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What Core Documents and Filing Materials Are Required for the Full Process of Compliant Entrepot Trade?
or complex compliance issues.
clearance and fund security.
I am a salesman of a foreign trade company in Shanghai mainly engaged in home appliance export. I just received an order from an American customer last week. Since the United States imposes anti-dumping duties on our intelligent sweeping robots, we decided to carry out entrepot trade to bypass the barriers, but we have never operated such business before.
Now the goods in 12 high containers have been stored in the bonded warehouse of Ningbo Port for 3 days. The freight forwarder we contacted last week said that the materials we submitted do not meet the compliance requirements for entrepot trade, so we cannot book space for shipment. I am so worried that I can hardly sleep.
I would like to ask, what core materials are needed for the whole process of entrepot trade? Are there differences in the materials required by trade entities with different qualifications? What exclusive additional materials need to be supplemented to avoid anti-dumping barriers? What proofs need to be submitted urgently in case of overseas customs inspection?
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
First of all，you need to complete pre-document review details: For the home appliance entrepot trade scenario，the basic materials to be reviewed in advance include: qualification certificate proving that "entrepot trade" is included in the business scope of the business license，entrepot transportation agreement signed with the freight forwarder at the transshipment port，certificate of origin issued by the factory in the country of origin without marking the final destination country，container replacement certificate from the transshipment port warehouse (container number and seal number shall be indicated). If you are a general taxpayer，you also need to prepare the VAT general taxpayer qualification certificate in advance for subsequent compliance filing of foreign exchange receipt and payment.
Supporting materials shall be provided for the connection of core nodes: In the booking stage，you need to submit the entrepot trade filing form (filed with the local SAFE in advance)，cargo packing list and invoice (marked "for entrepot trade only")，After container replacement at the transshipment port，you need to submit the entrepot release notice issued by the customs of the transshipment port，In the customs clearance stage at the port of destination，you need to submit the third-party certificate of origin issued by the transshipment country and the bill of lading from the transshipment country's freight forwarder (which shall be endorsed and transferred to the final customer).
Supplementary materials shall be prepared for exception response plans: In case of customs inspection at the transshipment port or the port of destination，you need to prepare the MSDS report of the goods (for electrified products)，shipment inspection report of the factory in the country of origin，and surveillance video screenshots from the transshipment port warehouse (to prove that the goods are only re-containerized without unpacking) in advance，If there is an abnormality in foreign exchange receipt and payment，you need to submit a letter of explanation on the authenticity of entrepot trade and bank slips for foreign exchange receipt and payment.
Data archiving shall be completed for final compliance implementation: All documents shall be retained for at least 5 years，including filing forms，transportation agreements，various types of documents，inspection records，etc。to respond to subsequent compliance inspections by the SAFE or customs.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
In the customs declaration link of entrepot trade, attention shall be paid to the logical consistency of materials. Inconsistencies in information such as cargo description, container number and weight between documents of the country of origin and documents of the transshipment country are strictly prohibited, otherwise it will directly trigger customs valuation disputes, and even be identified as false declaration of trade mode. You need to cross-check the core information of the certificate of origin of the country of origin, container replacement certificate of the transshipment country and bill of lading of the port of destination in advance to ensure that the cargo description, HS code, weight, volume, etc. are completely matched.
If sensitive products are involved, you need to additionally provide an entrepot trade confirmation letter issued by the customs of the transshipment country to prove that the goods have not entered the domestic circulation of the transshipment country. In addition, when declaring customs, "entrepot trade" shall be clearly marked in the "trade mode" column of the customs declaration form, and the number of the entrepot trade filing form shall be attached to avoid being misjudged as general trade export.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
The core materials in the logistics link of entrepot trade are documents related to cargo right control, including container replacement confirmation from the transshipment port warehouse, transshipment bill of lading issued by NVOCC, and seal number change records. You need to ensure that the container replacement confirmation clearly indicates the original container number, new container number, container replacement time and warehouse address, and the seal number is consistent with the seal number on the transshipment bill of lading to avoid cargo right disputes.
