Import Surveillance Requirements for Air Conditioning Units and Components Communiqué No: 2026/18

Scope of the Regulation

The surveillance measure applies to selected products under HS 8415, covering both complete units and key components commonly traded separately.

Air conditioning units classified under HS 8415.10.90.00.19 fall within scope when declared below USD 250 per unit.Components and parts classified under HS 8415.90.00.90.09 are subject to surveillance below USD 150 per unit.Indoor units of split air conditioning systems, classified under HS 8415.90.00.90.12, are covered when declared below USD 100 per unit.

Only imports declared at or above the applicable reference values may be released without surveillance certification.

Mandatory Surveillance Certificate

Where the declared unit value falls below the relevant reference threshold, importation is permitted only upon presentation of a valid Surveillance Certificate issued by the Ministry of Trade. The certificate must be obtained prior to registration of the customs declaration and must be correctly referenced in the declaration using the assigned document number and issue date.

Without a valid certificate, customs clearance will not be permitted, regardless of whether the goods are imported as spare parts, complete systems, or for after-sales service purposes.

Application and Review Process

Applications for Surveillance Certificates are submitted electronically through the national Single Window system using the designated industrial surveillance document type and selecting Communiqué No: 2026/18 as the legal basis. A qualified electronic signature is required, with an alternative submission channel available via the national e-government portal.

Where electronic submission is not technically feasible, physical applications may be accepted using the prescribed application form together with corporate registration documentation.

During the review stage, the authority may request original invoices, technical specifications, product descriptions, or supplementary explanations. Any inconsistency, deficiency, or contradiction identified will suspend issuance until fully remedied.

Customs Value Clarification and Practical Application

The Communiqué explicitly provides, in a separate provision, that the reference values introduced for surveillance purposes do not replace and do not constitute customs value. General customs valuation rules therefore remain fully applicable.

In practice—and specifically for value-based surveillance regimes—importers may lawfully increase the declared customs value by including legitimate foreign cost elements, such as international freight, insurance, royalties, tooling costs, or other overseas charges. By properly declaring these elements, the final customs value can be brought above the surveillance reference threshold, allowing the import to proceed without a Surveillance Certificate. This approach is accepted by customs authorities, provided that all cost elements are genuine, properly documented, and fully compliant with valuation rules.

This mechanism applies only to value-based surveillance measures and does not extend to quantity-based or non-value surveillance regimes.

Validity and Legal Effect

Surveillance Certificates issued under this Communiqué are valid for six months from the date of issuance. The presence of a certificate does not prevent customs authorities from examining or reassessing the declared value under general valuation principles. Conversely, correct and well-documented valuation may allow clearance without surveillance certification where thresholds are legitimately exceeded.

Enforcement and Compliance Risk

If inaccurate, misleading, or incomplete information is identified during the application or review stages, issuance of the Surveillance Certificate will be withheld until corrective action is taken. Non-compliance may result in customs delays, storage costs, and increased exposure to post-clearance audits.

Entry into Force

The Communiqué enters into force on the 30th day following its publication date. Importers with shipments in transit or under contract should reassess pricing structures and cost allocations to ensure compliance at the time of customs declaration.

Compliance Assessment

From a customs compliance and trade risk management perspective, this regulation targets a product group characterized by high import volumes, modular trade structures, and significant price variation between complete units and components. Importers of air conditioning equipment should review HS classification accuracy, unit pricing, and cost allocation models well in advance of shipment.

For value-based surveillance, lawful inclusion of overseas cost components can provide operational flexibility, provided documentation is robust and internally consistent. A shipment-by-shipment assessment is strongly recommended to determine whether surveillance can be avoided through correct valuation or whether proactive application for a Surveillance Certificate offers greater predictability and reduced clearance risk.

See relevant legislative document.