Shanghai Professional Daily Chemicals Import Customs Declaration Agent Full Process Analysis and Compliance Key Points Summary

I.Background and Practical Difficulties of Daily Chemicals Import

In the first quarter of 2026,the import declaration volume of cosmetics at Shanghai Port increased by 18.7% year-on-year,among which three categories of facial skin care,body cleansing and baby care account for 70% of the total.European brands focus on anti-aging lines,while Japanese and South Korean brands focus on the sensitive skin and whitening tracks.This category differentiation directly leads to differences in regulatory focus.High-end face creams imported from France often trigger quarantine approval because they contain animal and plant extracts such as propolis and centella asiatica; for whitening essences imported from South Korea,if the niacinamide concentration exceeds 5%,an additional toxicological assessment report is required.These details cannot be mastered by ordinary traders in real time.

In actual operation,the most common stuck point is label compliance.The revised *Rules for Label Inspection of Imported Cosmetics* issued by the General Administration of Customs (GAC) at the end of 2025 clearly requires that all ingredients must be marked on the Chinese label,and the sorting order must be completely consistent with the original text.Many enterprises directly translate foreign labels and ignore the rule that ingredients with a concentration lower than 1% can be sorted arbitrarily,resulting in the entire batch of goods being required to be rectified.A more hidden risk lies in packaging materials: some pump heads and spray bottles contain metal springs,if the material composition is not declared in advance,they may be identified as solid waste.These links are interlocked,and one negligence will trigger a chain reaction.

II.Core Role of Zhongshen in the Import Chain

Zhongshen is positioned not as a document courier,but as a risk filter.We have an internal "three-level review" mechanism: after receiving the order,the category specialist first checks the matching degree between the ingredient list and the *Catalog of Used Cosmetic Ingredients*; then the customs affairs team confirms the accuracy of HS Code and regulatory conditions; finally,the on-site staff predicts the port inspection probability.This process can intercept 80% of the problems before shipment,rather than remedying them after the goods are stranded in the port.

In March 2026,we handled a batch of shampoo imported from Japan,and the formula list provided by the customer contained "methylisothiazolinone".The system shows that the limit of this preservative in leave-on products is 0.01%,but the customer could not provide a product type statement.We required the Japanese side to issue a "rinse-off" certification document,avoiding the return caused by incorrect classification later.This pre-judgment relies on real-time tracking of regulatory dynamics,rather than simple experience replication.

III.Phased Disassembly of the Whole Import Customs Declaration Process

1.Document Pre-review Stage: Early Matching of Ingredients and Qualifications

The core of this stage is "checking against standards" rather than "gathering documents".Documents required for importing daily chemicals include certificate of origin,free sales certificate,formula list,brief production process description and safety assessment report.But the key is not whether the documents are complete,but whether the content is self-consistent.For example,if an ingredient in the formula list is marked as "plant extract",the specific Latin name of the plant,extraction site and extraction solvent must be provided simultaneously,otherwise the customs will determine that the ingredient is unknown.

• Animal and plant-derived ingredients: Official quarantine certificate issued by the exporting country is required,and it is necessary to confirm in advance whether it is included in the *List of Prohibited Entry Goods*.Since 2026,skin care products containing bovine-derived ingredients,regardless of content,are required to apply for the *Animal and Plant Quarantine Permit for Entry*.
• Children’s products: In addition to conventional documents,toxicological test reports are also required,and the testing institution must be among the 25 laboratories recognized by the General Administration of Customs.
• Products claiming special functions such as "sun protection and whitening": Must obtain the registration certificate of the National Medical Products Administration (NMPA),rather than ordinary filing.Many customers confuse the difference between filing and registration,resulting in failure to declare after the goods arrive at the port.

Zhongshen’s practice is to establish an ingredient database,marking common risk ingredients into three levels of red,yellow and blue.Red means absolute prohibition,yellow requires additional certification,and blue is recommended for replacement.After the customer uploads the formula,the system automatically compares and generates a risk report within 10 minutes,which is three times more efficient than manual review,with a misjudgment rate of less than 2%.

2.Port Customs Declaration Stage: Precise Control of Classification and Price Verification

HS Code classification is a technical work.Although facial cleanser and makeup remover balm are both cleaning products,the former is classified under 3401.3000,and the latter under 3401.2000,with a tariff difference of 2 percentage points.In 2026,the customs has stricter review of "2-in-1" products.If a product claims both cleansing and makeup removing functions,it must be classified according to its main function,and a third-party test report is required for support.We once encountered a customer who classified "cleansing foam" under the cosmetics tax code 3304.9900.After being questioned by the customs,we submitted an ingredient analysis report to prove that the surfactant content exceeded 20%,and finally declared it under 3401.3000,avoiding high taxes.

