How Do German and Dutch Contractors Source Building Materials from China?

German and Dutch contractors buy from China under a documentary regime that is stricter than most exporters expect and looser than most buyers fear. For any product covered by a harmonised European standard, the entry ticket is CE marking supported by a Declaration of Performance — and once a manufacturer has that, a member state may not add its own national approval on top for the characteristics the harmonised standard covers. Where a product is not covered by a harmonised standard, the picture reverses: Germany falls back on national approvals from the DIBt, and the Netherlands leans on KOMO certification that is voluntary in law and close to mandatory in practice. Knowing which of those two worlds a given product sits in is the single most useful thing a project buyer can establish before issuing an enquiry.

What does CE marking actually oblige a Chinese supplier to do?

Under the Construction Products Regulation, a manufacturer placing a product covered by a harmonised standard on the EU market must draw up a Declaration of Performance and apply the CE marking. The DoP is the document that matters: it states the declared performance for each essential characteristic, identifies the product by unique type code, and names the manufacturer — who carries the legal responsibility, wherever the factory is.

The harmonised standards a project buyer meets most often are:

• EN 14351-1 — windows and pedestrian doorsets
• EN 13830 — curtain walling
• EN 14041 — resilient, textile and laminate floor coverings
• EN 13964 — suspended ceilings
• EN 1090-1 — structural steel and aluminium components, which additionally requires the fabricator to hold a certified factory production control system with an execution class matched to the structure

Three practical points follow. First, the DoP must be available in the language of the member state where the product is sold, which means German for a German site and Dutch for a Dutch one; an English-only DoP is a defect. Second, CE marking is a manufacturer’s declaration, not a certificate someone hands out — but for most construction products it requires a notified body to have carried out initial type testing and to audit the factory production control, and the notified body number is checkable. Third, and most misunderstood: where a harmonised standard covers a characteristic, a member state may not require an additional national approval for it. Germany’s historic practice of adding national requirements to CE-marked products was found unlawful, and the German system was restructured accordingly. The comparison across markets, including the divergence of the UK after Brexit, is set out in window and door export certifications by market and in UKCA vs CE marking after Brexit.

Where German practice diverges: DIBt approvals and the Ü-Zeichen

For products outside the scope of a harmonised standard — and there are many, particularly in fixings, sealing systems, composite assemblies and anything novel — German building law requires a national usability verification. In practice that means one of:

• allgemeine bauaufsichtliche Zulassung (abZ) or the newer combined allgemeine Bauartgenehmigung (aBG), issued by the Deutsches Institut für Bautechnik
• allgemeines bauaufsichtliches Prüfzeugnis (abP), a general test certificate from an approved test body, common for fire behaviour
• a case-by-case approval for a single project

Products covered by a national approval carry the Ü-Zeichen conformity mark. For a Chinese manufacturer this is a serious undertaking: it typically involves testing at a German-recognised laboratory and ongoing external surveillance of the factory, and it takes many months. The buyer’s question is therefore not “can you get it” but “do you already hold it, and for which product type” — because a promise to obtain an abZ during a construction programme is not a schedule you can build on.

Where Dutch practice diverges: KOMO and the Bouwbesluit

Dutch building requirements sit in national building regulations, which since 2024 have been restructured under the Environment and Planning Act framework. Compliance can be demonstrated in several ways, but Dutch practice has a strong convention: the KOMO certificate. KOMO is a private, voluntary certification scheme, and it is important for a foreign supplier to understand both halves of that sentence. It is not legally mandatory. It is also written into a very large proportion of Dutch main contractor specifications and municipal expectations, so in commercial reality a product without KOMO faces a burden of proof that a product with it does not.

The second Dutch specificity is contractual. Traditional Dutch construction contracts run on the UAV conditions, and design-and-build on UAV-GC, and these allocate responsibility for material suitability in ways that differ from German VOB/B practice. A supplier used to selling on an ex-works basis into a trading company will not have priced for the obligations a Dutch main contractor assumes it is passing down.

Two obligations that catch importers, not exporters

These land on the German or Dutch company that imports, not on the Chinese factory, and they are routinely missed because they are not construction rules at all.

• German packaging law. Anyone placing packaged goods on the German market must register in the LUCID packaging register and participate in a dual system for the packaging, before the first shipment. This applies to the cartons, pallets and film around imported building products just as much as to consumer packaging, and enforcement is real. A contractor importing directly frequently discovers this after the goods have arrived.
• German supply chain due diligence. The Lieferkettensorgfaltspflichtengesetz obliges companies above a headcount threshold to run human rights and environmental due diligence across their supply chains, including foreign suppliers, and to report on it. A large German contractor will pass questionnaires and audit expectations down to its Chinese suppliers, and a supplier who cannot answer them will be dropped regardless of price or quality.

Alongside these sit the horizontal EU regimes that apply by product rather than by country: REACH and the POPs Regulation for substances, the EU Deforestation Regulation for timber and timber-containing products, and the Carbon Border Adjustment Mechanism for goods including steel, aluminium and cement. Each has its own scope, thresholds and phase-in dates, and each has been amended more than once — confirm the current position for your product and shipment date with a customs adviser rather than relying on a summary.

