---
title: "Is It Mandatory to Complete Two Full Customs Declaration Processes for China's Entrepot Trade in 2026?"
description: "Enterprises often feel confused about whether two declarations are required in entrepot trade. Under the 2026 compliance requirements，it is necessary to clarify the necessity and risks of two declarations. Through pre-document review and node coordination optimization，compliant and efficient operations can be realized to avoid customs penalties and port detention losses.。"
url: "https://www.sh-zhongshen.com/en/qa/2026-china-entrepot-trade-mandatory-two-customs-declarations.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-10-02"
dateModified: "2026-10-02"
brand: "Zhongshen Trading China"
answerCount: 8
---

# Is It Mandatory to Complete Two Full Customs Declaration Processes for China's Entrepot Trade in 2026?

## Question

 I am the person in charge of an enterprise engaged in entrepot trade with Southeast Asia. A recent batch of electronic components of our company is shipped from Thailand to the Netherlands via Hong Kong transit. The logistics provider we cooperated with before said that the policy has changed in 2026, and only one declaration is allowed for entrepot trade, but another customs broker said two declarations are mandatory. I am really纠结 now. Last year, a peer had their goods detained by customs due to non-standard declaration, which cost them more than CNY 50,000 in port detention fees and also damaged their cooperation with clients. The value of this batch of goods is CNY 5 million, I really can't afford any problems. I would like to ask whether two declarations are actually required in 2026? If they are mandatory, how to coordinate the process to avoid mistakes? What specific penalties will be imposed if the second declaration is omitted? I am really anxious right now, the client is urging for the goods, but I haven't even figured out the declaration process yet. 

## Answers
                            
### Answer 1 — Best Answer

Two declarations for entrepot trade are the core requirement for compliant operations in 2026，mainly targeting the two links of "inbound transit" and "outbound transit". When cargo ownership is transferred at the transit port，two declarations are required to complete customs filing，so as to avoid being identified as "smuggling" or "false declaration".

Pre-document review shall focus on the continuity of bill of lading endorsements: the transit port bill of lading must be endorsed by the first-hand seller to the transit trader，then endorsed by the transit trader to the final buyer，and all endorsements shall be consistent with the titles on commercial invoices and packing lists. In addition，**the "no processing in transit country" statement on the certificate of origin** shall be submitted during the first declaration to avoid customs questioning the authenticity of the goods.

For core node coordination，the first declaration (inbound transit) shall be completed 24 hours before the arrival of the goods to obtain the inbound filing list，the second declaration (outbound transit) shall be submitted 48 hours before the departure of the goods，and the outbound declaration form shall be associated with the inbound filing list number. Delayed coordination may lead to port detention of goods，resulting in port detention fees of 0.5% of the cargo value per day.

Abnormal contingency plans shall be prepared in advance: if document errors are found during the second declaration，you can apply for form deletion and re-declaration before customs completes the review，but this must be completed within 24 hours，otherwise you will be included in the customs key supervision list. In addition，**selecting ports with transit qualifications** (such as Hong Kong，Singapore) can simplify the declaration process and reduce review time.

Final compliance implementation shall ensure "consistency of four flows": cargo flow (bill of lading)，capital flow (foreign exchange receipt and payment)，document flow (invoice/packing list)，and information flow (declaration data) are fully matched. Customs has realized cross-border data networking in 2026，and any inconsistency will trigger automatic early warning，so regular data verification is required to avoid compliance risks.

**status:** accepted
**Author:** Michael Zhang
**Date:** 2026-10-02

### Answer 2

From the perspective of customs declaration, two declarations for entrepot trade are a necessary link for a logical closed loop. The first declaration is "inbound goods filing", which requires submission of transit agreement, copy of bill of lading and commercial invoice, and customs will issue an inbound filing number after passing the review; the second declaration is "outbound goods customs declaration", which requires association with the inbound filing number, and submission of the contract with the final buyer and certificate of origin.

