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Mulia Charcoal

Logistics · Germany import

Importing coconut charcoal to Germany

The German (EU) import mechanics for UN 1361 coconut charcoal from Semarang: how it is classified, the duty and import VAT, the ICS2/ATLAS entry process, and the EUDR position on charcoal.

Authored by
Andri Dharmawan
Founder & Director
Fact-checked by
Teguh Pranomo
Quality Control Manager
Last updated
Reading time
6 min

This page sits under the Mulia Charcoal Logistics pillar and covers the customs mechanics of importing into Germany and the wider EU customs territory. Logistics overview

Germany import at a glance

Classification, headline duty, import VAT, and who clears the cargo.

Commodity code
4402 20 00 00 ("of shells or nuts") under heading 4402
Headline duty
0% (Free) MFN; no usable Indonesia preference
Import VAT
19%
Entry documents
ICS2 ENS, ATLAS declaration, EORI, REACH proof
Customs clearance
Buyer's licensed customs broker
EUDR
4402 charcoal is in scope; the EU importer files a Due Diligence Statement
Trade term
FOB Tanjung Emas (Semarang) · CIF/CFR on request

What buyers in this market order

This comes from our own order book — the recurring accounts we ship to in this market. It describes what those buyers reorder, not the full range we produce.

Buyers here take the 28 mm cube — the largest size anywhere in that order book.

Across the five markets these guides cover, every account takes a 1 kg inner unit — printed box or plastic — packed into a master carton, and every account is private label: our briquette, your brand on the box.

Packaging formats and master-carton options Private label and white label

Every one of those accounts reorders. These are repeat programs, not one-off trial containers.

What these five markets buy is not the whole ladder — every grade we produce is specified on the grades page.

The full grade ladder Indicative FOB price per ton

Order book as of 2026-09-19

Who handles what

The division of labour for a 18 tons (one 20ft container) shipment. We export and document; you and your customs broker clear and deliver at destination.

The factory handles

  • Production and per-batch quality control, each batch with a Certificate of Analysis
  • Dangerous-goods-compliant packing, UN 1361 marking, and the safety data sheet (SDS)
  • Export documentation — commercial invoice, packing list, bill of lading, certificate of origin, dangerous-goods declaration, and the SP 978 weathering report
  • Delivery to Tanjung Emas (Semarang) under FOB, plus booking support

You and your customs broker handle

  • Ocean freight booking under FOB — or we quote CIF/CFR to your port on request
  • Destination customs declaration and clearance
  • Import duty, VAT or equivalent taxes, and destination port charges
  • EUDR due diligence — filing the Due Diligence Statement (DDS) via TRACES — and EU REACH registration or Only-Representative cover for placing the charcoal on the EU market
  • Final inland delivery to your warehouse

Commodity-code classification

Coconut shell charcoal falls under EU heading 4402. The correct, most specific code is 4402 20 00 00 ("of shells or nuts"); the residual 4402 90 ("other") is a documentary-mismatch risk in the automated ATLAS system. Both carry a Free base duty, so the code does not change the rate — but it must be declared identically on every document. Confirm the exact 11-digit ATLAS code with your customs broker.

Candidate codes:

  • 4402 20 00 00

    EU Combined Nomenclature / TARIC "Of shells or nuts" — the most specific subheading for carbonized coconut-shell charcoal. German ATLAS import declarations use the 11-digit code, the first 8 of which are this CN. Base (erga omnes) duty Free.

    Source (opens in new tab)

  • 4402 90 00 00

    Residual "Other". Some Indonesian exporters historically declared coconut-shell charcoal here, but in the EU it mis-signals a generic wood-derived product and creates an ATLAS documentary-mismatch risk; General Rule of Interpretation 3(a) gives precedence to the more specific 4402.20. Same Free duty, so the rate does not change.

    Source (opens in new tab)

Note: Declare 4402 20 00 00 ("of shells or nuts") + UN 1361 Class 4.2 identically on every document — commercial invoice, packing list, bill of lading, and certificate of origin. Persistent use of the residual 4402.90 can trigger the German ATLAS risk-profiling algorithm and a manifest-correction fee even though the duty is identical. Do not declare as 3802 (activated carbon) or 4401 (fuel wood). Confirm the exact 11-digit ATLAS code with your customs broker.

