When handling the return or repair of imported medical equipment, especially for medical equipment with HS code 90181990, some special compliance and customs requirements are usually encountered. The following is a detailed analysis of this issue, and some possible solutions are given.

According to Chinas import regulations, there are strict regulations for medical equipment.import and exportEspecially for usedMedical EquipmentThe state has clear regulations prohibiting the import. Therefore, the following points need to be paid special attention to when repairing or returning medical equipment:

(1) Restrictions on UsedEquipment ImportsUsed medical devices are usually prohibited from being imported. This is to prevent the adverse impact of imported second - hand equipment on the domestic market.(2) Approval Document from the Ministry of Commerce:
Even for equipment used for repair, an approval document from the Ministry of Commerce is usually required. However, it is very difficult to obtain this approval document, and usually only enterprises with certain backgrounds are likely to successfully apply.For many enterprises, even if they handle returns and repairs legally and compliantly, they still face numerous difficulties:

(1) Difficulty in Customs Release:

Even with the approval document from the Ministry of Commerce, there is still great uncertainty in the actual customs release in operation.(2) Restrictions on Bonded Zone Repair:
Even if choosing to repair in the bonded zone, it is still necessary to confirm whether the HS code is on the permitted repair list. If it is not on the list, it still cannot be processed.Although there are huge obstacles to directly importing for repair, there are still some alternative solutions to consider:

1. Send Spare Parts

(1) Method:

Directly send the spare parts that need to be replaced or repaired to the country where the equipment is located, and then let local technicians or the customers technical personnel replace them.(2) Advantages:
Avoid the complex procedures of importing and exporting the whole machine, the operation is relatively simple, and the compliance risk is low.(3) Disadvantages:
The customer or local technicians need to have the corresponding repair capabilities.2. Send Technicians for Repair

Send the companys internal technicians with the required spare parts to the country where the equipment is located for on - site repair.

Directly send the spare parts that need to be replaced or repaired to the country where the equipment is located, and then let local technicians or the customers technical personnel replace them.This can ensure the repair quality, as it is completed by the companys own technicians, and the risk is controlled within the company.
Avoid the complex procedures of importing and exporting the whole machine, the operation is relatively simple, and the compliance risk is low.However, issues such as visa, travel expenses and time costs for personnel travel need to be considered.
The customer or local technicians need to have the corresponding repair capabilities.3. Other Alternative Solutions

(1) After - sales Service Contract:

When selling the equipment, sign a detailed after - sales service contract with the customer, stipulating the handling methods in case of equipment failure, including but not limited to spare part replacement, technical support and on - site service.(2) Local Partners:
Find qualified partners at the destination of equipment sales and authorize them to carry out equipment repair and maintenance.Overall, for medical equipment with HS code 90181990, it is very difficult, almost impossible, to carry out compliant operations for equipment return or repair directly through express imports at Shanghai Pudong Airport. Enterprises should try to choose other alternative solutions, such as sending spare parts, sending technicians for repair, or cooperating with local partners. These methods can avoid compliance risks to a certain extent and ensure the smooth progress of equipment repair and maintenance services.

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