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Are customs declaration procedures required for all links in the entire process of bonded transit trade?
or complex compliance issues.
clearance and fund security.
I am the head of a company in Shanghai focusing on cross-border trade of electronic components. I just signed a RMB 12 million transit order last week: chips imported from South Korea will be stored in Yangshan Free Trade Port Area, then re-exported to Malaysia.
I heard from peers before that some links of bonded transit trade do not require customs declaration, but another friend of mine had his cargo detained at the port for 3 days last week due to missing transit declaration procedures, and paid nearly RMB 80,000 in port detention fees and liquidated damages. Now I am very anxious, as this batch is an urgent order for the customer, and one day of port detention will incur RMB 50,000 in compensation.
I also heard that there are special policies for bonded transit trade declaration in Shanghai Free Trade Zone, so I would like to ask: Is customs declaration required for bonded transit trade at all? What are the respective customs declaration requirements for the core links of warehousing, transit out of the zone, and cross-border transfer of cargo ownership? Are there any compliant declaration exemption scenarios?
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
First，the pre-document review details should be completed: prepare the transit trade contract，cargo ownership transfer agreement，and bonded warehouse warehousing letter of intent in advance，ensure that the cargo name，HS code，and quantity on the documents are completely consistent with the actual goods，and focus on checking the supervision conditions of the HS code，to avoid customs declaration rejection and delivery delay caused by document inconsistency.
The connection of core nodes must be accurately grasped: First，when goods enter the bonded warehouse from overseas，you need to handle bonded warehousing declaration，and enter the supervision mode code "0139" (bonded transit trade)，Second，when goods are transported out of the zone for re-export to overseas，handle customs transit declaration，no tariff and import value-added tax are required，but the final destination country and consignee information of the goods must be accurately declared，Third，when cross-border transfer of cargo ownership occurs，no separate customs declaration is required，only the information of the transferee needs to be indicated in the remark column of the customs transit declaration form.
Abnormal contingency plans should be formulated in advance: In case of customs valuation disputes or temporary missing documents，you need to immediately submit a letter of explanation，and contact the bonded warehouse operator to assist in obtaining the electronic certificate of cargo warehousing，to avoid extra costs caused by port detention due to delayed customs declaration.
The final compliance implementation can rely on the hierarchical supervision policy of Shanghai Free Trade Zone. If the enterprise has a Class A or higher credit rating，it can apply for the simplified customs declaration process to realize "one declaration，one inspection，one release"，which greatly shortens the customs clearance time and ensures efficient and compliant cargo circulation.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
Customs declaration requirements for bonded transit trade need to strictly distinguish between supervision modes and cargo flow directions. A common industry misunderstanding is that "transit trade in the bonded zone does not require customs declaration". In fact, customs supervision of bonded transit covers the whole process: When goods enter the bonded warehouse from overseas, you need to handle bonded warehousing declaration and enter the supervision mode code "0139" (bonded transit trade); When goods are transported out of the zone for re-export to overseas, you need to handle customs transit declaration, no tariff and import value-added tax are required, but the final destination country and consignee information of the goods must be accurately declared; If cross-border transfer of cargo ownership occurs within the bonded zone, no separate customs declaration procedures are required, only the enterprise code and name of the cargo ownership transferee need to be specified in the remark column of the customs transit declaration form.
If the customs declaration for the corresponding link is not completed as required, the customs will deem it as an illegal operation. In minor cases, a fine of 3%-5% of the cargo value will be imposed, and in serious cases, the goods will be detained for rectification, which directly affects the enterprise's customs credit rating, and the enterprise will be listed as a key inspection object for subsequent customs clearance.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
From the perspective of logistics route optimization, the customs declaration operation of bonded transit trade needs to be seamlessly connected with logistics nodes: After the goods arrive at the port, you need to handle bonded warehousing declaration as soon as possible, and handle the container pickup and warehousing procedures with the copy of the customs declaration form, to avoid container detention fees caused by delayed declaration; If you choose a third-country transit logistics route, you need to complete the customs transit declaration before transshipment, to ensure that the goods do not need to be unpacked and inspected at the transit port, which greatly shortens the transit time; In case of emergencies such as container rollover or space overload, you need to apply to the customs for declaration extension in advance, with a maximum extension of 7 days, to avoid the goods being detained by the customs due to overdue declaration. In addition, when cross-border transfer of cargo ownership occurs, it is necessary to ensure that the endorsement information on the sea bill of lading is completely consistent with the consignee information on the customs declaration form, to avoid the goods being unable to leave the zone normally due to inconsistency between the cargo ownership certificate and the declaration information, which affects the overall transit efficiency.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
From the perspective of tax planning, the customs declaration operation of bonded transit trade directly affects tax compliance and capital costs: If the bonded warehousing declaration is not handled as required, the goods will be recognized as ordinary imported goods by the customs, and you need to pay full tariff and import value-added tax, and cannot enjoy the tax deferral advantage of the bonded policy; If the customs transit declaration is not handled when the goods are transported out of the zone for re-export, the customs will treat them as domestic sales goods. In addition to paying the tariff and value-added tax in arrears, you also need to pay a late fee of 0.05% per day, which increases the extra cost of the enterprise.