The price verification link is more experience-dependent.The customs’ determination of the dutiable value of daily chemicals not only depends on the invoice amount,but also refers to the average import price of similar products in the same period.In 2026,the customs price database has been connected to the official website retail prices of major global brands.If the declared price is lower than 30% of the retail price,the system will automatically issue an early warning.Zhongshen’s response strategy is to prepare price explanation materials in advance,including discount policy documents issued by the brand,bulk purchase agreements,promotion period certificates,etc.These materials must be submitted simultaneously when declaring,and post-event supplementary submissions are basically not accepted.

3.Commodity Inspection Stage: On-site Verification of Labels and Quarantine

Commodity inspection is not a mere formality.In 2026,the sampling inspection rate for daily chemicals imported for the first time at Shanghai Port is no less than 30%.There are three key inspection points: whether the label covers the original label,whether the ingredients are prohibited,and whether the packaging is compliant.Label problems account for more than 60% of unqualified inspections.We require customers to reserve sufficient white background area when designing Chinese labels,and must not cover key information such as batch numbers and expiration dates on the original labels.Many customers design Chinese labels with transparent backgrounds for aesthetics,which will be judged as not meeting the "firm pasting" requirement.

The quarantine link mainly targets animal and plant ingredients.On-site customs officers may take samples and send them to the laboratory for testing,which takes about 15 working days.Zhongshen has established a green submission channel with port laboratories,which can shorten the cycle to 8 working days.However,this requires the *Import Cosmetics Safety Assessment Report* to be submitted in advance,and the testing items in the report must match the laboratory capabilities.We have an internal laboratory capability list,after the customer’s product ingredients are determined,we can directly match the corresponding laboratory to avoid finding that a certain item cannot be tested after submission.

IV.Actual Case: Manager Gao’s Import Dilemma and Solution

Manager Gao is the supply chain director of an import trading company.In early 2026,he imported a batch of high-end hand creams from Italy,with a total of 12 SKUs and a cargo value of about 500,000 euros.After the goods arrived at the port,they were detained by the customs on the grounds of "label ingredients inconsistent with filing".When Manager Gao contacted us,the goods had been stranded in the port area for 8 days,with a container detention fee of 1,200 yuan per day.

We retrieved the filing information and found that the problem lay in the ingredient "fragrance".It was written as "fragrance (spice)" when filing,but the Italian factory actually used "fragrance (containing limonene and linalool)".According to the 2025 new regulations,if the fragrance contains 26 EU allergens with a concentration exceeding 0.001%,it must be marked separately.The Italian factory believed that the total amount was less than 1% so no marking was required,but the customs calculated according to the concentration of a single allergen and determined that marking was mandatory.

The solution was divided into two steps: First,we assisted Manager Gao in submitting the *Label Rectification Application* to the customs,promising to affix supplementary labels in the customs supervised warehouse to mark the specific allergens; second,we contacted the Italian factory to issue a formula description,proving that the concentrations of limonene and linalool were both lower than 0.01%,and applied for low-concentration exemption.Finally,the customs agreed to the rectification plan,and the goods were released on the 12th day,avoiding return losses.Manager Gao calculated afterwards that if we had been asked to pre-review the labels in advance,the rectification cost would only be 2,000 yuan,while the container detention fee and expedited fee cost nearly 30,000 yuan.

V.Long-term Value of Professional Agents

Daily chemical import is not a one-time transaction,and regulations change every year.The import version of the *Cosmetics Production Quality Management Specification* will be implemented in July 2026,requiring overseas production enterprises to set up responsible persons in China,and the responsible persons must have quality audit capabilities.This means that importers should not only manage customs declaration,but also intervene in the overseas production system.Zhongshen has begun to assist customers in screening overseas audit institutions and lay out compliance systems in advance.

Another trend is the refinement of "batch management".The customs now requires products of the same SKU with different production batches to be declared separately,because the microbial indicators of different batches may be different.We have developed a batch management mini-program for customers,which can associate the customs declaration number,production date and inspection report by scanning the code,realizing full-link traceability.This system has helped three customers pass the customs AEO Advanced Certification,and the inspection rate has dropped from 30% to less than 5%.

The essence of choosing an agent is to purchase risk hedging capabilities.Zhongshen’s 20 years of accumulation is not document templates,but a problem database.We know which port is more sensitive to which ingredients,which season has stricter inspections,and which laboratory issues reports faster.This information cannot be obtained from public channels,and can only be precipitated from the actual operation of thousands of shipments.For importers,paying agency fees is not a cost,but a way to avoid greater hidden losses.