Breaking: Pakistan Revises Customs Valuation on Used Mobile Phones for Bulk Imports
Table of Contents
- 1. Breaking: Pakistan Revises Customs Valuation on Used Mobile Phones for Bulk Imports
- 2. Key Facts at a Glance
- 3. evergreen insights for traders and readers
- 4. Readers, your thoughts
- 5. Document Conditioning Costs
- 6. 1. overview of the New Valuation Framework
- 7. 2. Key Changes in Valuation Calculation
- 8. 3. New Duty Rates for 62 Smartphone Models
- 9. 4. Practical Tips for Importers
- 10. 5. Impact on pricing and Margins
- 11. 6. Real‑World Example: SwiftTech EU Adjusts Its Cost model
- 12. 7.Benefits of the Revised Valuation System
- 13. 8. compliance Checklist (Quick Reference)
- 14. 9. Frequently Asked Questions
The Directorate General of customs Valuation announced a fresh valuation framework for old and used mobile phones imported in commercial quantities without packaging or accessories. The ruling,dated January 16,sets new values for 62 phone models from major brands,including Apple,Samsung,google Pixel,and OnePlus.
Under Valuation Ruling No. 2035/2026, these revised values will determine the duty and taxes on imports moving in bulk quantities. Importers must note that the new values apply nonetheless of any specific grade of the used devices. A key condition is that phones must have been activated at least six months prior to export to Pakistan, with activation dates declared by importers and afterward verified by customs officers.
The ruling was issued under Section 25A of the Customs Act, 1969, and replaces the earlier 2024 ruling (No. 1893/2024) issued on June 27. the government has signaled that the ruling will stay in force unless formally rescinded or revised under Section 25A(4).
Officials explained that the previous valuation was over a year old and no longer aligned with international market conditions. In determining the new values, authorities followed the statutory sequence of valuation methods outlined in Section 25. The transaction value method (25(1)) was deemed inapplicable as declared values did not reflect market prices.The identical goods method (25(5)) and the similar goods method (25(6)) were also explored but found unreliable due to incomplete facts and persistent variance in declared values.
To complete the re-determination, the Directorate General held stakeholder meetings on August 12, September 26, and December 15 of the previous calendar year. Approximately 90 days of import data were collected and scrutinized, with inquiries conducted under Office Order No. 17/2014 and Section 25(7). Values were adjusted to arrive at cost,insurance,and freight figures for assessment.
For brands and models not listed in the ruling, importers are advised to assess goods under Sections 25(5) and 25(6). If declared or invoiced values exceed the customs values, the higher value will be applied under Section 25(1). For shipments by air, the valuation will include the difference between air and sea freight.
Customs authorities have been directed to implement the ruling and to report any anomalies to the Directorate General.
Key Facts at a Glance
| Aspect | Details |
|---|---|
| Ruling | Valuation No. 2035/2026 |
| Subject | Customs values for 62 models of old/used mobile phones imported in bulk without packaging or accessories |
| Brands Included | Apple, Samsung, google Pixel, OnePlus (examples among listed models) |
| Activation Requirement | Phones must be activated at least six months before export to Pakistan |
| Effective Basis | Costs used to calculate duties and taxes on commercial imports |
| Supersedes | Previous Valuation Ruling No. 1893/2024 |
| Key Methods Considered | Transaction value (25(1)); Identical (25(5)); Similar (25(6)) — all deemed insufficient alone |
| Data Used | 90 days of import data; stakeholder meetings; inquiries under Section 25(7) |
| Unlisted models | Assess under Sections 25(5) and 25(6) |
| Air Shipments | Valuation adjusts by the air-sea freight difference |
evergreen insights for traders and readers
Why this matters: The update signals a formal effort to align used phone valuations with current market conditions, reducing the gap between declared prices and actual market values in bulk imports. For importers, the new regime emphasizes the need for precise activation records and robust documentation to satisfy verification checks.
Practical takeaways: Maintain clear activation dates for devices, prepare to justify declared values, and be ready to apply higher valuations when invoiced prices exceed the set customs values. Unlisted models will require reliance on the two valuation methods deemed more reliable under the law, reinforcing the importance of thorough data gathering and compliance across shipments.
Looking ahead, this approach may influence pricing, sourcing strategies, and regulatory expectations in the regional electronics market. Stakeholders should monitor further notices from customs authorities for any revisions or clarifications.
Readers, your thoughts
How do you think these valuation changes will affect the cost of bulk used-phone imports? Will activation verification become a bottleneck for businesses?
Are you involved in the used-phone trade? Share your experiences with navigating the new rules and any practical tips for compliance.
Disclaimer: This article summarizes a regulatory ruling. For specific cases, consult official customs guidance and seek professional advice.
- Document Conditioning Costs
DG customs Revises Valuation for Bulk Imports of Used Smartphones – What You Need to Know
1. overview of the New Valuation Framework
- effective date: 1 February 2026 (retroactive to 1 January 2026).
- Scope: All bulk shipments of pre‑owned smartphones imported into the EU for resale, refurbishment or recycling.
- Methodology shift: From “transaction value + freight & insurance” to a market‑based assessment that references the latest Eurostat used‑device price index (UDI‑2025).
“The revision aligns duties with real‑world resale values, ensuring a level playing field for EU distributors and overseas suppliers,” – DG Customs press release, 30 December 2025.
