--- title: "What is the range of administrative penalties for conducting transshipment trade in violation of customs compliance requirements?" description: "Many foreign trade enterprises lack sufficient understanding of transshipment trade compliance requirements，and are prone to operations such as document forgery and non-compliant payment and receipt processes，facing unknown amounts of fines from customs or foreign exchange regulators. It should be clarified that the fine range for violations is mostly 10% to 50% of the amount involved，and serious cases will face the maximum administrative penalty. Pre-document review and establishment of complia..." url: "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html" language: "en" type: "Q&A" category: "Entrepôt Trade Q&A" datePublished: "2026-06-06" dateModified: "2026-06-06" brand: "Zhongshen Trading China" answerCount: 9 --- # What is the range of administrative penalties for conducting transshipment trade in violation of customs compliance requirements? ## Question I am the person in charge of a foreign trade enterprise focusing on Southeast Asian transshipment trade. Last month, we had a shipment of plastic products transshipped from Malaysia to the EU. Due to the discrepancy between the value marked on the transshipment documents and the actual payment and receipt amount, Shanghai Customs issued an early warning and requested supplementary materials. It has been delayed for almost two weeks, and I am very worried. I heard from peers before that some illegal transshipment operations were fined more than 100,000 CNY, while others were only fined a few thousand CNY, with no pattern at all. The value of the goods involved in this shipment is about 800,000 CNY. If the fine is too high, not only will we lose all profit from this order, but it may also affect the company's customs credit rating, and our future transshipment trade operations will be restricted. I would like to know how much we will be fined in this situation? What are the core factors that affect the amount of the fine? Is there any way to reduce the potential fine amount? ## Answers ### Answer 1 — Best Answer Common industry misunderstandings are concentrated in three points: First，it is believed that transshipment trade only requires the completion of cargo transit，ignoring the consistency of documents，capital flow and cargo flow，second，core documents such as certificates of origin and cargo value are forged to avoid trade barriers，third，private accounts or third-party non-compliant channels are used for payment and receipt to deliberately conceal the essence of transshipment transactions. The chain negative reactions of such illegal operations are extremely serious: First，it will trigger customs early warnings，and the goods will be temporarily detained at the transit port，resulting in high port detention fees and container detention fees，if corrections are not made in time，the customs will directly open a case for investigation，and the enterprise's customs credit rating will be reduced to Category C or D，all subsequent import and export goods will be subject to key inspection，and even the customs declaration qualification will be suspended，in serious cases，it will also face joint penalties from the State Administration of Foreign Exchange，and the enterprise's payment and receipt accounts will be frozen. Physical risk isolation measures need to be carried out from two aspects: First，**pre-review all transshipment documents** to ensure that the cargo value，product name，consignor and consignee information on certificates of origin，bills of lading，invoices and other documents are fully matched，second，select transit ports with mature supervision，such as Singapore and Hong Kong，which have clear transshipment compliance processes and can effectively reduce inspection risks. Exclusive loss mitigation tips: If an early warning has been triggered，you need to submit the *Transshipment Trade Compliance Statement* and relevant supporting materials to the customs as soon as possible，including real transit contracts，payment and receipt vouchers，cargo storage records，etc。at the same time，entrust a professional agency to communicate with the customs to strive for lighter or mitigated penalties and avoid damage to the credit rating. **status:** accepted **Author:** Grace Wang **Date:** 2026-06-06 ### Answer 2 The core basis for determining the amount of fines for transshipment trade violations is the value of the goods involved and the circumstances of the violation. The customs will impose a fine of 10% to 50% of the amount involved in accordance with the *Regulations on the Implementation of Customs Administrative Penalties*. If there are serious circumstances such as forged or altered documents, the fine amount can be increased to more than 1 time of the amount involved. Enterprises should note that if transshipment goods are identified as "false declaration of trade nature", they need to pay corresponding customs duties and value-added tax in addition to fines. In the customs declaration process, it is necessary to ensure that the remark column of the transshipment trade customs declaration form clearly marks "transshipment trade", and submit supporting materials such as storage certificates of the transit port and transshipment bills of lading to avoid being misjudged as general trade imports. **status:** suggested **Author:** Kevin Lin **Date:** 2026-06-06 ### Answer 3 If a fine is imposed due to illegal operations in transshipment trade, it is often