If the second declaration is omitted, the customs system will show that the goods are "inbound but not outbound", triggering account hanging warning, which needs to be resolved by form deletion and re-declaration later, but this will affect the enterprise's credit rating. Customs launched the new "integrated transit declaration" system in 2026, which allows completing two declarations through the same platform to reduce data entry errors, it is recommended that enterprises use it first.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-02

### Answer 3

From the perspective of logistics path, two declarations for entrepot trade directly affect cargo ownership control. After the first declaration is completed, the goods enter the bonded warehouse at the transit port, and the cargo ownership is temporarily transferred to the transit trader; after the second declaration is approved, the cargo ownership is officially transferred to the final buyer.

If the second declaration is skipped, the logistics provider cannot release the goods legally, which may lead to the goods being detained by the bonded warehouse, resulting in container detention fees of USD 100-200 per day. In addition, choosing a direct transit scheme (such as Thailand-Hong Kong-Netherlands) can shorten the transit time, and the interval between two declarations shall not exceed 72 hours, reducing the risk of port detention. It is recommended that enterprises clarify the declaration responsibility in the logistics contract to avoid prevarication by logistics providers.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-10-02

### Answer 4

From the tax perspective, two declarations for entrepot trade are closely related to VAT deferment. During the first declaration, VAT in the transit country can be applied for deferment without immediate payment; during the second declaration, the VAT number of the final buyer shall be submitted to complete tax deduction. If the second declaration is omitted, the VAT deferment in the transit country will become invalid, and the enterprise needs to pay the overdue VAT and late fee (0.05% per day).

The new cross-border tax regulations in 2026 allow the use of "one-stop VAT declaration" for entrepot trade, which allows submitting the tax data of two declarations in combination to simplify the process. However, it should be noted that VAT deferment is only applicable to enterprises with transit qualifications, which need to file with the tax authority in advance.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-02

### Answer 5

From the perspective of foreign exchange receipt and payment compliance, two declarations are the key basis for foreign exchange verification and cancellation. After the first declaration, the enterprise shall submit the inbound filing list to the bank to complete the preliminary verification and cancellation of foreign exchange income; after the second declaration, submit the outbound declaration form to complete the final verification and cancellation.

If the second declaration form is missing, the bank cannot complete foreign exchange settlement, and the foreign exchange will be frozen for 3-6 months. The new "entrepot trade foreign exchange linkage" function added to the CIPS system in 2026 can automatically associate the data of two declarations to realize real-time foreign exchange settlement. It is recommended that enterprises use the CIPS payment channel to reduce the time for foreign exchange verification and cancellation.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-02

### Answer 6

From the legal perspective, two declarations are legal proof of cargo ownership transfer. According to Incoterms 2026, the cargo ownership transfer for entrepot trade shall be based on customs declarations. The first declaration confirms that the goods enter the bonded zone of the transit country, and the second declaration confirms that the goods leave the transit country.

If the second declaration is omitted, the final buyer cannot claim the cargo ownership, which may lead to contract disputes. It is recommended that enterprises specify the clause of "cargo ownership transfer after the completion of two declarations" in the trade contract to avoid legal risks. In addition, if a dispute occurs, the customs declaration form can be used as key evidence, which shall be properly preserved for at least 5 years.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-02

### Answer 7

During on-site inspection, the consistency of two declarations is the focus of customs inspection. The goods description in the first declaration shall be completely consistent with that in the second declaration, including product name, quantity, weight, value, etc. If there is any difference, customs will launch container unpacking inspection, resulting in additional costs (about 1% of the cargo value).

Customs introduced the AI inspection system in 2026, which can automatically compare the data of two declarations, and a difference rate of more than 5% will trigger 100% inspection. It is recommended that enterprises use the customs pre-audit system to check data consistency before declaration to reduce the probability of inspection.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-10-02

### Answer 8

In supply chain planning, the efficiency of two declarations directly affects the overall cost. By optimizing the declaration process, the time for two declarations can be shortened from 72 hours to 48 hours, reducing logistics costs by about 10%. The new "transit trade parks" launched in 2026 (such as Shanghai Yangshan Port Transit Park) provide "one-stop declaration" services, where enterprises can complete two declarations in the park without traveling to and from customs.

In addition, choosing the "door-to-door" logistics scheme, where the logistics provider is responsible for two declarations, can reduce the operation cost of enterprises. However, the access threshold of the park shall be evaluated, for example, the annual transit cargo value shall exceed USD 10 million, which is suitable for medium and large enterprises.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-10-02

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