Split consignments may constitute one complete article: General Court clarifies GIR 2(a)

On 7 October 2026, the European Union’s General Court delivered its judgment in Case T-529/25. The judgment clarifies the application of section 2(a) of the General Rules for the Interpretation of the Harmonised System (GIR) to goods imported in an unassembled or disassembled state through separate consignments.

Key takeaway

It is not necessary for all components to be presented to customs at the same time in order to classify them as one complete article under GIR 2(a). Separate customs declarations, spread over several weeks or even months, do not preclude such classification where objective factors, assessed at the time of customs clearance, demonstrate that the components form a whole and comprise all the essential components of the complete article.

Background to the case

Between January 2019 and April 2021, frames, forks, motors, and other components of electric bicycles originating in China were imported under 27 customs declarations. The goods were declared as parts and accessories under CN heading 8714. The Belgian customs authorities, however, identified six clusters of declarations containing the components required to assemble complete electric bicycles. The invoices within each cluster carried the same reference number.

This distinction had a significant financial impact: complete electric bicycles originating in China and classified under CN subheading 8711 60 10 were subject to anti-dumping and countervailing duties, while the components, as separately declared, were not. The main proceedings concerned the alleged evasion of more than EUR 2.9 million in duties.

What did the General Court decide?

The General Court confirmed that components of electric bicycles may fall under the same tariff heading as the complete electric bicycle, even where they are:

• Invoiced by different suppliers;

• Transported in different containers;

• Declared under separate customs declarations; or

• imported over a period of several weeks or months.

The decisive question is whether objective factors, verifiable at the time of customs clearance, demonstrate that the components form a whole, are intended to be assembled into a single article, and comprise all the essential components of that article. Simultaneous presentation is merely one relevant indication and is not a mandatory condition.

Practical impact for businesses

The judgment is relevant beyond electric bicycles. It may have a broader impact on CKD (completely knocked down) and SKD (semi-knocked down) arrangements and other split consignments where components of a product are imported through multiple suppliers, containers, or declarations. The mere fact that components are imported in separate consignments or declared under separate customs declarations is therefore not, in itself, sufficient to prevent their classification as a single complete article under GIR 2(a).

The consequences may be significant where classification as the complete article results in higher customs duties, anti-dumping or countervailing duties, quotas, or other trade measures. The assessment should therefore extend beyond each individual declaration and consider the relationship between purchase orders, invoices, logistics flows, and assembly activities.

Deloitte’s Global Trade Advisory specialists are part of a global network of professionals who provide specialised support on global trade matters. Our professionals assist businesses in assessing and managing the implications of the developments described above.