---
title: "Can Ceramic Tile Transit Trade Avoid Anti-Dumping Duties? What Are Core Risks and Compliance Key Points?"
description: "Facing the up-to-189% anti-dumping duty imposed by the US on Chinese ceramic tiles，tile export enterprises intend to cut costs via transit trade，but worry about compliance risks，cargo damage and port detention issues due to previous cases of peers having goods detained by customs for fake documents. By selecting qualified third-country factories for authentic reprocessing，adopting AI traceability prevention and control，signing port detention compensation agreements and other measures，common indu..."
url: "https://www.sh-zhongshen.com/en/qa/ceramic-tile-transit-trade-anti-dumping-duty-core-risk-compliance-requirements.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-08-16"
dateModified: "2026-08-16"
brand: "Zhongshen Trading China"
answerCount: 10
---

# Can Ceramic Tile Transit Trade Avoid Anti-Dumping Duties? What Are Core Risks and Compliance Key Points?

## Question

 I am the head of a medium-sized ceramic tile factory in Foshan. At the end of March this year, I received an order for 2 containers of 600*1200 rustic tiles from a client in Los Angeles, the US. However, the anti-dumping duty on Chinese tiles in the US is as high as 189%, and the client clearly requires cost reduction via transit trade to close the deal. I heard from a peer in Shunde that a batch of transit tiles was detained by US Customs last year due to a fake certificate of origin, the goods were held for 3 months and a fine of 120,000 RMB was imposed. Now I am eager to ship the goods but afraid of falling into pitfalls: Is transit trade really reliable? Will the goods be detained by US Customs? Will the comprehensive cost be much higher than expected? If problems occur, are there practical loss-stopping solutions? 

## Answers
                            
### Answer 1 — Best Answer

The core misunderstanding of current ceramic tile transit trade is that small agents only avoid anti-dumping duties via container swapping and fake certificate of origin，without keeping authentic reprocessing records. In 2026，US Customs has launched the **AI traceability system**，which can trace the origin of tiles through their composition，production batch number and packaging barcode. Fake documents will directly trigger customs detention，the port detention fee is around 1,200 USD per container per day，and enterprises will also be listed on the US Customs "High-Risk Exporter Blacklist"，with all their goods subject to 100% inspection within 3 years.

For physical risk isolation，it is necessary to select a third country with formal ceramic tile processing qualification (such as Malaysia)，complete authentic reprocessing (such as edge chamfering，repackaging)，keep full sets of vouchers including processing monitoring records，worker attendance records，local VAT invoices，etc。to ensure a fully closed loop of documentation chain and cargo flow.

Exclusive loss-stopping tips: Be sure to sign a **port detention compensation agreement** with the agent，stipulating that if customs detention is caused by the agent's compliance issues，0.1% of the container value shall be compensated per day，meanwhile，purchase **exclusive transit trade insurance** covering risks such as customs detention，port detention and cargo damage，with the compensation ratio reaching up to 110% of the cargo value.

**status:** accepted
**Author:** Victor Sun
**Date:** 2026-08-17

### Answer 2

The core of customs declaration for ceramic tile transit trade is the closed logic of documents. It is necessary to verify the authenticity of the third-country certificate of origin in advance.

In 2026, US Customs has realized data interconnection with customs of third countries such as Malaysia and Thailand, and can query the issuance records of certificates of origin in real time. Meanwhile, the cargo value on the customs declaration form for China's export to the third country shall comply with the arm's length principle, and shall not be lower than the cost price, to avoid being identified as profit shifting via related-party transactions by China's tax authorities.

In addition, US import pre-declaration requires submission of full sets of documents including third-country reprocessing records, local VAT invoices, China's export declaration form 3 days in advance. In case of price review disputes, processing cost details of the third-country factory shall be supplemented within 72 hours to avoid temporary detention of goods.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-08-16

### Answer 3

Cargo right control and path optimization are the core of ceramic tile transit trade. It is necessary to select third-country bonded zones for container swapping operations, such as the bonded zone of Port Klang West Port in Malaysia.

Full-process loading supervision is required during container swapping, high-definition videos of seal number, cargo appearance and container loading shall be taken and kept for 6 months after the goods are cleared through customs. Straight bill of lading shall be used to avoid cargo right loss caused by order bill of lading; meanwhile, priority shall be given to shipping companies with direct routes to the US (such as Maersk, Mediterranean Shipping Company), to reduce transit times and lower cargo damage risks.

In addition, booking shall be made 10 days in advance to lock the free storage period (usually 7 days). In case of space shortage, an extension of 2 days of free storage period can be applied for to avoid detention fee expenses.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-08-16

### Answer 4

Tax planning for ceramic tile transit trade shall be centered on VAT deferment and related-party transaction compliance. The VAT rate of third countries (such as Malaysia) is 6%, and VAT deferment can be applied for, no advance payment is required, and settlement can be made after the goods are cleared in the US, which effectively relieves capital pressure.

