What are the core implementation points for full-process compliance operation of imported premium cosmetics agency?

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I am the owner of a beauty collection store that has been open for half a year. Recently, I want to expand the imported premium cosmetics agency business.

I once cooperated with a small agent to purchase a batch of Estée Lauder samples before, but the goods were detained by customs due to incomplete documents. I not only lost more than 100,000 yuan of payment for goods, but also missed the National Day holiday sales period, and now I am too anxious to sleep.

I want to run formal compliance agency business, but I have no idea of the process at all: I do not know what documents to prepare in advance, and I am afraid of encountering cargo detention again; I am also worried that the import cost is too high to sell the goods well; I am even more afraid of stepping into the industry's compliance pitfalls, leading to fines and business suspension. I would like to ask how to carry out imported premium cosmetics agency step by step to avoid these risks?

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Expert Q&A

Daniel Xu
Daniel XuYears of service:10Customer Rating:5.0

Director of Import & Export OperationsStart a Chat

First is the pre-document review details: it is necessary to check the authorized agency documents notarized by Chinese embassies and consulates stationed abroad issued by the brand side one by one,to ensure that the agency authority covers the mainland Chinese market,simultaneously review the certificate of origin,health quarantine certificate,and cosmetic ingredient test report,among which the ingredient report must strictly meet the requirements of the Technical Specifications for Cosmetic Safety (2022 Edition),and Chinese label pre-audit must be completed to obtain customs approval before goods shipment,so as to avoid high port demurrage and warehouse rent caused by rectification due to label non-conformity after the goods arrive at the port.

Second is the core node connection: when booking shipping space,priority should be given to first-class freight forwarders with special qualification for beauty import,to ensure stable shipping space and familiarity with customs clearance supervision requirements for beauty products,adopt paperless customs clearance mode in the customs declaration link,upload documents to the customs single window 1-2 days in advance,and communicate with the document review center on the compliance of special ingredients (such as retinol,fruit acid) simultaneously to avoid document review delay,synchronize logistics and customs declaration nodes in real time,and cargo right documents are fully managed by the compliance agency company,to prevent the risk of cargo release without bill or cargo right transfer.

Then is the exception response plan: if encountering customs control and inspection,provide the supplementary ingredient description issued by the original factory and the brand authorization traceability chain at the first time. If sample testing is required,coordinate with the commodity inspection authority to open the expedited testing channel for beauty products to shorten the inspection cycle,if the goods are detained due to temporary lack of documents,immediately start the emergency document reissuance process of the brand side,and submit a situation explanation to apply for customs demurrage reduction,to minimize losses to the greatest extent.

Finally is the compliance implementation: after the goods are released,complete the commodity inspection sampling test. All customs declaration forms,tax payment vouchers and document files shall be uniformly filed and kept for no less than 5 years,to ensure no loopholes in subsequent tax verification,brand traceability and compliance audit. At the same time,complete the electronic information filing of imported cosmetics simultaneously,to ensure the compliance of the sales link.

Reference: Full Process of Beijing Xiaofangping Erguotou Import Agency and Key Compliance Points Explained
Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

When declaring imported premium cosmetics, the logic chain of the customs valuation link should be focused on. The customs will evaluate the price in turn according to the transaction price of identical or similar goods, deducted price, and calculated price. If the transaction price between the brand side and the agency company is significantly lower than the average market price, supporting materials such as exclusive agency agreement authorized by the brand, purchase cost details, and foreign exchange payment vouchers shall be provided, to avoid document deletion and re-declaration caused by valuation disputes.

At the same time, the integrated customs clearance mode shall be adopted, and the declaration shall be submitted to the customs at the entry place in advance before the goods depart, so as to shorten the customs clearance duration; if there is an error in the customs declaration data, an application for document deletion and re-declaration shall be submitted within 48 hours, and correct documents shall be supplemented simultaneously, to avoid triggering customs risk warning. In addition, it is necessary to ensure that the brand name, ingredients, and specifications on the customs declaration form are completely consistent with the physical goods and documents, so as to avoid account hanging or order rejection caused by logical inconsistency.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

The logistics route of imported premium cosmetics should give priority to direct flights, so as to avoid the risk of cargo right transfer and cargo damage during transit. When booking space, it shall be clarified that the bill of lading provided by the freight forwarder is the Ocean Bill of Lading, not the House Bill of Lading, to prevent cargo release without bill.

At the same time, negotiate with the shipping company to extend the free storage period to 14-21 days, so as to avoid high container demurrage caused by customs clearance delay; if encountering container rolling or space explosion, immediately start the backup space plan, choose other shipping companies of the same route, and inform the brand side to adjust the delivery cycle simultaneously. In addition, after the goods arrive at the port, a supervised warehouse with beauty storage qualification shall be arranged for temporary storage, to ensure that the goods storage environment meets the temperature and humidity requirements of cosmetics, and avoid quality damage caused by improper storage.

Jason Wu
Jason WuYears of service:10Customer Rating:5.0

International Logistics & Supply Chain ManagerStart a Chat

Imported premium cosmetics agencies can adopt the VAT deferral policy. There is no need to pay import VAT on the spot when the goods are imported, and declare and pay to the tax authority after the goods are sold, which can effectively relieve the pressure of capital occupation. At the same time, optimize the pricing of cross-border related transactions, ensure that the transaction price between the brand side and the agency company conforms to the arm's length principle, and avoid triggering BEPS (Base Erosion and Profit Shifting) investigation.