Duties & import VAT

EU customs duty on heading 4402 is a single layer — 0% (Free) MFN, the same for all origins — on top of which German import VAT (Einfuhrumsatzsteuer) is charged. Read the duty as a dated layer with its legal status, and the VAT as a separate recoverable line.

Layer Rate As of Legal status
Customs duty (erga omnes / third-country MFN) EU Common Customs Tariff for heading 4402, all origins; assessed on the customs (CIF) value Source (opens in new tab) 0% (Free) 2026-06-21 Confirmed. MFN is already 0%, so Indonesia's loss of GSP preference does not raise the duty.

Verified as of the date shown; duties and tariffs change without notice — confirm with your customs broker at booking.

Import VAT

Einfuhrumsatzsteuer (German import VAT): 19% — Charged on the customs value plus duty plus domestic charges to the first destination. Charcoal does not qualify for the reduced 7% rate. Fully recoverable as input tax by a VAT-registered importer; import-VAT deferment (Aufschubkonto) and input-VAT deduction are available, recovered via the German VAT return.

As of 2026

Source (opens in new tab)

Indonesia-origin duty preference

No usable duty benefit. EU MFN for 4402 is already 0%, so preference status is immaterial to duty. Indonesia's wood/wooden-articles section (S9a) graduated out of EU GSP on 1 January 2020, GSP preferences for the section were further suspended for 2026–2028, and Indonesia loses GSP beneficiary status entirely from 2027. Practically, this shifts the ATLAS entry from a preferential regime to a standard MFN regime but does not increase the tax burden.

Origin document: Standard certificate of origin for trade statistics and surveillance; a REX origin statement would only matter if a preference were claimed (none avails here, so it is optional for duty).

Source (opens in new tab)

How the preference position moved

Before 2026, importers could rely on a Form A or REX statement to claim GSP duty-free access for Indonesian charcoal; from 2026 that preference is suspended (Commission Implementing Regulation (EU) 2025/1909) and Indonesia loses GSP status from 2027. Because the underlying MFN rate is 0%, the change alters the declaration method, not the amount of duty paid.

Anti-dumping / countervailing

No anti-dumping or countervailing-duty measure was found for heading 4402 charcoal from Indonesia in the EU's trade-defence records; confirm with your customs broker.

Landed-cost worked example

Landed cost is the sum of the goods, the freight, and the import charges. The structure below holds for any lane; the duty and VAT components are public verified figures, while the FOB and freight are illustrative and quoted at booking.

FOB goods value
Illustrative only — your actual FOB applies
Ocean freight + DG surcharges
Quoted on request (indicative)
Duties & import VAT
0% duty + 19% Einfuhrumsatzsteuer (recoverable if VAT-registered)
Landed cost
FOB + freight + duties & import VAT

The formula is shown so you can plug in your own figures. The indicative FOB range per grade is published on the pricing pillar, and the landed-cost page carries this same layer model with a calculator that runs on your own freight quote — both are linked under Related topics below. Live numbers for your order are quoted at booking.

What your incoterm covers (FOB and the freight split)

The entry process

EU entry for a UN 1361 container follows the standard pre-arrival-then-declaration sequence, handled by the buyer's customs broker with data we supply.

Step by step:

  1. ICS2 security filing (ENS). A pre-arrival Entry Summary Declaration (ENS) is mandatory under ICS2 Release 3, which is live for maritime cargo entering the EU. The vessel-operating carrier files the master-level ENS and the forwarder/NVOCC files the house-level ENS (plain-language goods description, HS6 minimum, consignee EORI). "No MRN, no load" is enforced; ICS1 was fully phased out on 1 September 2025. The filing is the carrier's and forwarder's responsibility — the Indonesian factory supplies the export data they need.
  2. ATLAS import declaration. The import declaration is filed through the German ATLAS system by the buyer's customs broker under a customs power of attorney, using the 11-digit commodity code and the customs (CIF) value. The buyer needs a valid EU/German EORI; clearance cannot legally proceed without it. German terminals grant Class 4.2 cargo very short free time, so the broker should have the ATLAS entry ready against the arrival notice to avoid demurrage.

The export documents we supply

Dangerous-goods handling at German ports

The cargo arrives as declared UN 1361, Class 4.2 dangerous goods, and is handled accordingly at Hamburg and Bremerhaven. The classification and the prevention controls are covered on the dangerous-goods pages.

What UN 1361 is The 2026 rules Insured arrival & cargo protection

EUDR: charcoal is in scope of the EU Deforestation Regulation

This is regulatory information, not legal advice — see the disclaimer below.

