How to export orthopaedic implants from the UK to China

Device approval comes before shipment

Orthopaedic implants and prosthetics need medical-device filing or registration before import: class I devices are filed, while class II and III devices are registered. Confirm the applicant and supporting-material arrangements with the Chinese authority or licensed partners. For an overseas class I filer, a designated mainland legal-person company submits the filing and home-country proof permitting sale. Plan for months, not weeks; the Chinese authority decides, and no approval timetable is promised.

Under HS 9021-9021 (8 subheadings): HMRC recorded £28.8m of UK goods exports to mainland China under 8 HS6 subheadings in 2025 (2024: £24.2m, +18.7%).

Exports to Hong Kong under the same codes were £847k. January to July 2026: £15.0m against £18.6m in the same months of 2025 (-19.7%). The largest UK export line to mainland China was 90213100, artificial joints for orthopaedic purposes, at £15.1m. These are HS-code totals, rather than sales of your particular implants.

Calculate the Chinese border cost by tariff line

The verified MFN rates for the listed Chinese tariff lines are shown below. The provisional 2026 rates are 2% for 90212100, 90212900 and 90213100, and 1% for 90214000. The eight HS6 headings lead to ten Chinese tariff lines, so use the product’s Chinese classification when discussing the price your importer can offer.

Import VAT is generally 13%, subject to the statutory exceptions. Its base is the customs value plus customs duty plus consumption tax. Duty and VAT add to the importer’s landed cost. The importer’s customs broker or adviser confirms the applicable tariff treatment and whether consumption tax applies to these implants.

Prepare Chinese instructions and labels

Imported devices must have Chinese instructions and Chinese labels; devices without them may not be imported. The instructions must state the origin and the name, address and contact details of the mainland legal entity designated by the overseas registrant or filer. Prepare these materials alongside the device application, with the designated company’s details agreed before shipment.

Set up the UK export documents

Find the correct UK commodity code for the actual device, rather than treating all the listed HS6 headings as interchangeable. Exports from England, Scotland and Wales need a GB EORI and an online export declaration. Give the declarant the commodity code, value, weight, packaging, destination, transport details and invoice and packing-list references; give the carrier the invoice and any required export licences or certificates.

Check the medical-device export requirements for your product. You may need an MHRA Certificate of Free Sale. MHRA does not verify that the device meets the importing country’s rules, so this certificate does not replace Chinese filing or registration.

The retail e-commerce entry excludes medical devices

The cross-border e-commerce retail import list includes 90211000, orthopaedic or fracture appliances, with the remark excluding goods managed as medical devices. That entry therefore provides no retail e-commerce route for implants regulated as medical devices. Have the importer’s customs broker confirm the treatment of the actual product before choosing a sales channel.

Find and check a Chinese importer

Our own staff in China find and check Chinese importers and distributors for UK brands. If a Chinese importer has already approached your brand, our staff in China check that company before stock is sent or anything is signed.

For these implants, our help is limited to preparation, finding and checking a Chinese importer, and coordinating licensed partners. We prepare registration and label work with licensed partners in China. The importer of record and other regulated roles stay with licensed partners in China; the brand’s own filings stay the brand’s. Use our export-to-China service for this preparation.