Connect & Solve
Trade Q&A
Do transit goods transiting through domestic ports during entrepot trade need to go through customs declaration procedures?
or complex compliance issues.
clearance and fund security.
I am a foreign trade salesman in Shanghai who mainly engages in entrepot trade with Southeast Asia. Recently, I have two batches of goods to handle urgently: one batch is natural rubber shipped from Malaysia to Germany, which is scheduled to transit through Shanghai Yangshan Port; the other batch is entrepot goods involving sensitive electronic components, which is planned to flow through Waigaoqiao Bonded Zone.
I heard from old colleagues that entrepot goods do not need to declare customs, but last week I heard that a colleague's entrepot goods were detained at the port and seized due to failure to declare customs as required, and tens of thousands of fines and detention fees were incurred. I am very anxious now, afraid of making mistakes, and want to clearly know whether entrepot goods need to declare customs in different scenarios? If they need to declare, are there special requirements for different goods?
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
First，we need to expose the common misconceptions in the industry: many practitioners mistakenly believe that all entrepot goods do not need to declare customs，or only sensitive goods need to declare，which is the core cause of customs detention and port detention.
If customs declaration is not carried out as required，a chain of negative reactions will be triggered: non-bonded goods transiting through conventional ports that fail to declare will be deemed as illegal entry by the customs，with direct cargo seizure and a fine of 5%-30% of the cargo value，and additional costs such as detention fees and container detention fees will be incurred，goods flowing through bonded supervision zones that fail to file for customs declaration will be restricted from leaving the zone，which will not only delay the delivery cycle，but also reduce the enterprise's customs credit rating and affect the customs clearance efficiency of all subsequent import and export businesses.
Physical risk isolation measures: strictly distinguish the goods circulation scenarios，entrepot goods transiting through conventional ports need to declare the "Entrepot Goods Customs Declaration Form" to the customs，and submit core documents such as bills of lading and entrepot contracts，goods flowing through bonded zones need to go through "bonded entrepot filing" and retain complete ownership transfer vouchers，sensitive goods，regardless of circulation scenarios，must submit complete customs declaration documents such as certificates of origin and composition test reports.
Exclusive loss mitigation tips: entrust a professional foreign trade agency to pre-examine the goods list and circulation path 3 days in advance to ensure document compliance，if a missed declaration has occurred，submit a supplementary declaration application to the customs within 24 hours and explain reasonable reasons，which can strive for a reduction of more than 50% of the fine，and coordinate with the shipping company to extend the free stacking period to reduce detention costs.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
The customs declaration requirements for entrepot trade goods shall be determined based on the actual circulation path of the goods: if the goods enter the domestic non-bonded area, regardless of the transit time, they must declare the entrepot goods customs declaration form to the customs. When declaring, the trade mode of "entrepot trade" must be clearly marked, and the submitted bill of lading must show the final port of destination and the port of departure, and the ownership documents shall not be forged or altered.
If the goods only circulate within the bonded supervision zone, bonded entrepot filing shall be handled, and documents such as entrepot contracts and warehouse receipts shall be provided during filing to ensure the logical closed loop of ownership, logistics and capital flow. For price review disputes, prepare purchase contracts, sales contracts and international logistics invoices for entrepot goods in advance to prove the authenticity of entrepot trade and avoid being deemed as general trade taxation by the customs.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
The customs declaration of entrepot trade goods is directly related to the logistics path: if direct transit is chosen, the goods will not enter the domestic port yard, but only transfer ships at the anchorage, and no customs declaration is required; if the goods need to enter the domestic port yard for loading, unloading or storage, entrepot customs declaration procedures must be handled. In logistics operations, confirm the transit terms with the shipping company in advance, clarify the calculation standards for free stacking period and container detention fees.
If detention at the port is caused by delayed customs declaration, coordinate with the shipping company to apply for an extension of the free stacking period. At the same time, control the cargo rights through bill of lading endorsement to avoid cargo being released without presentation of original bill of lading. The manifest of entrepot goods must clearly mark the word "entrepot" to avoid confusion with general trade goods and lead to customs misjudgment.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
The customs declaration of entrepot trade goods directly affects tax compliance: if customs declaration is not carried out as required, the tax preferential policies for entrepot trade cannot be enjoyed, and it may be deemed as general trade, requiring payment of import tariffs, value-added tax and consumption tax. For entrepot trade carried out through bonded supervision zones, VAT deferral can be applied for, without the need to pay import value-added tax in advance, reducing capital occupation costs.
At the same time, ensure that the capital flow of entrepot trade is consistent with the cargo flow, avoid being identified as false transactions by the tax authorities due to the mismatch between customs declaration information and capital flow, and trigger tax audits. If cross-border related party transactions are involved, transfer pricing filing shall be carried out in advance to avoid adjustment of taxable income due to abnormal prices.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
The customs declaration of entrepot trade goods is the core basis for compliance of receipts and payments: if customs declaration procedures are not handled, valid customs declaration forms cannot be provided to the bank, resulting in restrictions on receipts and payments, and even being included in the foreign exchange supervision blacklist. For entrepot trade settled with cross-border RMB, customs declaration forms, entrepot contracts and logistics documents of entrepot goods shall be submitted to the bank to ensure the consistency of capital flow and cargo flow.
At the same time, handle cross-border RMB receipts and payments through the CIPS system, avoid using offshore accounts for illegal settlement. If there is an abnormality in receipts and payments, submit an explanation to the State Administration of Foreign Exchange in time and supplement supporting materials such as customs declaration forms to lift regulatory restrictions.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
The customs declaration clauses of entrepot trade goods shall be clearly agreed in the contract: the buyer and seller shall clearly specify the goods circulation path, customs declaration responsibility and cost bearer in the entrepot contract to avoid disputes caused by unclear customs declaration responsibility. If the goods involve sensitive commodities, the time and method of providing customs declaration documents such as certificates of origin and composition test reports shall be agreed in the contract to ensure customs declaration compliance.
At the same time, handle the ownership transfer guarantee to ensure the effective transfer of cargo rights during the entrepot process, and avoid cargo rights disputes caused by delayed customs declaration. If the goods are seized due to failure to declare, submit a reconsideration application to the customs in time and provide supporting materials such as entrepot contracts and bills of lading to strive for the release of the seized goods.
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
The customs declaration planning of entrepot trade goods shall be included in the supply chain architecture design: if carrying out entrepot trade for a long time, a transit warehouse can be set up in the bonded supervision zone to reduce customs declaration costs and logistics costs, and enjoy the preferential policies of bonded supervision. In cost accounting, it is necessary to include customs declaration costs and port detention risk costs into the total cost, compare the cost differences of different transit paths, and select the optimal transit plan.
At the same time, establish an inventory linkage strategy to ensure the circulation efficiency of entrepot goods and avoid inventory backlog caused by delayed customs declaration. If multiple batches of entrepot goods are involved, centralized customs declaration can be adopted to improve customs declaration efficiency and reduce operating costs.