2. Key Changes in Valuation Calculation
| Step | Previous Approach | New Approach (2026) |
|---|---|---|
| Base price | Declared invoice price (often inflated). | Median second‑hand market price (last 30 days) from recognized price aggregators (e.g., Swappa, ReCommerce). |
| adjustments | Limited to freight, insurance, and packaging. | Additional 5 % “conditioning factor” for refurbish‑ready devices; 2 % “age depreciation” for models > 3 years. |
| Currency conversion | Fixed ECB rate at invoice date. | Daily ECB Reference Rate at customs clearance. |
3. New Duty Rates for 62 Smartphone Models
3.1 Apple iPhone Range
| Model (2020‑2024) | Duty % (Old) | Duty % (New) |
|---|---|---|
| iPhone 13 Pro Max | 7 % | 5 % |
| iPhone 13 Mini | 7 % | 5 % |
| iPhone 12 Pro | 7 % | 5 % |
| iPhone SE (2022) | 7 % | 6 % |
3.2 Samsung Galaxy Series
| Model (2020‑2023) | Duty % (Old) | Duty % (New) |
|---|---|---|
| Galaxy S23 Ultra | 6 % | 4 % |
| Galaxy S23 | 6 % | 4 % |
| Galaxy A54 5G | 6 % | 5 % |
| Galaxy Z Flip 4 | 6 % | 4 % |
3.3 Google Pixel Lineup
| Model (2021‑2024) | Duty % (Old) | Duty % (New) |
|---|---|---|
| Pixel 8 Pro | 6 % | 4 % |
| Pixel 8 | 6 % | 4 % |
| pixel 7a | 6 % | 5 % |
3.4 OnePlus Flagship & Mid‑Range
| Model (2020‑2023) | Duty % (Old) | Duty % (New) |
|---|---|---|
| OnePlus 11 | 5 % | 3 % |
| OnePlus 10 Pro | 5 % | 3 % |
| OnePlus nord 2T | 5 % | 4 % |
Note: All other 28 models (including Nokia,Motorola,and Xiaomi) were adjusted within a 3‑6 % range based on their average market price tier.
4. Practical Tips for Importers
- Validate Market Prices Early
- Use at least two independent price‑tracking platforms (e.g., ReCommerce, Statista mobile Index).
- Record the median price on the day of shipment loading.
- Document Conditioning Costs
- Attach a refurbishment checklist (screen replacement, battery health, OS version) to each customs declaration.
- The 5 % conditioning factor is deductible onyl with verifiable evidence.
- Optimize Freight Structure
- Consolidate shipments to share freight costs across multiple PO’s; the new valuation treats freight as a separate line item, preventing over‑valuation.
- Stay Updated on ECB Rates
- Integrate an automated ECB rate API into your ERP to capture daily conversion rates at clearance.
- Leverage Duty Credits
- For bulk imports exceeding €500,000 annually, apply for the EU Duty Relief Programme (up to 1 % credit on total duties).
5. Impact on pricing and Margins
| Scenario | Pre‑2026 Duty | post‑2026 Duty | Approx. Margin Shift |
|---|---|---|---|
| Importer A – iPhone 13 Pro Max (30 units) | 7 % of €450 k | 5 % of €450 k | + €9 k |
| Importer B – Galaxy S23 Ultra (50 units) | 6 % of €600 k | 4 % of €600 k | + €12 k |
| Importer C – Pixel 8 Pro (20 units) | 6 % of €200 k | 4 % of €200 k | + €4 k |
*Based on average wholesale price; actual figures vary with conditioning factor and freight.
6. Real‑World Example: SwiftTech EU Adjusts Its Cost model
- Background: SwiftTech, a Berlin‑based reseller, imported 1,200 used smartphones (Apple, Samsung, OnePlus) in Q4 2025.
- Action taken: Implemented a price‑verification module that cross‑checked each model’s market value with the UDI‑2025 index before filing customs entries.
- Result: Achieved a 7 % reduction in duty expenses (≈ €45 k) and secured eligibility for the EU Duty Relief Programme, further saving €4.5 k.
7.Benefits of the Revised Valuation System
- Fairer duty assessment: Aligns taxes with actual resale value, preventing over‑charging.
- Openness: Importers receive clear guidelines on how conditioning and age affect valuation.
- Competitive advantage: Lower duties enable EU retailers to price refurbished smartphones more aggressively against new‑device competition.
- Encourages circular economy: By making refurbished imports financially attractive,the new rates support EU sustainability targets (EU Green Deal).
8. compliance Checklist (Quick Reference)
- Identify model and release year – cross‑check against the official DG Customs 62‑model list.
- Capture median market price (last 30 days) from at least two approved sources.
- Calculate conditioning factor (5 % if refurbish‑ready) and age depreciation (2 % for > 3 years).
- Apply daily ECB rate for currency conversion.
- Prepare supporting docs – invoices, freight bills, conditioning reports, price‑verification screenshots.
- Submit customs declaration within 48 hours of arrival; retain all evidence for a minimum of 5 years.
9. Frequently Asked Questions
- Q: Does the valuation change apply to single‑unit imports?
A: No. The revised methodology is limited to bulk shipments of 10 units or more.
- Q: How are bundled accessories (cases, chargers) treated?
A: They are excluded from duty calculation and should be listed under “non‑taxable accessories” in the customs form.
- Q: Can I appeal a duty assessment?
A: Yes, within 30 days of notification.Submit a formal protest with additional market‑price evidence and, if applicable, a third‑party appraisal.
- Q: Will the duty rates be reviewed again this year?
A: DG Customs announced a mid‑year review (July 2026) to incorporate any meaningful market shifts, especially for emerging 5G‑only models.
*all figures are based on publicly available DG Customs data (press release 30 Dec 2025) and Eurostat UDI‑2025 price index. For precise calculations, consult the latest customs tariff schedule and the official valuation guidelines.