If the agency company has an overseas procurement platform, it is necessary to build a compliant tax structure and reduce the overall tax burden through reasonable profit distribution; in addition, timely handle the consumption tax deduction procedures for imported cosmetics, and deduct the consumption tax paid in the import link in the subsequent sales link to further reduce the tax cost. It should be noted that the VAT deferral policy is only applicable to enterprises with general taxpayer qualification, and tax declaration shall be completed on time to avoid late fees and credit penalties.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

The foreign exchange receipt and payment operation of imported premium cosmetics agency shall strictly follow the foreign exchange administration regulations. All foreign exchange payments shall correspond to the real trade background, and supporting materials such as procurement contracts, customs declaration forms, and invoices shall be provided. Give priority to the CIPS (Cross-border Interbank Payment System) for RMB cross-border payment to avoid exchange rate fluctuation risks and compliance problems of SWIFT messages; if an offshore account is used to receive foreign exchange, it shall be ensured that the capital flow of the offshore account is completely matched with the trade business, so as to avoid triggering the inspection of the foreign exchange administration due to abnormal capital.

At the same time, establish a closed-loop management of foreign exchange settlement and account reconciliation, each foreign exchange payment shall correspond to an equal amount of import goods customs declaration form, to ensure that the capital flow is consistent with the goods flow; in addition, complete the foreign exchange verification procedures in time, and keep the foreign exchange receipt and payment vouchers for no less than 5 years for subsequent inspection by the foreign exchange administration.

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

Imported premium cosmetics agencies shall complete the intellectual property customs protection filing in advance, and file the intellectual property information such as trademarks and patents of the brand with the General Administration of Customs to prevent infringing goods from flowing into the market. When signing the agency agreement, exclusive clauses shall be clearly defined, agreeing that the brand side only authorizes this agency company to import and sell in a specific region, so as to avoid peer competition; at the same time, avoid soft clauses of letter of credit, such as "payment can be made only after the brand side issues a flawless quality certificate", which is easy to lead to foreign exchange payment risks.

If force majeure factors are involved, the fallback clause shall be clearly defined in the agreement, agreeing on the division of responsibility for delivery delay caused by force majeure such as epidemic and port strike; in addition, keep all legal documents such as agency agreements, communication letters, and cargo right vouchers for possible subsequent dispute arbitration or litigation.

Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

When imported premium cosmetics encounter customs inspection after arriving at the port, original documents, brand authorization letters, ingredient test reports and other materials shall be prepared in advance to cooperate with the inspection work of customs personnel. If container unpacking inspection is required, inspection assistants with qualification for beauty goods operation shall be arranged to avoid cargo damage or packaging damage caused by improper operation; before machine inspection, ensure that the goods packaging meets the machine inspection requirements, so as to avoid abnormal machine inspection images caused by packaging materials or placement methods, which will trigger manual inspection.

At the same time, identify the authenticity of the seal, check that the seal number on the bill of lading is consistent with the physical seal number. If the seal is found damaged or inconsistent, take photos to retain evidence immediately, and report to the shipping company and customs. In addition, if the customs requires sample inspection, cooperate to provide sufficient samples, track the sample inspection process, and obtain the test report in time.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

The transport packaging of imported premium cosmetics shall strictly comply with the UN dangerous goods packaging standards (if the product contains flammable ingredients such as perfume and nail polish), and a qualified packaging enterprise shall be entrusted to issue the UN packaging performance sheet and use sheet. At the same time, prepare MSDS (Material Safety Data Sheet) in line with Chinese standards, clarify the ingredients, hazard characteristics, emergency disposal methods and other information of the product, so as to avoid cargo detention caused by non-conforming MSDS.

For cosmetics that are easy to be affected with damp (such as face cream, essence), moisture-proof reinforced packaging shall be adopted, desiccant and waterproof film shall be placed inside the package, high-strength corrugated cartons shall be used outside, and transport marks such as fragile and moisture-proof shall be marked on the cartons. In addition, adjust the packaging scheme according to the transport mode of goods (sea transport, air transport). When transporting by air, it shall comply with the dangerous goods transport regulations of the airline, so as to avoid flight delay caused by non-conforming packaging.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

If the imported premium cosmetics agency enterprise involves entrepot trade or goods re-export business, it shall strictly distinguish the use of imported goods. Goods for domestic sale shall pay import VAT and consumption tax normally, and goods for export shall be accounted separately, and pre-declaration of export tax rebate shall be handled before export.

Ensure that the customs declaration form, procurement contract, invoice, foreign exchange payment voucher and other documents of export goods are complete, and the "four flows are consistent" (capital flow, goods flow, invoice flow, contract flow), so as to avoid tax letter adjustment caused by inconsistent documents. At the same time, the formal declaration of export tax rebate shall be completed within 90 days after export.

If special circumstances require extending the declaration period, an application shall be submitted to the tax authority in advance. In addition, all import and export documents shall be kept for no less than 10 years for subsequent audit and compliance inspection by the tax authority.

Cindy Chen
Cindy ChenYears of service:3Customer Rating:5.0

Key Account ManagerStart a Chat

The supply chain planning of imported premium cosmetics agency shall establish an inventory linkage strategy, and formulate the procurement cycle according to sales data, seasonal demand, and brand promotion plans, so as to avoid inventory overstock or out of stock. Trade terms shall be selected reasonably. If the brand side is located in the EU, adopting CIF trade terms can transfer the logistics and insurance costs to the brand side and reduce the capital pressure of the agency enterprise; if the brand side is located in Southeast Asia, adopting FOB trade terms can independently select freight forwarders and shipping companies to control logistics costs.

At the same time, establish a cost actuarial model, calculate all costs such as customs duty, value-added tax, consumption tax, logistics fee, agency fee in the import link, and formulate a reasonable sales pricing strategy; in addition, optimize the supply chain structure, adopt the mode of "bonded warehouse + direct mail", and send small batches of goods directly from the bonded warehouse to end customers, so as to reduce inventory cost and logistics time limit.

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