What are the specific types of customs supervision declaration codes required for entrepot trade operations?

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I am an operator of a foreign trade company specializing in Southeast Asian entrepot trade. Last week, I made a mistake in filling the entrepot trade declaration code, which led to a 3-day port detention of the rubber container shipped from Malaysia to the EU, resulting in more than RMB 2,300 in port detention fees, and I was criticized by the leader. Now I have another shipment of rubber products with the same route and a cargo value of RMB 280,000 to declare, and the document cut-off time is tomorrow.

I am extremely anxious, afraid of filling the code wrong again, which will not only make me bear port detention fees and document modification fees, but also trigger customs compliance warnings and affect subsequent foreign exchange collection and payment. I would like to ask how many types of declaration codes there are for entrepot trade, whether different codes are required for direct sea transshipment and bonded warehouse entrepot trade, and whether there are immediate compliant correction methods if errors are found temporarily.

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Expert Q&A

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

Customs Declaration & Compliance ExpertStart a Chat

First of all,we would like to point out common industry misunderstandings: most enterprises mistakenly believe that entrepot trade only corresponds to a single declaration code. In fact,the customs subdivides different supervision codes according to entrepot modes. The most easily confused ones are the Code 0139 for bonded entrepot trade and Code 0110 for direct transshipment entrepot trade,and mixed use is a high-frequency error point.

Misuse of codes will trigger a chain of negative reactions: for example,if direct transshipment entrepot trade is wrongly declared as Code 0139,the customs system will fail to match the verification and write-off information of the bonded warehouse,and the goods will be detained at the port. This will not only incur port detention fees and document modification fees,but also trigger customs compliance warnings,reduce the enterprise's credit rating,and even restrict the enterprise's right to collect and pay foreign exchange for entrepot trade in the following 3 months.

Physical risk isolation measures: Complete the cross-verification of "document-mode-code" 24 hours before customs declaration,check the entrepot trade agreement,third-party logistics bill of lading and cargo storage certificate to ensure that the trade mode is fully matched with the code,select an agency with exclusive customs declaration port for entrepot trade,and the system will automatically pre-verify the code compliance.

Exclusive loss reduction tips: If errors are found before customs examination and approval,you can directly correct them through the "Single Window Paperless Document Modification" channel,if the examination and approval has been completed,you need to immediately submit the authenticity certificate of entrepot trade (entrepot agreement,ownership transfer certificate) to apply for manual document modification,and at the same time,the agency will coordinate with the port to apply for a 24-hour free port detention extension,so as to minimize losses.

Reference: US Anti-Dumping Hardware: Avoid Duties & Risks
Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

The filling of entrepot trade declaration codes directly affects the customs valuation logic. If the code is wrongly declared, the customs will recalculate the cargo value according to the valuation rules of the corresponding supervision mode. For example, if Code 0139 for bonded entrepot trade is wrongly declared as the general trade code, it will trigger dutiable value verification, requiring the enterprise to submit additional documents such as ownership transfer certificate and entrepot profit certificate.

If they cannot be provided within 3 working days, it will be listed as a valuation dispute case, and the port detention time of the goods will be extended to 7-10 days. Enterprises shall clarify the ownership transfer path of entrepot trade before customs declaration to ensure that the code matches the ownership transfer node. For example, bonded entrepot trade requires the bonded warehouse delivery order, and direct transshipment entrepot trade requires the full bill of lading from the international freight forwarder, so as to avoid valuation disputes.

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

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

The selection of entrepot trade declaration codes shall be fully matched with the logistics route. If Code 0110 for direct transshipment entrepot trade is selected, the logistics route must be the direct transshipment mode of "overseas - domestic port - overseas", and the goods shall not enter the domestic bonded warehouse or other supervision places; if Code 0139 for bonded entrepot trade is selected, the goods must enter the special customs supervision area or bonded logistics center for storage and transshipment.

If the code does not match the logistics route, it will lead to data conflict between the logistics manifest and the customs declaration form, trigger abnormal manifest verification and write-off, make the goods unable to be loaded and departed, and also incur additional manifest modification fees and container detention fees. Enterprises shall confirm the logistics route with the freight forwarder before booking, and match the corresponding declaration code simultaneously to avoid data conflicts.

