant (customs agent or forwarder) |
Accuracy of the filed information toward customs | Declarant |
Customs debt on incorrect information | Importer, plus the declarant under indirect representation |
In our sourcing projects, we regularly see buyers assume they don't need to worry about the customs declaration at all because the forwarder handles it. Without a correct tariff code, customs value, and proof of origin from the buyer, though, the declarant can't file a reliable declaration in the first place, no matter how experienced they are.
A customs declaration rests on a set of core data points and supporting documents that have to be settled before filing:
Commercial invoice with goods value and description
Tariff code for each goods position
Country of origin and, where relevant, proof of preferential origin
Freight document (e.g. bill of lading) and proof of insurance
EORI number of the declarant or importer
Statistical value and weight of the shipment
Missing even one of these items delays the declaration, and the goods sit with customs in the meantime. The tariff code and the customs value are the two items that most often need correcting after the fact, because they weren't properly determined during procurement.
Depending on the type of goods, customs may also require product-specific proof, such as a declaration of conformity. Our post on the 2026 import regulations covers such additional import requirements in more depth.
Without a valid EORI number, no customs declaration can be filed in ATLAS, whether by the importer directly or by a commissioned declarant. The number has to be obtained before the first import, not once the container is already sitting at the port. Applying usually takes only a few business days, but it still regularly gets started too late, since it's easy to overlook during procurement until an actual shipment is on the way.
The declaration itself is entered into ATLAS in structured data fields, not as free text, so the language question really concerns the supporting documents. German customs in practice usually accept commercial invoices and freight documents in English too; when in doubt, it's worth checking with the responsible customs office or your declarant. For original Chinese-language documents, such as factory certificates, a German or English translation is worth adding as well, to avoid queries during review.
In one of our sourcing projects, a client only requested the commercial invoice from the supplier after the container had already arrived, since it hadn't seemed important until then. The result was several days of demurrage fees at the port before the declaration was finally complete. Since then, we make sure all declaration data is in hand before the shipment leaves, not once it arrives.
In practice, an import declaration through ATLAS runs through roughly these steps:
Declarant enters the shipment data (goods value, tariff code, origin) into ATLAS
The system checks the data automatically and issues a declaration number (MRN)
Customs decides on release, physical inspection, or document review
Once released, the goods are cleared for pickup
The duty and import VAT assessment goes to the declarant or importer
Further guidance on electronic filing is also available from the Chamber of Commerce's ATLAS factsheet, as well as from customs authorities themselves on their page about internet customs declarations. As an importer, you don't need to know this process in detail, but you should know where your own input feeds into it, so you can answer your declarant's questions quickly.
At minimum: commercial invoice, freight document, proof of origin (if relevant for preferences), and the EORI number. Depending on the type of goods, further proof such as declarations of conformity may be required.
A simplified customs declaration lets certain information or documents be missing at first, to be supplied later with a supplementary declaration. The procedure has to be applied for and approved by customs, and suits companies with regular, similar imports rather than occasional one-off shipments.
There's no separate paper form for a regular customs declaration anymore; the data goes directly into ATLAS. The Single Administrative Document once used on paper now only exists as a fallback for exceptions such as a system outage.
With complete information and no physical inspection, ATLAS often grants release within a few hours. If customs selects the shipment for a document or goods inspection, release can be delayed by several days.
A customs declaration through ATLAS rarely fails because of the software in practice; it fails because of missing or late information from the importer, such as the tariff code, customs value, or EORI number. Coordinating that information with your declarant before the shipment leaves avoids demurrage fees and delays at the port. For a broader overview of the whole import process, see our guide to importing from China, if the customs declaration is just one of several open items in your procurement.
Line Up supports you in preparing customs declarations for your China imports, from correct tariff classification through EORI registration to ongoing coordination with your declarant or freight forwarder. 👉 Schedule a no-obligation consultation.
Your requirements are unique. So are our solutions. Let's talk about it.
Schedule a call →Sign up now for our free Line Up newsletter and stay up to date.

