How to export medical devices from the UK to China

Secure the device's import route before committing stock

For products regulated as medical devices, class I devices need filing, while class II and III need registration before import. For class I, the overseas filer’s designated mainland legal-person company submits the filing and home-country permission-to-market evidence. Confirm who must apply for the exact device with the Chinese authority or licensed partners. Plan for months, not weeks; the Chinese authority decides, with no assured outcome or timetable.

Under HS 9018-9020 (7 subheadings): HMRC recorded £22.5m of UK goods exports to mainland China under 7 HS6 subheadings in 2025 (2024: £32.3m, -30.5%). The largest listed UK export line was 90185090, optical ophthalmic instruments and appliances, at £7.4m. These are HS-code totals, which can include other products.

Price against the exact Chinese tariff line

The verified Chinese tariff lines for these products are shown below. Rates are MFN, except that 90200000 shows MFN followed by its provisional 2026 rate. Import VAT is generally 13%, subject to special rules, on customs value plus duty plus any applicable consumption tax. These charges increase landed cost and shape the importer's offer; its customs broker confirms classification and whether consumption tax applies.

Prepare Chinese instructions and check the CCC scope

Imported devices must have Chinese instructions and Chinese labels. Instructions must identify the origin and the name, address and contact details of the mainland legal entity designated by the overseas registrant or filer; devices without these cannot be imported. Separately, the CCC reference table matches 9020000000 to refuge and escape products using third-party certification. That match calls for a product-scope check, rather than treating every breathing appliance as subject to CCC.

Arrange the UK declaration and check the MHRA certificate

For exports from England, Scotland or Wales, classify the device, obtain a GB EORI and arrange the online export declaration. Supply the commodity code, value, weight, packaging, destination, transport and invoice and packing-list references; the carrier needs the invoice and any export licences or certificates. A medical device may need an MHRA Certificate of Free Sale. MHRA does not verify compliance with China's import rules.

Check the retail list's exclusions before choosing e-commerce

Cross-border retail eligibility is partial. The list includes blood-pressure instruments under 90189020, excluding goods in the prohibited-import catalogue's seventh batch, and massage appliances under 90191010. Entries 90191090, 90192010, 90192020 and 90192090 exclude goods managed as medical devices. A listed breathing or therapy code therefore does not itself provide a retail route for a regulated device.

Eligible listed goods entering through bonded 1210 or direct 9610 are supervised as personal-use articles, without first-import licence, registration or filing requirements, subject to epidemic-area suspensions and emergency risk measures. They may not be resold. The overseas business bears product quality and safety responsibility and must appoint a mainland-registered company for customs registration, truthful declarations and shared civil liability.

Find an importer suited to the device and its application

Our own staff in China find and check Chinese importers and distributors for UK brands. If an importer has already approached you, our staff check that company before stock is sent or anything is signed. Use our export-to-China service for this preparation and importer checking.

For these devices, our help is limited to preparation, finding and checking an importer, and coordinating licensed partners. We prepare registration and label work with licensed partners in China. The importer of record and any required regulated representative or cross-border e-commerce agent remain with licensed partners in China; the manufacturer's own filings remain its own.