EUDR — scope
Heading 4402 wood charcoal (including shell or nut charcoal) is listed in Annex I of the EU Deforestation Regulation (Reg. (EU) 2023/1115), with no carve-out for coconut-shell charcoal, so EUDR applies. Source (opens in new tab)
EUDR — when it applies
Reg. (EU) 2025/2650 postponed application to 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators. Source (opens in new tab)
EUDR — who files
The EU importer (the first operator placing the product on the EU market) must submit a Due Diligence Statement (DDS) via the EU Information System (TRACES), demonstrating plot geolocation, deforestation-free status (land not deforested after 31 December 2020) and legality. The factory is working toward supplying the geolocation, legality and traceability evidence the buyer needs to file that DDS. Source (opens in new tab)
EU REACH + CLP
Charcoal is a registrable substance under EU REACH (not an SDS-only product): an EU importer placing more than one tonne per year on the market must either hold its own registration or be covered by the non-EU manufacturer's appointed Only Representative (OR) holding a Letter of Access to the existing joint registration, whose lead registrant is COALSTER GmbH. Two substance identities are in play — generic "Charcoal" (EC 240-383-3, CAS 16291-96-6) and the coconut-shell-specific "Charcoal coconut shell" (EC 271-974-4, CAS 68647-86-9); confirm with the lead registrant / OR which one your tapioca-bound composition registers under. CLP self-heating-substance classification and labelling apply (UN 1361, Class 4.2). Source (opens in new tab)
EUTR (predecessor)
The EU Timber Regulation continues transitionally for certain timber harvested before 29 June 2023 but is superseded by EUDR; coconut shell is an agricultural byproduct rather than timber. Source (opens in new tab)

Production and transit lead time

Production takes about 21 days for a 20-ft container and 21–25 days for a 40-ft; sea transit from Semarang (IDSRG) to Hamburg and Bremerhaven runs about 32–45 days, for an indicative 53–70 days from order to arrival. A first order under a new brand adds 7–10 days to the production stage.

Class 4.2 dangerous-goods bookings need extra lead time, so book early. The SP 978 weathering window (at least 14 days) is part of our production and packing schedule, not added on top of it when the order is planned ahead.

Indicative only — subject to vessel schedule and booking confirmation, and never a guaranteed arrival date.

German ports & routing

Indicative ocean transit from Semarang (IDSRG) to the main German gateways:

  • Hamburg, Germany (DEHAM): about 32–45 days.
  • Bremerhaven, Germany (DEBRV): about 32–45 days.

Indicative; varies by line and season. Last updated 2026-06-22.

Frequently asked questions

What duty applies when importing coconut charcoal to Germany?
The EU third-country (MFN) duty on heading 4402 is 0% (Free), assessed on the customs (CIF) value. Indonesia's loss of GSP preference does not change this — MFN is already 0%. Confirm the live TARIC line and your 11-digit ATLAS code with your broker at booking.
Is German import VAT on charcoal recoverable?
German import VAT (Einfuhrumsatzsteuer) is 19%, charged on the customs value plus duty plus domestic charges. Charcoal does not qualify for the reduced 7% rate. It is fully recoverable as input tax by a VAT-registered importer with an EU/German EORI; deferment (Aufschubkonto) and input-VAT deduction apply, so it is a cash-flow event, not a permanent cost.
Does EUDR apply to coconut charcoal, who files, and when?
Yes. Heading 4402 charcoal is listed in Annex I of the EU Deforestation Regulation, with no carve-out for coconut shell. The EU importer (the first operator placing it on the market) files a Due Diligence Statement via TRACES, showing plot geolocation, deforestation-free status and legality. Application is 30 December 2026 for large/medium operators and 30 June 2027 for micro/small. We are working toward supplying the geolocation and legality evidence your DDS needs. EU REACH registration or Only-Representative cover is also required above one tonne per year — this is general information, confirm with counsel.
How long does shipping from Indonesia to Germany take?
We model the lane ex-Semarang (IDSRG) to the main German gateways — Hamburg and Bremerhaven — at roughly 32–45 days of sea transit; see the transit list above for the per-port range. Other German ports are available; confirm routing and the vessel schedule with the carrier at booking.

Shipping the same coconut charcoal to more than one country? Duty, tax and clearance differ by destination — here are our other market guides.

All country import guides

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