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

Director of Import & Export OperationsStart a Chat

The selection of entrepot trade declaration codes directly affects the compliance of cross-border tax planning. If Code 0139 for bonded entrepot trade is selected, the goods can enjoy the VAT deferral policy after entering the bonded zone, no need to pay value-added tax at the import link, and only need to pay enterprise income tax according to the entrepot profit after the completion of entrepot trade; if Code 0110 for direct transshipment entrepot trade is selected, as the goods do not enter the domestic supervision area, they cannot enjoy VAT deferral, and need to prepay value-added tax deposit according to a certain proportion of the FOB value of the goods.

If the entrepot trade is not completed within 6 months, the deposit will be converted into tax for supplementary payment. Enterprises shall select the corresponding code according to the entrepot cycle and cargo value scale to optimize tax costs.

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

Key Account ManagerStart a Chat

The entrepot trade declaration code is the core basis for the compliance review of cross-border foreign exchange collection and payment. The bank will verify the authenticity of foreign exchange collection and payment according to the code on the customs declaration form. If the code is 0139 (bonded entrepot trade), the bonded warehouse delivery certificate and entrepot trade agreement shall be provided as supporting documents for foreign exchange collection and payment; if the code is 0110 (direct transshipment entrepot trade), the full international bill of lading and ownership transfer certificate shall be provided.

If the code does not match the supporting documents for foreign exchange collection and payment, the bank will list the foreign exchange collection and payment as a suspicious transaction, suspend the right of foreign exchange settlement or sale, and even report it to the State Administration of Foreign Exchange, affecting the enterprise's foreign exchange settlement qualification. Enterprises shall synchronize the code information to the financial department before customs declaration to ensure that the foreign exchange collection and payment documents match the code.

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

International Logistics & Supply Chain ManagerStart a Chat

The selection of entrepot trade declaration codes shall be fully consistent with the terms of the trade contract. If the contract stipulates the bonded warehouse entrepot mode, but the direct transshipment entrepot code is misused during customs declaration, it will lead to conflict between the contract and customs declaration data.

In case of ownership dispute, the court or arbitration institution will take the customs declaration code as the core basis for determining the time of ownership transfer, which may lead to the enterprise losing the legitimacy of ownership claim. Enterprises shall clarify the entrepot mode when signing the entrepot trade contract, stipulate the clause that "the customs declaration code shall match the entrepot mode" in the contract, and retain the corresponding relationship between the contract and the customs declaration form as the core evidence for dispute handling.

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

Supply Chain Management ExpertStart a Chat

The entrepot trade declaration code will directly trigger different on-site inspection logics. If the code is 0139 (bonded entrepot trade), the customs will focus on checking whether the goods meet the bonded storage requirements, and verify the consistency between the cargo marks and the bonded warehouse delivery order; if the code is 0110 (direct transshipment entrepot trade), the customs will focus on checking the transit attribute of the goods, and verify the consistency between the full bill of lading and the place of departure and destination of the goods.

If the code does not match the inspection content, it will trigger in-depth inspection, such as unpacking inspection of the inner parts and marks of the goods, even sending for inspection and identification, leading to the extension of port detention time of 3-5 days. Enterprises shall prepare inspection supporting documents corresponding to the code before customs declaration to shorten the inspection time.

Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

The selection of entrepot trade declaration codes will affect the judgment standard of packaging compliance. If the code is 0139 (bonded entrepot trade), the goods shall meet the packaging requirements of bonded storage when entering the bonded warehouse, for example, adopt neutral packaging with re-markable marks, and avoid domestic production marks; if the code is 0110 (direct transshipment entrepot trade), the goods shall meet the packaging requirements of transit transportation, for example, adopt moisture-proof and shock-proof reinforced packaging to avoid damage during transshipment.

If the packaging does not meet the requirements corresponding to the code, the customs will require the enterprise to repackage, resulting in additional packaging fees and port detention fees. Enterprises shall formulate the packaging scheme in advance according to the customs declaration code to ensure packaging compliance.

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

Senior Foreign Trade ConsultantStart a Chat

The entrepot trade declaration code directly affects the compliance judgment of export tax refund. Entrepot trade is not within the scope of export tax refund. If an enterprise mistakenly fills the entrepot trade code as the general trade export code, it will trigger an early warning of export tax refund audit, and the tax authority will require the enterprise to submit the authenticity certificate of entrepot trade.

If it cannot be provided, it will be listed as a suspect of tax refund fraud, the refunded tax will be recovered, and a fine of 10%-50% of the tax will be imposed. Enterprises shall clarify the attribute of entrepot trade before customs declaration, avoid misusing export tax refund type customs declaration codes, and retain all documents of entrepot trade as supporting materials for tax audit.

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