لوائح الشحن الجوي لعام 2026 من الصين: القيود المفروضة على البطاريات، والجمارك الإلكترونية، وما يجب على المستوردين معرفته

مقدمة

As global trade moves through 2026, the air freight corridor between China and major destination markets — particularly the EU — faces its most significant regulatory tightening in years. For China-based exporters, cross-border e-commerce sellers, and the freight forwarders who move their cargo, three converging frameworks now shape how a shipment gets built, packed, and declared before it ever leaves a Chinese hub: stricter lithium battery shipping rules, EU carbon border pricing that is increasingly being pushed back onto the export side through DDP contracts, and fully mandatory digital customs filing.

Non-compliance at this stage doesn’t just mean delays on the EU side — it means fines, cargo holds, or outright rejection at the Chinese export hubs themselves, including Shanghai Pudong (PVG), Guangzhou Baiyun (CAN), and Shenzhen Bao’an (SZX).

This guide breaks down what’s changed in 2026, with a focus on what exporters and forwarders on the China side actually need to do differently — not just what EU-based importers are on the hook for.

1. EU CBAM — Why It’s Becoming an Exporter and Forwarder Problem, Not Just an EU Importer Problem

The EU Carbon Border Adjustment Mechanism entered its definitive regime on January 1, 2026. The transitional reporting-only period is over — financial obligations are now active for covered goods (iron and steel, cement, aluminium, fertilisers, electricity, and hydrogen).

On paper, CBAM obligations sit with the EU-based importer or their indirect customs representative. In practice, the cost and data burden are increasingly landing on the China side of the transaction:

Confirmed 2026 Certificate Pricing

Certificate sales themselves don’t begin until 1 February 2027, and the first annual declaration and surrender deadline is 30 September 2027, covering all embedded emissions from 2026 imports. From 2027 onward, pricing shifts from quarterly to weekly averages of EU ETS auction clearing prices.

Real cost impact — worked example: For 2026, the CBAM adjustment (phase-in) factor is 2.5%. A product with 2.0 tonnes of embedded CO2 per tonne, at Q1 pricing, works out to roughly 2.0 × €75.36 × 2.5% ≈ €3.77 per tonne of product for that quarter — before any deduction for carbon price already paid in China. That factor rises each year through full application by 2034, so the exposure compounds over time even at a flat certificate price.

Sector note: CBAM currently touches roughly 3% of total EU imports by volume, but those sectors account for over 50% of industrial emissions inside the EU ETS — meaning enforcement scrutiny on covered goods is disproportionately high relative to trade volume.

Why this matters for the China side:

• EU buyers are increasingly restructuring contracts toward البرنامج الإنمائي terms specifically to shift CBAM compliance cost and risk onto the exporting/forwarding side. If your quotes are still built on FOB/CFR assumptions for CBAM-covered materials, you’re likely underpricing the deal.
• Chinese manufacturers and exporters shipping CBAM-covered goods (steel, aluminium, cement, fertilisers) should expect EU buyers to start requesting embedded emissions data per shipment — this data collection needs to start now, not in 2027, since the September 2027 surrender deadline covers everything shipped in 2026.
• Forwarders quoting DDP on CBAM-covered cargo should build a CBAM cost line into landed-cost calculators rather than treating it as the buyer’s problem — clients will increasingly expect this to already be reflected in the quote.

2. Lithium Battery Air Shipping — A Packing-Line and Pre-Shipment QC Problem for Chinese Exporters

This is the most operationally significant change for exporters in 2026, and it hits at the sourcing/packing stage in China — before cargo ever reaches the airport.

What changed on January 1, 2026:

Previously, the 30% state-of-charge (SoC) ceiling applied only to loose/standalone lithium-ion batteries (UN 3480). Under IATA’s DGR 67th Edition, effective 1 January 2026, this scope has expanded significantly:

Lithium-ion batteries packed with equipment (UN 3481) with a Watt-hour rating greater than 2.7 Wh, and lithium-ion battery-powered vehicles (UN 3556) with a rating greater than 100 Wh, must now also be offered for transport at a state of charge not exceeding 30% of rated design capacity, or an indicated battery capacity not exceeding 25%.

In practice, this closes a loophole many Chinese suppliers and their forwarders relied on: devices shipped with batteries packed alongside (not installed) were previously exempt from the SoC ceiling that applied to loose cells. That exemption is gone.