In addition, if the enterprise has a Class A or higher customs credit rating, it can apply for the VAT deferral policy at the same time, no need to prepay import value-added tax at the declaration link, and conduct tax verification after the goods complete transit and obtain export certificates, which can greatly reduce the occupation rate of the enterprise's working capital. Calculated based on the cargo value of RMB 12 million, it can reduce capital occupation by about RMB 1.56 million.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
From the perspective of payment and receipt compliance, the customs declaration form of bonded transit trade is the core certificate for handling cross-border payment and receipt: If the customs declaration for the corresponding link is not completed as required, the enterprise will not be able to provide valid supporting materials for payment and receipt to the bank, resulting in direct rejection of foreign exchange settlement and purchase operations, which affects the normal circulation of funds; If the deviation between the cargo value on the declaration form and the actual payment and receipt amount exceeds 5%, the bank will deem it as an abnormal cross-border transaction, triggering anti-money laundering compliance review, and even temporarily freezing the enterprise's offshore account or cross-border payment authority. In addition, if the Cross-border Interbank Payment System (CIPS) is used to handle payment and receipt for transit trade, it is necessary to ensure that the settlement currency on the customs declaration form is marked as RMB, and the deviation between the payment and receipt amount and the declaration value is controlled within 3%, to avoid payment failure due to inconsistent currency identification or amount, which affects the stability of the enterprise's capital chain.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
From the perspective of legal risk avoidance, the customs declaration form of bonded transit trade is the core legal certificate for cargo ownership transfer and dispute proof: If the customs declaration for the corresponding link is not completed as required, the enterprise will not be able to provide valid proof of the legal source and circulation path of the goods to the court or arbitration institution.
In case of cargo ownership dispute or trade breach dispute, it will face the risk of losing the lawsuit due to insufficient evidence, and need to bear the compensation liability for the full payment of the goods; If the information of the cargo ownership transferee on the declaration form is inconsistent with the agreement in the trade contract, the cargo ownership transfer will be deemed invalid, and the enterprise needs to pay the buyer a liquidated damage of 10%-20% of the cargo value. In addition, if the transit goods involve intellectual property rights, you need to handle the intellectual property customs protection filing with the customs in advance, to avoid the goods being detained by the customs due to suspected infringement, which affects the progress of the overall transit process.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
From the perspective of on-site inspection, the declaration information of bonded transit trade directly affects the probability of customs inspection and customs clearance efficiency: If the HS code, cargo name, and quantity on the declaration form deviate from the actual goods, even if it is a minor category difference, the customs will directly list the batch of goods as a key inspection object, with an inspection rate as high as 90%, and a single inspection takes about 2-3 days, which greatly delays the delivery time; If the packaging is damaged or the quantity is short during the storage of the goods in the bonded warehouse, you need to submit the packaging damage explanation, on-site photos and inventory record of the bonded warehouse to the customs before handling the customs transit declaration, otherwise it will be deemed as an illegal operation, and a fine of 2%-3% of the cargo value will be imposed. In addition, if the transit goods involve hazardous chemicals, you need to submit the qualified MSDS report and dangerous goods packaging inspection certificate at the same time when declaring, otherwise the customs will directly refuse customs clearance, and the goods will be temporarily detained in the port area.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
From the perspective of export tax refund compliance, bonded transit trade is not within the scope of export tax refund, but the declaration operation directly affects tax compliance: If the customs declaration for the corresponding link is not completed as required, the enterprise will not be able to provide valid proof of the transit attribute of the goods to the tax authority, and may be recognized as domestic sales goods, requiring full payment of value-added tax and enterprise income tax, and even triggering tax letter verification, which affects the normal tax refund business of the enterprise; If the supervision mode code on the declaration form is filled incorrectly (such as mistakenly filling in 0110 for ordinary trade), the tax system will not be able to identify the transit trade attribute, triggering a tax warning, and the enterprise needs to cooperate with the tax authority for a 1-2 month inspection. In addition, enterprises shall keep and file documents such as customs declaration forms, transit trade contracts, payment and receipt vouchers, and bonded warehouse warehousing vouchers for 10 years for subsequent inspection by tax authorities.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
From the perspective of supply chain planning, the customs declaration operation of bonded transit trade needs to be deeply linked with inventory management and logistics timeliness: If the bonded warehousing declaration is not handled as required, the goods cannot be stored in the bonded warehouse, and can only be stored in ordinary foreign trade warehouses, and the storage cost will increase by 30%-50%; If the customs transit declaration is not handled in time when the goods are transported out of the zone for re-export, the goods cannot be shipped out of the zone normally, resulting in delay of supply chain nodes and affecting the customer satisfaction of the enterprise; If the enterprise has a Class A or higher customs credit rating, it can apply for direct system connection between the customs and the bonded warehouse, to realize real-time synchronization of declaration information and inventory information, no need for manual data entry, which greatly improves the response speed of the supply chain.
In addition, enterprises can shorten the overall transit cycle by 2-3 days by optimizing the connection between the declaration process and the logistics route. Calculated based on the cargo value of RMB 12 million, it can reduce the inventory holding cost and capital occupation cost by about RMB 80,000.