accompanied by chain losses of cargo detention at the port. The daily port detention fee and container detention fee can reach 0.5% to 1% of the cargo value, far exceeding the fine itself. When selecting a transit port, priority should be given to the transparency of customs supervision and transshipment efficiency. Ports such as Singapore and Hong Kong offer 7-14 days of free storage period for transshipment goods, and the customs inspection process is clear, which can quickly complete cargo transit. If the goods have been temporarily detained, you need to contact the agent of the transit port as soon as possible to arrange the transfer of the goods to the supervised warehouse to avoid high port detention fees, and cooperate with the customs to complete the inspection to shorten the detention time of the goods. **status:** suggested **Author:** Lucas Liu **Date:** 2026-06-06 ### Answer 4 In addition to customs fines for illegal operations of transshipment trade, it may also trigger a chain reaction at the tax level. If an enterprise transfers profits through false transshipment trade, the tax authority will identify it as "tax evasion". In addition to recovering the tax, it will also charge a late fee of 0.05% per day and impose a fine of 50% to 5 times the amount of tax evaded. Compliant transshipment trade needs to ensure that the capital flow is consistent with the cargo flow and document flow. Payment and receipt must be completed through the corporate public account, avoid using offshore accounts or private accounts for fund transfer, and all transaction vouchers of transshipment trade, including transit contracts, storage fee invoices, transportation invoices, etc., must be retained for verification by tax authorities. **status:** suggested **Author:** Victor Sun **Date:** 2026-06-06 ### Answer 5 The amount of fines for illegal payment and receipt in transshipment trade is determined by the State Administration of Foreign Exchange in accordance with the *Foreign Exchange Administration Regulations*, usually 10% to 30% of the amount involved, and in serious cases, a fine of 30% to 100% of the amount involved may be imposed, or even the enterprise's payment and receipt qualification may be suspended. Compliant payment and receipt need to ensure that the amount received is consistent with the value of the transshipment goods, and there shall be no over-receipt or under-receipt of foreign exchange; when paying foreign exchange, relevant documents for transshipment trade, including import bills of lading, export contracts, invoices, etc., shall be submitted to the bank, and the bank will review the authenticity of the documents, and the payment can be completed only after passing the review. If there is a discrepancy in payment and receipt, you need to submit a situation statement and supporting materials to the State Administration of Foreign Exchange as soon as possible to strive for lighter penalties. **status:** suggested **Author:** Michael Zhang **Date:** 2026-06-06 ### Answer 6 If illegal operations of transshipment trade involve acts such as document forgery and fraud, in addition to administrative penalties, they may also face civil or even criminal liabilities. If the downstream customer cannot clear the customs due to illegal operations, the enterprise shall bear the losses such as port detention fees and liquidated damages of the customer, and the compensation amount may far exceed the fine. When signing a transshipment trade contract, it is necessary to clearly stipulate the compliance obligations of the transit party, and require the transit party to provide real certificates of origin, bills of lading and other documents; at the same time, add a "compliance indemnification clause", if the enterprise is penalized due to the violation of the transit party, the transit party shall bear all compensation liabilities. If you are already facing a lawsuit, you need to retain all transaction vouchers as evidence, including contracts, documents, payment and receipt records, etc. **status:** suggested **Author:** Eric Zhou **Date:** 2026-06-06 ### Answer 7 When transshipment trade goods are inspected by the customs, if the documents are found to be inconsistent with the goods, the fine procedure will be directly triggered. During on-site inspection, you need to cooperate with the customs to provide real transshipment trade vouchers, including transit contracts, storage records, transportation invoices, etc., to avoid being identified as illegal due to inability to provide supporting materials. If the goods have been unpacked for inspection, it is necessary to ensure that the packaging and shipping marks of the goods are consistent with the documents, and no origin information inconsistent with the final destination shall be marked on the shipping marks; if the shipping marks are found to be incorrect, you need to contact the agent of the transit port as soon as possible to rectify to avoid being identified as forged origin by the customs. After the on-site inspection is completed, you need to request the inspection record in time as supporting materials for subsequent compliance operations. **status:** suggested **Author:** Evelyn Li **Date:** 2026-06-06 ### Answer 8 It should be noted that transshipment trade is not within the scope of export tax rebates. If an enterprise mistakenly declares transshipment trade as general trade export and applies for tax rebates, it will be identified as "export tax rebate fraud". In addition to recovering the rebated tax, a