Scale of exposure: lithium battery air shipments have grown roughly 25% year-on-year, with nearly 100 regulatory updates introduced across the 2026 IATA manuals — this is not a one-off tightening but a continuing trend that exporters should expect to keep adapting to.

Unchanged core compliance mandates (still enforced at Chinese export hubs):

• UN 38.3 Test Summary Reports required for all shipments containing lithium batteries, standalone or packed with/in equipment.
• Air Transport Conditions Appraisal Report — still required by Chinese ground handlers, issued by authorized bodies such as DGM or CQC, current-year validity.
• Cargo Aircraft Only (CAO) restrictions remain for high-capacity or Section IA/IB shipments — packages under Packing Instruction 968 Sections IA/IB must carry a CAO label in addition to standard marks.

Sourcing/packing implication for exporters: any product bundled with its battery — power tools, robotic devices, e-bikes, smart home units — that previously shipped fully charged for functional testing now needs a discharge step built into the packing line before air tender, or it will be held at PVG/CAN/SZX before it even departs. This is a factory-floor and QC process change, not just a paperwork change.

3. E-Customs & Digital Manifest Filing — What China-Side Exporters and Forwarders Must Submit Before Loading

The EU’s Import Control System 2 (ICS2) rollout has completed its final phase, with one lingering exception now closed. While ICS2 is an EU system, the filing obligation starts on the China side — cargo cannot be loaded without the correct pre-loading data submitted from origin.

Any filing still using version 2 messaging formats after these cutoff dates is rejected outright by the ICS2 Common Repository — meaning a Chinese forwarder still running outdated EDI templates now faces automatic rejection at the filing stage, not just a warning further down the chain.

Forward-looking note: by the end of 2026, ICS2 is expected to support multiple ENS filings, letting different parties in the supply chain (carrier, forwarder, importer) submit partial filings rather than requiring one party to hold the full dataset — worth watching for Chinese forwarders currently absorbing full ENS liability on behalf of clients, since this could redistribute some of that data burden.

Unchanged core requirements at origin:

• PLACI (Pre-Loading Advance Cargo Information): full MAWB/HAWB data must be filed electronically by the China-side forwarder before cargo is loaded.
• HS Code Precision: 6–8 digit codes required on all manifests. Vague descriptions (“samples,” “electronics,” “auto parts”) trigger immediate digital rejection and cargo holds at Chinese export terminals — this is enforced at origin, before the cargo ever reaches EU customs.

4. 2026 Action Checklist for Chinese Exporters and Forwarders

CBAM (if shipping covered bulk goods to the EU):

• Confirm whether your EU buyers are shifting to DDP terms for CBAM-covered materials, and build a CBAM cost line into your landed-cost quoting accordingly
• Start collecting and organizing supplier-side embedded emissions data now — buyers will start asking for this well before the 2027 surrender deadline
• Track the Q1–Q2 price trend (€75.36 → €75.28) when modeling client cost exposure for Q3/Q4 shipments

Lithium Batteries:

• Audit all battery-inclusive product lines you handle — not just standalone battery SKUs — against the new 30% SoC rule for packed-with-equipment shipments
• Confirm your Chinese manufacturing clients have updated UN 38.3 summaries and current-year Air Transport Conditions Appraisal Reports on file
• Build a discharge/testing step into pre-shipment QC for any device shipped with an installed or accompanying battery, before it reaches PVG/CAN/SZX

E-Customs:

• Verify your own EDI systems and any road/rail partners have transitioned off ICS1 and support current ICS2 messaging formats
• Confirm PLACI/ENS filing is fully automated on your end, with zero manual re-entry required before the terminal cut-off
• Tighten رمز النظام المنسق accuracy on all outbound manifests — vague descriptions now trigger holds at the Chinese export terminal, not just downstream

الخاتمة

The assessment is: this is both a risk and a selling point. Customers increasingly expect you to package CBAM cost lines, lithium battery discharge processes, and ICS2 automatic declarations together in your DDP quotes.

Whoever standardizes these capabilities first will be able to capture more market share amidst this year’s compliance anxieties. Competitors who still consider this “an EU matter” will gradually fall behind due to PVG, CAN, and SZX’s restrictions on shipments.

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