The customs and VAT route: why so much China cargo enters through Rotterdam

Both countries need the importer to hold an EORI number, and both apply the EU common customs tariff, so duty is the same wherever the goods enter. What differs is the cash-flow treatment of import VAT.

In Germany, import VAT (Einfuhrumsatzsteuer) is generally paid at import and recovered later through the VAT return, so the money is out of the business for a period. In the Netherlands, an importer holding an Article 23 licence may defer import VAT to the periodic VAT return, where it is declared and deducted in the same filing — a net cash effect of nil. For a contractor importing several containers of building materials this is a material working-capital difference, and it is the practical reason a great deal of China cargo destined for German and Belgian sites is customs-cleared in the Netherlands.

That is a decision for the project’s tax adviser, not for a supplier. What the buyer should settle before ordering is simply who is the importer of record, because that party carries the CPR obligations, the packaging registration and the customs liability. It is also the party for whom the landed cost has to be built, using the method in how to calculate landed cost for a China project order, with classification handled as described in what HS codes apply to furniture and building materials imports.

What German and Dutch buyers should demand before ordering

1. The Declaration of Performance for each product type, in German or Dutch, naming the harmonised standard and the notified body where one is involved.
2. Confirmation of which characteristics are declared and which are stated as NPD (no performance determined). An NPD against a characteristic the specification requires is a failure, and it is easy to miss.
3. For EN 1090 work, the fabricator’s FPC certificate, the execution class it covers, and welder and procedure qualifications.
4. For non-harmonised products in Germany, the existing abZ, aBG or abP number — held today, for the exact product type.
5. For Dutch work, whether KOMO exists for the product and, if not, what alternative evidence the main contractor will accept, agreed in writing before the order.
6. Contract furniture strength evidence where furniture is in scope, as covered in what EN 16139 requires from contract furniture in Europe.
7. Confirmation of who is the importer of record, and that party’s EORI, packaging registration and VAT position.
8. A responsible counterparty. If the supplier is a trading intermediary, establish which factory produces and whose name goes on the documents, because under the CPR the party placing the product on the EU market inherits the manufacturer’s obligations if it sells under its own name.

Where the package spans several trades, the boundary drawing matters as much as the compliance work — the method is described in how a sourcing agent splits a BOQ into factory-level RFQs, and what a BOQ-based quotation should and should not contain in what a BOQ-based quotation from China actually includes.

What this means in practice for a European project

The realistic conclusion is that the compliance regime rules some categories in and some out. Categories where Chinese factories routinely hold current EU evidence — lighting, sanitaryware, furniture, floor coverings, ironmongery, kitchen and joinery products, and increasingly windows and doors to EN 14351-1 — are straightforward to buy. Categories that depend on a German national approval the factory does not already hold, or on structural certification with an execution class it has never been assessed for, are not a sourcing problem but a programme risk, and are usually better bought in Europe.

A buyer who sorts the schedule into those two groups before issuing enquiries will spend a great deal less time reading declarations that were never going to work.

About FBM Sourcing

FBM Sourcing manages the entire China procurement package for overseas construction projects. Sourcing since 2014, we have shipped 1,000+ containers to project sites in 20+ countries, working with project owners, developers, main contractors and FF&E contractors on hotels, apartment buildings, schools, offices and other commercial buildings. All quotations, invoices and shipping documents are issued by FBM Sourcing — you deal with us, and we carry the responsibility. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price.

If you have a German or Dutch project package to price, send us the specification and we will tell you which items are realistically buyable from China with current EU evidence and which are not at https://fbmsourcing.com/china-building-materials-ffe-procurement/.

Frequently asked questions

Do Chinese building products need CE marking for Germany and the Netherlands?

Yes, where the product is covered by a harmonised European standard under the Construction Products Regulation. The manufacturer must draw up a Declaration of Performance and apply the CE marking, and the DoP has to be available in the language of the member state — German for a German site, Dutch for a Dutch one. Products outside the scope of a harmonised standard follow national routes instead.

Can Germany require a national approval on top of CE marking?

Not for characteristics that a harmonised standard already covers. Germany previously added national requirements to CE-marked products and that practice was found unlawful, after which the German system was restructured. National approvals from the DIBt — abZ, aBG or abP, carrying the Ü-Zeichen — remain required for products that fall outside a harmonised standard.

Is KOMO certification mandatory in the Netherlands?

No. KOMO is a private, voluntary certification scheme and is not a legal requirement. In practice it is written into a large share of Dutch main contractor specifications, so a product without KOMO carries a heavier burden of proof. Agree with the main contractor in writing, before ordering, what alternative evidence it will accept.

Why do so many China shipments for German projects clear customs in the Netherlands?

Because of import VAT cash flow. A Dutch importer holding an Article 23 licence can defer import VAT to its periodic VAT return, where it is declared and deducted in the same filing, giving a net cash effect of nil. In Germany import VAT is generally paid at import and recovered later. Duty rates are identical, since both apply the EU common customs tariff.

What obligations fall on the importer rather than the Chinese factory?

Several. The importer needs an EORI number and carries customs and VAT liability; in Germany it must register packaging in the LUCID register and join a dual system before the first shipment; and a large German contractor will pass down supply chain due diligence obligations under the Lieferkettensorgfaltspflichtengesetz. If the importer sells the product under its own name, it also inherits the manufacturer obligations under the Construction Products Regulation.