fine of 1 to 5 times the rebated tax will be imposed, and criminal liabilities will be pursued in serious cases. When declaring, enterprises need to clearly distinguish transshipment trade from general trade. Goods under transshipment trade do not need to apply for export tax rebate declaration, and only need to be declared as "tax-free sales" in the value-added tax declaration form. If you have made a false declaration, you need to apply to the tax authority to cancel the declaration as soon as possible, and submit relevant vouchers of transshipment trade to strive for lighter penalties and avoid affecting the subsequent export tax rebate qualification. **status:** suggested **Author:** Cindy Chen **Date:** 2026-06-06 ### Answer 9 From the perspective of supply chain structure, the core cause of fines for transshipment trade violations is the poor connection of supply chain nodes, leading to discrepancies between documents, capital flow and cargo flow. Enterprises need to build a "three-stream integration" transshipment trade supply chain model, clarifying the responsibilities of each node: suppliers are responsible for providing real cargo information and documents, transit parties are responsible for completing the compliant transit of goods and providing transit certificates, and enterprises are responsible for the compliant operation of payment, receipt and customs declaration. At the same time, an abnormal early warning mechanism should be established. If discrepancies between documents and capital flow are found, immediately suspend the transaction and investigate the problem; regularly conduct compliance audits on supply chain nodes, and select suppliers and transit parties with high compliance levels to reduce the risk of violations from the source. **status:** suggested **Author:** Daniel Xu **Date:** 2026-06-06 ## Related Categories - [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-agency/) - [Export Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-agency/) - [Export Tax Rebate Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-tax-rebate/) - [Customs Declaration Q&A](https://www.sh-zhongshen.com/en/qa/cat-customs-declaration/) - [Freight Forwarding Q&A](https://www.sh-zhongshen.com/en/qa/cat-freight-forwarding/) - [Forex Settlement Q&A](https://www.sh-zhongshen.com/en/qa/cat-forex-settlement/) - [General Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-general-trade/) ## Related Resources - [Trade Services](https://www.sh-zhongshen.com/en/services/) - [Trade Cases](https://www.sh-zhongshen.com/en/cases/) - [Trade Wiki](https://www.sh-zhongshen.com/en/wiki/) - [Trade Class](https://www.sh-zhongshen.com/en/guide/) - [Global Trade Services](https://www.sh-zhongshen.com/en/country/) ## Structured Data ```json [ { "@context": "https://schema.org", "@type": "QAPage", "inLanguage":"en", "isPartOf": { "@id":"https://www.sh-zhongshen.com/en/#website" }, "publisher":{ "@id":"https://www.sh-zhongshen.com/en/#organization" }, "mainEntity": { "@type": "Question", "name": "What is the range of administrative penalties for conducting transshipment trade in violation of customs compliance requirements?", "text": "I am the person in charge of a foreign trade enterprise focusing on Southeast Asian transshipment trade. Last month, we had a shipment of plastic products transshipped from Malaysia to the EU. Due to the discrepancy between the value marked on the transshipment documents and the actual payment and receipt amount, Shanghai Customs issued an early warning and requested supplementary materials. It has been delayed for almost two weeks, and I am very worried. I heard from peers before that some illegal transshipment operations were fined more than 100,000 CNY, while others were only fined a few thousand CNY, with no pattern at all. The value of the goods involved in this shipment is about 800,000 CNY. If the fine is too high, not only will we lose all profit from this order, but it may also affect the company's customs credit rating, and our future transshipment trade operations will be restricted. I would like to know how much we will be fined in this situation? What are the core factors that affect the amount of the fine? Is there any way to reduce the potential fine amount?", "answerCount": 9, "upvoteCount": 3, "datePublished": "2026-06-06T04:56:48Z", "dateModified": "2026-06-06T05:10:12Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "Common industry misunderstandings are concentrated in three points: First，it is believed that transshipment trade only requires the completion of cargo transit，ignoring the consistency of documents，capital flow and cargo flow，second，core documents such as certificates of origin and cargo value are forged to avoid trade barriers，third，private accounts or third-party non-compliant channels are used for payment and receipt to deliberately conceal the essence of transshipment transactions. The chain negative reactions of such illegal operations are extremely serious: First，it will trigger customs early warnings，and the goods will be temporarily detained at the transit port，resulting in high port detention fees and container detention fees，if corrections are not made in time，the customs will directly open a case for investigation，and the enterprise's customs credit rating will be reduced to Category C or D，all subsequent import and export goods will be subject to key inspection，and even the customs declaration qualification will be suspended，in serious cases，it will also face joint penalties from the State