In our March 2026 post, we described how EU customs authorities are targeting split shipments and post-entry assembly. We also asked whether General Rule of Interpretation (GRI) 2(a) really requires components to be presented “simultaneously” before they can be classified as the finished article. The General Court of the European Union has now answered that question, and the answer favours the authorities. In its judgment of 7 October 2026 in Prestige Rijwielen (T‑529/25), the court ruled that simultaneous presentation is not legally required. Parts imported in separate shipments and declarations, even months apart, can be classified as the complete article presented unassembled or disassembled where objective evidence shows that the parts form a whole and include all the article’s essential components. The ruling should not, however, be read or applied too broadly: it does not turn every series of import of parts into an import of finished products.

Why this matters

The judgment removes one of importers’ strongest defences against reclassification: the argument that goods arriving separately must be classified separately. Customs authorities can now look across a series of declarations and treat them, taken together, as an unassembled finished product. The financial consequences are greatest where parts attract lower duties than the finished product, for example where anti-dumping or countervailing duties apply only to the assembled article, as they do for Chinese e-bikes. Although the case concerns e-bikes, the reasoning could apply to any situation where components attract lower customs duties than the finished product.

At the same time, the ruling raises real and important practical questions about how far it reaches. The court answered a narrow question in a specific setting. The case involved a pattern of declarations that customs could tie to parts of complete e-bikes through matching invoice references and quantities, and a consignee that had stopped importing finished products. The judgment does not mean that every series of component imports can be treated as a finished product. Authorities will still need compelling, objective evidence that the imported parts are in fact assembled into a finished product after entry. Suspicion based on timing alone, or on the theoretical possibility of assembly, should not be enough.

Background to the dispute

The Antwerp Court of Appeal referred the case during criminal proceedings brought by the European Public Prosecutor’s Office (EPPO) and civil claims brought by the Belgian customs administration. Between January 2019 and April 2021, a Belgian importer’s customs representative filed 27 import declarations at one customs office for frames, forks, motors and other e-bike parts from two Chinese suppliers. The goods were declared as parts under CN heading 8714. That heading avoids the anti-dumping and countervailing duties on Chinese e-bikes under CN subheading 8711 60 10. Customs challenged the practice and considered that these were not imports of e-bike parts, but in fact imports of unassembled e-bikes.

The court’s conclusions

GRI 2(a) sets no timeframe within which the components of an article must be presented, so the court concluded that simultaneous presentation is not a condition for classifying them as the complete article. What matters is whether the parts have the essential character of the complete article, which must be verifiable on the basis of objective factors at the time of customs clearance. Building on the Court of Justice’s ruling in X BV (C-107/22), the court reasoned that any other reading would let importers choose their classification simply by filing separate declarations. It also cited the European Commission’s warning that staggered shipments have become widespread, highlighting a risk of manipulation.

The evidence customs will be looking for

The referring court relied on the same buyer, intermediary, declarant and customs office; quantities of parts matching a set number of complete e-bikes; invoice references identifying sets of parts; and the consignee’s switch away from importing complete e-bikes. The national court must still decide whether this evidence is enough. However, the judgment confirms that authorities may combine evidence across declarations and over time to build their case.

What this means for importers and customs representatives

Importers can no longer argue that parts must be classified separately because they arrived in different consignments, came from different suppliers or were declared weeks or months apart. Customs authorities and the EPPO can link declarations through common invoice references, matching quantities, a shared declarant and customs office, and a shift away from importing finished products.

The exposure is greatest where parts fall under a lower-duty heading than the finished product, especially where trade defence duties apply only to the assembled article. Reclassification can then lead to additional customs, anti-dumping and countervailing duties, and criminal proceedings.

Importers should review their import patterns now. Where the classification is open to challenge, they should apply for Binding Tariff Information and fully disclose the import model. They should also document that the operations carried out after entry go beyond mere assembly and/or that parts are used as parts. Customs brokers should carry out enhanced due diligence on their clients. They should flag clients that switch from finished goods to parts when duties rise, and record the basis for each classification decision.