How to Import Generators From China: The Complete Guide

A stylized digital rendering of several different types of generators, including gas-powered portable designs, stationary commercial backup generators, a heavy-duty model mounted to a trailer, and solar-powered models.
Importing generators from China is a worthwhile business venture. However, challenges during the importing process must be accounted for and addressed. Learn what these challenges are and how to overcome them.
February 16, 2021
Last Modified: July 17, 2024
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Consumer and business demand for generators has risen in recent years and is projected to continue steady growth. During certain times of the year, like Hurricane Season and winter, demand for these products skyrockets. Many generators are imported from China due to their affordability compared to other sources. 

Key Takeaways

  • Generators are regulated by the Environmental Protection Agency (EPA).
  • The EPA requires generator motors to be accompanied by a Certificate of Conformity and an Emissions Control Label.
  • The California Air Resources Board (CARB) has stricter emissions regulations than the EPA, and generators sold in California must meet CARB standards.
  • Like many imported goods from China, generators are subject to Section 301 tariffs.

Below, we explain the requirements and processes involved for importing generators from China. 

Ensure Compliance With U.S. Emission Regulations

The government entity responsible for enforcing regulations on generators is the Environmental Protection Agency (EPA). Along with the EPA, Customs and Border Protection (CBP) serves as the first line of defense at the border for imports arriving in the U.S. CBP agents are tasked with reviewing import details and flagging shipments that aren’t in line with U.S. import rules. 

In order to provide proof that your imported generators comply with emission standards, you’ll need two documents from the EPA: A Certificate of Conformity and an Emissions Control Label.

EPA Certificate of Conformity

The Certificate of Conformity states that the engine used in the generator complies with EPA emission standards. Manufacturers must obtain this certification prior to offering a generator for sale in the U.S. 

While CBP and EPA guidelines don’t dictate that the certificate be presented at the time of import, it’s highly advisable to have it readily available. If there’s any question as to the validity of the generator being imported, CBP and EPA agents will look to the Certificate of Conformity for further clarification

EPA Emissions Control Label

The other important aspect that proves imported generators are compliant with U.S. emission standards is the EPA Emissions Control Label

This label is located on or near the engine and includes a few important details, such as:

  • The manufacturer of the engine
  • Trademark for the manufacturer
  • Model year of the engine
  • Statement from the EPA indicating that the engine is compliant
  • Type of fuel and tank capacity
  • Which EPA and CARB (if applicable) emission standards the engine complies with

If this label is visible on all the generators being imported, you should face little resistance for this portion of the customs clearance journey. 

EPA Form 3520-21

The last piece of EPA-specific documentation that importers need to have is Form 3520-21. This form is used when importing heavy duty, nonroad, or stationary engines. 

The information required on this form includes: 

  • Identification of the type of engine being imported
  • Manufacturer name
  • Model and serial number of the engines being imported
  • Manufacture date of the engines being imported

All of this information is reviewed by CBP agents at the time of entry to determine admissibility. 

It’s important to note that this form isn’t required to be submitted if the following four conditions are met. 

  1. The engines being imported are new
  2. They’re covered by an EPA Certificate of Conformity
  3. They bear an EPA Emission Control Label
  4. The original manufacturer of the engine is the importer

If all four of the above conditions are fulfilled, you won’t have to submit EPA Form 3520-21. 

Importing Generators For Sale in California

The Golden State has its own rules governing emissions, which requires importers to do some additional work. This is due to the fact that California Air Resource Board (CARB) emission standards are stricter than those set by the EPA. 

For generators to be eligible to be sold in California, they’ll need to be certified as CARB compliant. Engine manufacturers will need to follow a set process to earn this certification:

  1. Engine must be tested according to CARB specifications. 
  2. After the testing is complete, manufacturers need to send the results to CARB to be reviewed. 
  3. If the engine passes the CARB inspection, it receives an official certification and can be noted as such on the EPA Emission Control Label.

Once the above process is complete, the imported generators will be eligible for sale and use in California.

Many states have adopted California’s emissions standards, so your generators will need to be CARB compliant to be sold legally in the following states as well.

  • Colorado
  • Connecticut
  • Delaware
  • Maine
  • Maryland
  • Massachusetts
  • New Jersey
  • New York
  • Oregon
  • Pennsylvania
  • Rhode Island
  • Vermont
  • Virginia
  • Washington
  • Washington, District of Columbia

Other states are likely to adopt these standards over the next several years, so make sure to check your target market’s standards before you order a shipment of generators.

30 Minute Licensed Expert Consulting Will Personally Guide You
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Not Sure if Your Generators Comply With EPA and CARB Requirements? We can help.

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Confirm the Import Duty Prior to Importing

To calculate the duties that will be owed on your imported generators, you’ll first need to determine the correct Harmonized Tariff Schedule (HTS) code for the goods in question. Each eight-digit subheading code has a specific import duty amount applied to it. 

In the table below, I’ve compiled the HTS codes and rates of duty for some commonly-imported types of generators.

An infographic titled “HTS Codes and General Rates of Duty for Imported Generators”. The information is presented as a bar graph with three columns. From left to right, the columns are titled “HTS Code”, “Commodity Described”, and “General Duty Rate”. The presented information reads as follows.

HTS Code 8501.10.20.00: Synchronous electric motors not valued over $4 a piece. 6.7% duty rate.
HTS Code 8501.20.20.00: Universal AC/DC motors exceeding 37.5 W but not exceeding 74.6 W. 3.3% duty rate. 
HTS Code 8501.40.40.40: Single phase AC motors exceeding 74.6 W but not exceeding 735 W.
4% duty rate.

These are just a few of the several dozen HTS codes used to classify generators. The codes vary according to factors such as motor design, how much power the generator creates, and whether it incorporates photovoltaic elements.

Keep in mind that these are general rates that don’t include extra duties and tariffs that are often applied to Chinese imports.

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Section 301 Tariffs

In 2018, additional import duties were placed on imported goods from China through the introduction of Section 301 tariffs. The additional tariffs were rolled out in four separate products lists, and several types of generators are included among the listed products. 

Consequently, many generators imported from China are subject to an additional 25% tariff on top of general duties and other fees.  

Related: A Guide to China’s Section 301 Tariffs

Antidumping & Countervailing Duties

In addition to section 301 consideration, anti-dumping and countervailing duties (AD/CVD) can also come into play. These duties are applied when an imported product is sold in the U.S. for well-below market value. 

The United States International Trade Administration has several types of generators and generator components scheduled to review for possible AD/CVD actions. Announcements of final determinations are currently scheduled for September and November 2024.

Any goods or materials produced in the Xinjiang region are prohibited from being imported into the U.S. Read our article on the Xinjiang import ban to find out more and avoid having your shipment fined and detained.

Obtain a Customs Bond

All generator imports will require a custom bond, due to the fact that generators are regulated by the EPA. A customs bond is an official document that acts as an insurance policy for CBP to ensure import duties and fees are paid by the importer. Bonds are required for shipments over $2,500, or imports regulated by a U.S. government agency.

Related: How to Get a Customs Bond: A Guide for New Importers

Get Help Importing Generators From China

As you can see, importing generators from China is a complex task with many hurdles and challenges to overcome. However, you don’t have to go it alone. The team of experienced and licensed professionals at USA Customs Clearance is here to help you. 

We can manage the entire process of importing your generators from China to the U.S. Once we have the necessary details of your import, we handle the rest. You won’t need to worry about running into unexpected issues during the process.

Among our many services, we can provide you with:

Are you ready to power up your import business? Give us a call at (855) 912-0406 or submit a contact form online today!

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