Administration of Foreign Exchange，and the enterprise's payment and receipt accounts will be frozen. Physical risk isolation measures need to be carried out from two aspects: First， pre-review all transshipment documents to ensure that the cargo value，product name，consignor and consignee information on certificates of origin，bills of lading，invoices and other documents are fully matched，second，select transit ports with mature supervision，such as Singapore and Hong Kong，which have clear transshipment compliance processes and can effectively reduce inspection risks. Exclusive loss mitigation tips: If an early warning has been triggered，you need to submit the *Transshipment Trade Compliance Statement* and relevant supporting materials to the customs as soon as possible，including real transit contracts，payment and receipt vouchers，cargo storage records，etc。at the same time，entrust a professional agency to communicate with the customs to strive for lighter or mitigated penalties and avoid damage to the credit rating.", "upvoteCount": 3, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#acceptedAnswer", "datePublished": "2026-06-06T05:43:56Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "The core basis for determining the amount of fines for transshipment trade violations is the value of the goods involved and the circumstances of the violation. The customs will impose a fine of 10% to 50% of the amount involved in accordance with the *Regulations on the Implementation of Customs Administrative Penalties*. If there are serious circumstances such as forged or altered documents, the fine amount can be increased to more than 1 time of the amount involved. Enterprises should note that if transshipment goods are identified as "false declaration of trade nature", they need to pay corresponding customs duties and value-added tax in addition to fines. In the customs declaration process, it is necessary to ensure that the remark column of the transshipment trade customs declaration form clearly marks "transshipment trade", and submit supporting materials such as storage certificates of the transit port and transshipment bills of lading to avoid being misjudged as general trade imports.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-2", "datePublished": "2026-06-06T05:39:10Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "If a fine is imposed due to illegal operations in transshipment trade, it is often accompanied by chain losses of cargo detention at the port. The daily port detention fee and container detention fee can reach 0.5% to 1% of the cargo value, far exceeding the fine itself. When selecting a transit port, priority should be given to the transparency of customs supervision and transshipment efficiency. Ports such as Singapore and Hong Kong offer 7-14 days of free storage period for transshipment goods, and the customs inspection process is clear, which can quickly complete cargo transit. If the goods have been temporarily detained, you need to contact the agent of the transit port as soon as possible to arrange the transfer of the goods to the supervised warehouse to avoid high port detention fees, and cooperate with the customs to complete the inspection to shorten the detention time of the goods.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-3", "datePublished": "2026-06-06T05:39:04Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } , { "@type": "Answer", "text": "In addition to customs fines for illegal operations of transshipment trade, it may also trigger a chain reaction at the tax level. If an enterprise transfers profits through false transshipment trade, the tax authority will identify it as "tax evasion". In addition to recovering the tax, it will also charge a late fee of 0.05% per day and impose a fine of 50% to 5 times the amount of tax evaded. Compliant transshipment trade needs to ensure that the capital flow is consistent with the cargo flow and document flow. Payment and receipt must be completed through the corporate public account, avoid using offshore accounts or private accounts for fund transfer, and all transaction vouchers of transshipment trade, including transit contracts, storage fee invoices, transportation invoices, etc., must be retained for verification by tax authorities.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-4", "datePublished": "2026-06-06T05:36:44Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } , { "@type": "Answer", "text": "The amount of fines for illegal payment and receipt in transshipment trade is determined by the State Administration of Foreign Exchange in accordance with the *Foreign Exchange Administration Regulations*, usually 10% to 30% of the amount involved, and in serious cases, a fine of 30% to 100% of the amount involved may be imposed, or even the enterprise's payment and receipt qualification may be suspended. Compliant payment and receipt need to ensure that the amount received is consistent with the value of the transshipment goods, and there shall be no over-receipt or under-receipt of foreign exchange; when paying foreign exchange, relevant documents for transshipment trade, including import bills of lading, export contracts, invoices, etc., shall be submitted to the bank, and the bank will review the authenticity of the documents, and the payment can be completed only after passing the review. If there is a discrepancy in payment and receipt, you need to submit a situation statement and supporting materials to the State Administration of Foreign Exchange as soon as possible to strive for lighter penalties.