If you choose a third-party transshipment warehouse, you need to require the warehouse to provide qualification certification documents in advance to ensure that it has the compliance qualification for storage and container replacement of entrepot trade goods. In addition, you need to retain the full record of the logistics track, including the manifest information of the shipping company, berthing record of the transshipment port, and container pickup record of the port of destination, to prove the authenticity of the entrepot route of the goods and avoid risks such as container rollover and port change.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
Materials to be prepared in the tax link of entrepot trade include: purchase and sales contracts for entrepot trade, bank slips for foreign exchange receipt and payment, tax certificate of the transshipment country (if turnover tax is required to be paid in the transshipment country), and VAT declaration form of domestic enterprises. If you are a general taxpayer, you need to ensure that the capital flow of foreign exchange receipt and payment of entrepot trade is completely consistent with the contract flow and cargo flow, so as to avoid the risk of being identified as falsely issuing VAT invoices.
In addition, if the entrepot trade involves cross-border related transactions, you need to prepare supporting materials for related transaction pricing in advance, including market price reports of similar products and pricing descriptions of related transactions, to respond to the compliance inspection of BEPS (Base Erosion and Profit Shifting), and avoid the adjustment of taxable income by the tax authority due to unreasonable pricing.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
Materials to be prepared in the foreign exchange receipt and payment link of entrepot trade include: entrepot trade filing form issued by the SAFE, purchase and sales contracts between both trading parties, transshipment transportation agreement, bank SWIFT message (or CIPS payment voucher), and cargo title document (such as copy of bill of lading). You need to ensure that the amount of foreign exchange received and paid fully matches the contract amount and cargo value, and the deviation between the amount of foreign exchange received and paid and the cargo value exceeding 5% is strictly prohibited, otherwise it will trigger the compliance early warning of the SAFE.
If you use an offshore account for foreign exchange receipt and payment, you need to prepare the opening certification documents of the offshore account and transaction flow records of the offshore account in advance to prove the authenticity of the capital flow. In addition, all documents for foreign exchange receipt and payment shall be retained for at least 5 years to respond to subsequent inspections by the SAFE.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
Materials to be prepared at the legal level of entrepot trade include: cargo right transfer agreement signed with the freight forwarder of the transshipment country, sales contract signed with the final customer (entrepot trade clauses shall be specified), procurement contract signed with the supplier in the country of origin (it shall be indicated that the goods are used for entrepot trade), and umbrella agreement with force majeure clauses. You need to ensure that the trade mode of "entrepot trade" is clearly marked in all contracts to avoid cargo right disputes caused by vague contract clauses.
If products involve intellectual property rights, you need to prepare intellectual property rights customs protection filing certification documents in advance to avoid the goods being detained at the transshipment port or the port of destination due to intellectual property infringement. In addition, the original or notarized copies of all contracts shall be retained to respond to possible international trade arbitration.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
Materials to be prepared in the on-site inspection link of entrepot trade include: cargo packing list, invoice, certificate of origin, MSDS report (for dangerous goods or electrified products), container replacement certificate of the transshipment port, and surveillance video screenshots of the warehouse. You need to ensure that the information of all materials is completely consistent with the actual goods, especially core information such as cargo description, HS code, weight and volume, so as to avoid customs detention caused by inconsistent information.
If the customs requires unpacking inspection, you need to prepare the sample test report of the goods and the shipment inspection certificate of the factory in the country of origin in advance to prove the quality of the goods and the authenticity of the country of origin information. In addition, you need to cooperate with the customs to complete the signature confirmation of the inspection record, ensure that the content of the inspection record is consistent with the actual situation, and avoid subsequent compliance risks.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
Entrepot trade is not within the scope of export tax rebate, so the materials to be prepared include: entrepot trade filing form, purchase and sales contracts, foreign exchange receipt and payment slips, and logistics documents, to prove that the goods are not actually declared for domestic consumption, so as to avoid tax penalties caused by false declaration of export tax rebates.
You need to ensure the logical consistency of all materials, and it is strictly prohibited to declare entrepot trade goods as general trade exports, otherwise it will trigger the letter verification of the tax authority, and even the recovered tax rebate and late fee will be imposed. In addition, all materials shall be retained for at least 10 years to respond to subsequent audit and inspection by the tax authority and ensure the tax compliance of entrepot trade.