Full Import vs SKD Assembly in Europe

Full import and SKD assembly differ in what crosses the border and where the product is finished — not in who designed it or who manufactures the boards. In full import, a finished, tested and packed charger arrives and is sold as received. In SKD assembly, tested board sets and component kits arrive and final assembly, end-of-line testing and packing happen at a site in Europe. The platform, the supplier and the certification obligations are the same in both models. This page sets out what actually changes, what does not, and the one claim that should never be made about either.

What changes, item by item

  • Customs classification. A finished charger and a kit of boards and components can fall under different headings. General interpretative rule 2(a) of the Harmonized System can require an incomplete or unassembled article to be classified as the finished article where it already has the essential character of that article, so a kit is not automatically classified as parts. Confirm the classification and the applicable rate in the EU TARIC database for the specific product and origin before the model is chosen, and consider requesting binding tariff information from a national customs authority.
  • Origin. Assembly in Europe does not by itself make a product EU origin. See the section below.
  • Working capital and stock shape. This is the substantive commercial difference. Stock held in Europe becomes generic boards and components rather than finished variants, so the same inventory can serve several models, connector types, enclosure colours and firmware configurations.
  • Variant response time. A change of label, connector, enclosure or firmware configuration can be answered from local stock instead of from a new production run and a new shipment.
  • Service and repair. A site that assembles the product can also repair it at board level, which shortens the warranty loop and keeps failed units out of return freight.
  • Test responsibility. The end-of-line test moves to your line and must be equivalent to the factory test. This is the obligation that people underestimate; it is also the reason engineering transfer matters more than the kit price.

What does not change

  • Production lead time. eectec's serial production lead time is 45 days in both models. Kits are produced on the same line, to the same schedule, as finished units.
  • Ocean transit. Kits travel the same route as finished chargers. SKD does not compress transit time; it changes what is in the container and what happens after it arrives.
  • Minimum order quantity at board level. 300 sets for standard controller boards and 1,000 sets for custom board designs, in both models.
  • Who the manufacturer is in EU product law. The party placing the product on the market under its own name or trademark holds the CE technical file and the declaration of conformity, whoever physically assembled the unit. See ODM vs OEM vs white label.
  • The design and its field record. The same platform, the same firmware and the same failure data apply — a rolling 12-month hardware failure rate of 880 PPM across shipped boards, with over 1,000,000 AC and DC boards delivered to date.

Origin: the question that has to be asked of customs, not of a supplier

Article 60(2) of the Union Customs Code, Regulation (EU) No 952/2013, provides that goods whose production involves more than one country originate in the country where they underwent their last substantial, economically justified processing or working, in an undertaking equipped for that purpose, resulting in the manufacture of a new product or representing an important stage of manufacture. The European Commission's guidance on non-preferential rules of origin adds the constraint that matters here: processing which is not economically justified, or which consists of minimal operations, does not confer origin even if it is the last operation performed.

The consequence is that no supplier can tell a customer what the origin of its assembled product will be. Whether a given operation passes the test depends on what is actually performed at the site, with what equipment, and why. The reliable route to an answer is a binding origin information decision from a national customs authority, obtained before the supply chain is committed. Where a public tender or a funding programme carries a local-content condition, that condition should be read directly and matched against the customs assessment, not against a supplier's description of its model.

eectec does not claim that SKD assembly confers EU origin, satisfies any local-content rule, or makes a product compliant with any "made in Europe" requirement. Our boards are manufactured in China. What we support is the execution side of a customer's localisation strategy: kits, engineering transfer and line onboarding. The legal characterisation belongs to the customer and to customs.

What eectec supplies in each model

European buyers increasingly want charging hardware assembled close to home — for lead time, serviceability and local-content strategy. That is the model we have run for a decade: 1,500+ charger builders in China assemble their own products on our boards. We support the same partnership in Europe at whatever depth of localisation a customer chooses.

Full import

Complete-Unit ODM

  • We design, build and test the complete charger under your brand; it arrives ready to sell
  • Minimum order quantity: 500 units for AC chargers, 100 for DC chargers, 20 for charging stacks and storage-integrated systems
  • Lowest demand on your organisation; least flexibility once units are in transit
How a project runs →
SKD

SKD kits and your assembly line

  • Tested board sets and component kits; final assembly and end-of-line test at your European site
  • Includes line onboarding, test procedures and ATE fixture transfer
  • Minimum order quantity at board level: 300 sets standard, 1,000 sets custom design
Local assembly models →
Board level

Control platform supply

  • You own the complete product design; we supply the control mainboards and firmware stack
  • Annual capacity: 1,000,000+ controller boards, 200,000+ AC chargers, 10,000+ DC chargers
  • The deepest form of localisation, and the one that demands the most engineering on your side
Controller specifications →

We back your localisation strategy with engineering transfer — test programmes, fixtures, documentation and training move to your line, not locked away in ours.

