Partnering with an IOR and an EOR helps prevent penalties and delays.
The real point of friction in refurbished equipment imports arises when these assets must be interpreted by different authorities operating within regulatory frameworks not designed for reuse cycles, reassembly, or the relocation of critical infrastructure. In this context, every decision made before shipment— how the product is described, how the invoice is structured, what is documented or omitted—directly impacts the outcome of the operation.
At that stage, the role of an Importer and Exporter of Record (IOR/EOR), such as Aerodoc, becomes essential to successfully deal with the regulatory and tax reviews inherent to the process.
The 3 Keys When Importing Refurbished Equipment for Data Centers
Tariff Classification
What Are the Most Common Issues?
- A generic HS code is declared, but the equipment includes modules or functionalities that alter its treatment.
- Shipments with multiple SKUs are classified as “parts” or “computers” without a consistent logic.
- Transceivers, batteries, radio/wireless components, and cryptographic elements are combined without proper declaration or segregation.
How Does an IOR/EOR Address This?
- It implements a master catalog that standardizes, for each device and component, the tariff classification, technical description, and key regulatory attributes that affect import clearance.
- It applies internal rulings or consistent classification criteria, with change audit trails when the same model undergoes a board or revision update.
- It designs documentation to support the HS code, including datasheets, functional descriptions, BOMs per kit, serial and part numbers, photos, and test reports.
Customs Value
Unlike new hardware, where list prices and benchmarks are well established, refurbished equipment involves numerous cost layers that, if not clearly documented, trigger immediate scrutiny from customs authorities.
What Are the Most Common Issues?
- The invoiced price appears “too low”, with no clear breakdown or justification for why it is reasonable for refurbished goods.
- Some actual costs—such as refurbishment, testing, spare parts, support, or logistics—are left out of the invoice, even when local regulations require them to be included in the dutiable value.
- The transaction involves related parties, creating room for challenges between customs value and internal pricing policies.
How Does an IOR/EOR Address This?
- It defines a clear and repeatable methodology for building the value of the equipment, explaining how the final price of a refurbished asset is constructed.
- It documents this methodology by product type, relying on market references, historical data, and reasonable depreciation criteria.
- It aligns contracts, invoicing, and Incoterms so that payment, declaration, and documentation all convey a coherent and consistent narrative.
Regulatory Risk
One of the less frequent—but more sensitive—risks of refurbished imports is that authorities may question whether the shipment contains reusable equipment or merely electronic waste.
What Are the Most Common Issues?
- The shipment fails to clearly demonstrate that the devices are operational and intended for productive use.
- There is no evidence that the assets have been tested, refurbished, or are covered by any form of warranty.
- Lack of traceability: it’s unclear which units are being imported, in what condition, or with what background.
How Does an IOR/EOR Address This?
- Presents documentation that confirms the equipment is functional and has been refurbished in accordance with defined standards.
- Clearly identify each unit to remove ambiguity about quantity, condition, or intended use.
Importing Refurbished Equipment with Aerodoc
The value of an IOR/EOR partner lies in structuring risk in a way that prevents operational decisions from turning into regulatory or fiscal contingencies that may later become complex to resolve.
If your company imports refurbished data center equipment and is currently facing issues related to tariff classification, questions about the declared customs value, or regulatory uncertainty regarding the assets’ condition, our team is available to provide support.
Please contact our specialists for further assistance.
Q&A
- How do international certifications influence the import process of refurbished equipment for data centers? Certifications such as CE, FCC, and RoHS are often required to demonstrate compliance with safety, emissions, and environmental standards. Their presence facilitates customs clearance and reduces the risk of regulatory delays.
- What extent does the country of origin affect the tariff treatment of refurbished equipment for data center deployment? The declared country of origin can influence import duties, particularly under free trade agreements. Accurate origin documentation is essential to avoid excessive tariffs and potential customs disputes.
- What are the fiscal risks of failing to document refurbishment-related costs when importing data center equipment? Omitting costs such as testing, repairs, or component replacement may lead to valuation challenges, tax reassessments, and penalties. Clear cost breakdowns help ensure compliance with international customs valuation rules.
- What are the regulatory differences between importing refurbished equipment for internal use versus for resale in the data center sector? Imports for internal use often face fewer regulatory requirements, whereas resale scenarios demand full compliance with local technical, tax, and labeling regulations, impacting licensing and duty obligations.