Meanwhile, BEPS (Base Erosion and Profit Shifting) rules shall be strictly followed, the price of goods exported from China to the third country shall conform to the market fair value, to avoid being required to pay back export tax rebates or charged late fees by China's tax authorities. In addition, full sets of transaction vouchers (including invoices, bills of lading, processing orders, payment vouchers) shall be kept for tax authority inquiries to ensure tax compliance.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-08-16

### Answer 5

Foreign exchange receipt and payment for ceramic tile transit trade shall adopt the CIPS RMB cross-border payment system to avoid sanction risks of the SWIFT system. Meanwhile, compliant accounts shall be opened in local banks of the third country (such as Maybank), and offshore accounts are prohibited for foreign exchange receipt and payment, to avoid being identified as illegal foreign exchange operations by the foreign exchange administration.

When settling foreign exchange, full sets of transit documents (China's export declaration form, third-country export declaration form, US import declaration form, processing order) shall be submitted to ensure the capital flow fully matches the cargo flow and document flow. In addition, forward foreign exchange settlement and sale can be used to lock the exchange rate, avoid cost increases caused by RMB exchange rate fluctuations, and the locking period is generally 30-90 days.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-08-16

### Answer 6

Legal risk prevention and control for ceramic tile transit trade shall focus on contract clauses and intellectual property rights. A "Compliant Transit Service Agreement" shall be signed with the transit agent to clarify the agent's compliance responsibility.

If customs detention is caused by fake documents provided by the agent, the agent shall bear the compensation liability of 120% of the cargo value. Meanwhile, the soft clause of "certificate of origin showing China" shall be deleted from the US client's letter of credit, it shall be clearly required that "certificate of origin shows the third country", and a force majeure clause shall be added.

If force majeure events such as political unrest and natural disasters occur in the third country, the contract can be terminated with exemption. In addition, customs registration of ceramic tile trademarks shall be completed in the third country to avoid intellectual property infringement complaints.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-08-16

### Answer 7

On-site inspection response for ceramic tile transit trade requires preparation of full sets of vouchers in advance. When inspected by third-country customs, monitoring videos of reprocessing, worker attendance records, processing equipment usage records, etc. shall be submitted to prove the authenticity of reprocessing; when inspected by US Customs, the authenticity query code of the third-country certificate of origin, tile composition test report, local packaging purchase invoice of the third country, etc. shall be submitted.

If false transit is suspected, the logistics track of China's export to the third country and processing cost details of the third-country factory shall be supplemented within 48 hours to avoid the goods being detained for inspection. In addition, formal seals of shipping companies shall be used, unbranded seals are prohibited, to avoid being identified as container tampering.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-08-16

### Answer 8

Packaging for ceramic tile transit trade shall meet the dual requirements of the third country and the importing country. Third-country packaging shall be marked with local production identification (such as "Made in Malaysia"), repackaging shall be completed in the third-country factory, and locally purchased packaging materials shall be used, to avoid fraud suspicion caused by directly pasting identification.

Meanwhile, ceramic tiles are fragile goods, UN3000 standard buffer packaging shall be adopted, 2 moisture-proof desiccants shall be placed in each box (increased to 4 when humidity is ≥60%), to avoid tile moisture deformation caused by the high humidity environment of Port Klang. In addition, MSDS reports meeting third-country requirements shall be prepared in advance, clarifying the composition and transportation requirements of ceramic tiles, to avoid being identified as dangerous goods by customs.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-08-16

### Answer 9

Export tax rebate for ceramic tile transit trade shall meet the requirement of four-flow consistency, that is, the capital flow, cargo flow, invoice flow and contract flow are fully matched. Full sets of documents including the third-country import declaration form, China's export declaration form, special VAT invoice, reprocessing agreement, etc. shall be submitted. When applying for export tax rebate, supporting materials such as processing records of the third-country factory and local VAT invoices shall be uploaded in the tax rebate system.

If the tax authority conducts an inquiry, monitoring videos of reprocessing, worker attendance records, logistics track, etc. shall be supplemented within 15 days to avoid temporary withholding of tax rebates. In addition, tax rebate declaration shall be completed within 90 days after the goods are exported, and no tax rebate policy will be available after the deadline.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-08-16

### Answer 10

Supply chain planning for ceramic tile transit trade shall focus on cost actuarial calculation and inventory linkage. A transit cost model shall be established, covering third-country processing fees, container swapping fees, certificate of origin fees, logistics fees, etc., and compared with the anti-dumping duty difference of direct export.

If the difference is larger than the transit cost, the solution is feasible. Meanwhile, transit inventory can be established in the third-country bonded zone, a certain amount of ceramic tiles can be stored in advance.

If US clients have urgent orders, goods can be shipped directly from the third country to shorten the delivery cycle. In addition, according to the adjustment of US anti-dumping duties, the transit country can be flexibly switched (such as switching from Malaysia to Thailand), to reduce trade risks and improve supply chain resilience.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-08-16

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