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-5", "datePublished": "2026-06-06T05:33:18Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "If illegal operations of transshipment trade involve acts such as document forgery and fraud, in addition to administrative penalties, they may also face civil or even criminal liabilities. If the downstream customer cannot clear the customs due to illegal operations, the enterprise shall bear the losses such as port detention fees and liquidated damages of the customer, and the compensation amount may far exceed the fine. When signing a transshipment trade contract, it is necessary to clearly stipulate the compliance obligations of the transit party, and require the transit party to provide real certificates of origin, bills of lading and other documents; at the same time, add a "compliance indemnification clause", if the enterprise is penalized due to the violation of the transit party, the transit party shall bear all compensation liabilities. If you are already facing a lawsuit, you need to retain all transaction vouchers as evidence, including contracts, documents, payment and receipt records, etc.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-6", "datePublished": "2026-06-06T05:32:38Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } , { "@type": "Answer", "text": "When transshipment trade goods are inspected by the customs, if the documents are found to be inconsistent with the goods, the fine procedure will be directly triggered. During on-site inspection, you need to cooperate with the customs to provide real transshipment trade vouchers, including transit contracts, storage records, transportation invoices, etc., to avoid being identified as illegal due to inability to provide supporting materials. If the goods have been unpacked for inspection, it is necessary to ensure that the packaging and shipping marks of the goods are consistent with the documents, and no origin information inconsistent with the final destination shall be marked on the shipping marks; if the shipping marks are found to be incorrect, you need to contact the agent of the transit port as soon as possible to rectify to avoid being identified as forged origin by the customs. After the on-site inspection is completed, you need to request the inspection record in time as supporting materials for subsequent compliance operations.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-7", "datePublished": "2026-06-06T05:18:39Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "It should be noted that transshipment trade is not within the scope of export tax rebates. If an enterprise mistakenly declares transshipment trade as general trade export and applies for tax rebates, it will be identified as "export tax rebate fraud". In addition to recovering the rebated tax, a fine of 1 to 5 times the rebated tax will be imposed, and criminal liabilities will be pursued in serious cases. When declaring, enterprises need to clearly distinguish transshipment trade from general trade. Goods under transshipment trade do not need to apply for export tax rebate declaration, and only need to be declared as "tax-free sales" in the value-added tax declaration form. If you have made a false declaration, you need to apply to the tax authority to cancel the declaration as soon as possible, and submit relevant vouchers of transshipment trade to strive for lighter penalties and avoid affecting the subsequent export tax rebate qualification.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-8", "datePublished": "2026-06-06T05:11:11Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "From the perspective of supply chain structure, the core cause of fines for transshipment trade violations is the poor connection of supply chain nodes, leading to discrepancies between documents, capital flow and cargo flow. Enterprises need to build a "three-stream integration" transshipment trade supply chain model, clarifying the responsibilities of each node: suppliers are responsible for providing real cargo information and documents, transit parties are responsible for completing the compliant transit of goods and providing transit certificates, and enterprises are responsible for the compliant operation of payment, receipt and customs declaration. At the same time, an abnormal early warning mechanism should be established. If discrepancies between documents and capital flow are found, immediately suspend the transaction and investigate the problem; regularly conduct compliance audits on supply chain nodes, and select suppliers and transit parties with high compliance levels to reduce the risk of violations from the source.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/customs-administrative-penalty-amount-range-for-non-compliant-transshipment-trade.html#suggestedAnswer-9", "datePublished": "2026-06-06T05:10:12Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } ] } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ {"@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.sh-zhongshen.com/en/"},{"@type": "ListItem", "position": 2, "name": "Q&A", "item": "https://www.sh-zhongshen.com/en/qa/"},{"@type": "ListItem", "position": 3, "name": "Entrepôt Trade Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-entrepot-trade/"} ,{"@type": "ListItem", "position": 4, "name": "What is the range of administrative penalties for conducting transshipment trade in violation of customs compliance requirements?"} ] } ] ```