How to decide

  • Choose full import when the range is narrow, volumes per variant are predictable, and there is no site or team to absorb assembly. The organisational cost of SKD is not recovered on a single high-volume model.
  • Choose SKD when the range is wide relative to volume, when configuration is decided late, when service response time is a competitive factor, or when a customer or tender requires assembly in Europe as a commercial condition. The gain is flexibility and service, and it is paid for with a line, fixtures and trained operators.
  • Choose board-level supply when you already have a product design and a manufacturing organisation, and the control platform is the part you do not want to develop.
  • Settle the customs questions first — classification, rate and, if origin is commercially relevant, a binding origin information decision. These determine whether the model works financially, and they are answered by customs, not by a supplier.

Questions we are asked about this

What is the difference between full import and SKD assembly for EV chargers?

In full import, a finished, tested and packed charger crosses the border and is sold as received. In SKD assembly, tested board sets and component kits cross the border and the final assembly, end-of-line testing and packing take place at a site in Europe. The design, the platform and the supplier are the same in both cases; what changes is where the product is finished, what is declared at import, and who performs the final test.

Does assembling a charger in Europe make it EU origin?

Not automatically. Article 60(2) of the Union Customs Code, Regulation (EU) No 952/2013, provides that goods produced in more than one country originate where they underwent their last substantial, economically justified processing or working in an undertaking equipped for that purpose, resulting in a new product or an important stage of manufacture. The Commission's guidance on non-preferential rules of origin states that processing which is not economically justified, or which consists of minimal operations, does not confer origin. Whether a particular assembly operation meets the test depends on what is actually done at the site and must be assessed case by case; a binding origin information decision from a national customs authority is the way to settle it with legal certainty.

Does SKD assembly reduce import duty?

It changes the classification of what is imported, which may or may not change the rate. A finished charger and a kit of boards and components can fall under different headings, and general interpretative rule 2(a) of the Harmonized System can require an incomplete or unassembled article to be classified as the finished article where it has its essential character. Duty rates for the relevant subheadings should be confirmed in the EU TARIC database for the specific product and origin rather than assumed, and the classification itself is worth confirming with customs in advance.

Does SKD assembly shorten lead time?

It does not shorten production or ocean transit; it changes what you are holding when a customer order arrives. eectec's serial production lead time is 45 days in either model, and kits travel the same route as finished units. What SKD changes is that the stock held in Europe is generic boards and components rather than finished variants, so a change of enclosure, label, connector type or firmware configuration can be answered from local stock instead of from a new production run.

What does a company need in place to run SKD assembly?

A site, trained operators, end-of-line test equipment and a controlled process. eectec supports this with engineering transfer: test programmes, ATE fixtures, documentation and training move to the customer's line. The obligations that come with it are that the end-of-line test must be equivalent to the factory test, the traceability record has to be maintained locally, and the party placing the product on the market under its own name holds the CE technical file for the product as assembled.

Is SKD the same as CKD?

They differ in how far the product is disassembled. SKD, semi knocked down, ships major assemblies — in EV charging, tested board sets, enclosure parts and component kits — for a short final assembly. CKD, completely knocked down, ships the product at component level for a full build, including operations such as board assembly. CKD demands substantially more equipment and process control on the receiving line. The terms are commercial rather than legal, and neither term determines customs classification or origin on its own.

Who does the final quality test in an SKD model?

Your line does, using the procedures and fixtures transferred from ours. In our own factory the sequence is AOI after SMT, ATE circuit testing after through-hole assembly, functional test on every board, board-level burn-in, then full-function ATE testing and burn-in of every assembled charger before packing. The end-of-line portion of that sequence is what moves to an SKD line, and its equivalence should be documented, because it becomes part of your conformity evidence.

Does SKD assembly affect the CE marking?

The obligation does not move, but the evidence has to describe the product as actually assembled. The party placing the product on the market under its own name or trademark remains the manufacturer under EU product law and holds the technical file. If assembly, cabling or configuration differs from the tested configuration, that difference belongs in the technical documentation and may require assessment. Agree with the supplier in advance which test reports cover which configurations.

Can we start with full import and move to SKD later?

Yes, and starting that way is usually cheaper. The transferable parts are the test programmes, the fixtures and the documentation, so the practical question to settle at the first contract is whether those are available for transfer and on what terms. Building the first volumes as full import also produces the field data that makes the business case for a line.

What is the smallest sensible SKD volume?

The floor is set by the board minimums — 300 sets for a standard controller board, 1,000 sets for a custom design — but the real threshold is the fixed cost of the line: equipment, fixtures, operator training and the quality system around them. Below the point where that fixed cost is recovered by the flexibility and service gains, full import is the cheaper answer. That calculation is specific to a product range and is worth doing explicitly rather than by analogy.

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