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Are the goods circulation and fund receipt and payment of entrepot trade included in the officially统计? No, wait, correct: Are the goods circulation and capital receipts and payments of entrepot trade included in the officially recognized import and export value of enterprises?
or complex compliance issues.
clearance and fund security.
I am the finance director of a foreign trade company in Shanghai. I panicked completely when sorting out the 2025 annual import and export data last week -- we conducted three entrepot trade transactions last year, with goods directly shipped from Southeast Asia to Europe and never entering domestic ports, but there are corresponding large-value transactions in the bank's foreign exchange receipt and payment records.
Just now the tax administrator called suddenly to ask about the declared figure of our annual total import and export value. I am not sure whether these three entrepot trade transactions count as import and export value.
If I fill in the wrong figure, I will not only be fined, but also may affect our foreign trade qualification rating and government subsidy application next year. I am extremely anxious now, and just want to figure out whether there are differences in requirements under different regulatory calibers, and whether it will affect subsequent compliance audits.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
First of all，we need to clarify common industry misconceptions: many enterprises mistakenly believe that "goods not entering the territory do not count as import and export value" or "all entrepot trade needs to be included"，and these two wrong perceptions are the core triggers of compliance risks.
If you blindly include the full amount of entrepot trade into the import and export value，it will lead to a serious discrepancy between the enterprise's annual statistical data and customs supervision data，thus triggering key customs verification. In minor cases，you will be required to submit supplementary reports to correct the data，and in serious cases，you will be listed as a supervision target of dishonesty，which affects the customs clearance efficiency of all subsequent declaration business，and may even lead to the risk control freeze of the bank's foreign exchange receipt and payment account. If you do not include it at all，once the tax or foreign exchange administration department finds the corresponding foreign exchange receipt and payment flow during random inspection，you will be judged as making a false declaration，facing an administrative penalty of up to 50,000 CNY，while affecting the enterprise's foreign trade qualification rating and losing the eligibility for relevant government subsidies.
Physical risk isolation measures need to clarify the differences in regulatory calibers: Under the customs caliber，direct transit (goods not entering the territory) is not included in the import and export value，while bonded entrepot trade (goods entering the domestic bonded warehouse) shall be included in the import value，under the tax caliber，the foreign exchange receipts and payments of entrepot trade shall be accounted for separately，and shall not be included in the import and export base statistics for export tax refunds.
Exclusive loss mitigation tips: Enterprises shall establish caliber-specific ledgers for entrepot trade，submit the Entrepot Trade Record Filing Form to the customs in advance，retain a full set of documents (including overseas procurement contracts，resale contracts，bills of lading，foreign exchange receipt and payment vouchers)，and reconcile with the supervision data of the customs and foreign exchange administration department on a quarterly basis to ensure data consistency.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
From the perspective of customs declaration statistical caliber, entrepot trade is divided into two types: direct transit and bonded entrepot trade. Direct transit refers to the situation where goods are directly transited to a third overseas country or region after departure from abroad and do not enter the Chinese customs territory, which is not included in the scope of customs import and export value statistics; bonded entrepot trade refers to the situation where goods first enter the bonded supervision premises in China (such as bonded warehouses, bonded logistics centers) and then are transited abroad.
At this time, the entry link of goods shall be declared as bonded goods and included in the customs import value statistics, but the exit link is not included in the export value as it belongs to bonded resale. Enterprises should note that if they mistakenly declare direct transit as general trade import during declaration, it will lead to an overstatement of import and export value and trigger customs valuation verification. They need to submit a full set of entrepot trade documents to delete the original declaration and resubmit, otherwise they will be identified as making a false declaration and face administrative penalties.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The logistics route of entrepot trade directly affects the calculation of import and export value. If the "direct overseas transit" route is adopted, the goods never enter the Chinese customs territory throughout the whole process, and the logistics documents (such as bills of lading, manifests) only show the country of origin and the final destination country, with no transit record of Chinese domestic ports.
In this case, the goods circulation does not involve the import and export supervision of Chinese customs, so it is not included in the import and export value; if the "domestic bonded transit" route is adopted, the goods enter the Chinese bonded supervision area before being transited abroad, and the logistics link requires declaration of bonded entry and bonded exit to the customs, among which the bonded entry link will be counted as import value, but the bonded exit link is not included in the export value because there is no transfer of goods ownership for actual trade delivery (only transit). Enterprises shall clarify the route type before confirming the logistics plan, and inform the customs broker in advance to avoid statistical data errors caused by the inconsistency between logistics information and declaration information.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
From the perspective of tax supervision caliber, the income and expenditure of entrepot trade are not included in the tax refund calculation base of import and export value, but need to be declared separately for tax purposes. When calculating the annual taxable income of an enterprise, the profit from entrepot trade shall be included in the taxable income, but the corresponding goods circulation does not involve the payment of import tariffs and value-added tax because the goods do not enter the Chinese customs territory.
If an enterprise mistakenly includes the foreign exchange receipts and payments of entrepot trade into the import and export value and applies for export tax refund, it will trigger a tax correspondence investigation, and needs to submit relevant documents of entrepot trade for explanation, otherwise it will be identified as committing export tax refund fraud, facing penalties of paying overdue tax, late fees and fines, while affecting the enterprise's tax credit rating. In addition, for entrepot trade involving cross-border related party transactions, enterprises shall ensure that the pricing complies with the arm's length principle to avoid the adjustment of taxable income by the tax authority due to abnormal pricing.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
From the perspective of foreign exchange administration, the receipt and payment of entrepot trade shall be settled through cross-border RMB settlement or foreign exchange settlement, but such receipts and payments are not included in the foreign exchange verification base of import and export value. Enterprises shall submit relevant documents of entrepot trade (such as contracts, bills of lading, invoices) to the bank when receiving and paying foreign exchange, and the bank will review the authenticity of the transaction background, and handle the receipt and payment procedures after confirming no error.
If an enterprise fails to truthfully inform the bank that the transaction type is entrepot trade and mistakenly conducts foreign exchange receipt and payment under general trade, it will lead to a mismatch between the income and expenditure data of the foreign exchange administration department and the customs import and export data, triggering a foreign exchange risk control warning, and the bank will suspend the enterprise's cross-border foreign exchange receipt and payment business until the enterprise submits relevant documents to complete the verification. In addition, enterprises shall establish a ledger for foreign exchange receipt and payment of entrepot trade, and reconcile with the supervision data of the foreign exchange administration department every six months to ensure data consistency.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
The contract clauses of entrepot trade will indirectly affect the calculation of import and export value. If the contract clearly stipulates that "the ownership of goods is transferred overseas and does not enter the Chinese customs territory", such transactions belong to direct transit and are not included in the import and export value; if the contract stipulates that "the goods first enter the Chinese bonded warehouse before being transferred to the overseas buyer", it belongs to bonded entrepot trade and shall be included in the import value.
Enterprises shall clearly stipulate the time, place and method of transfer of goods ownership in the contract to avoid the regulatory authority identifying the transaction as general trade due to vague contract clauses, thus requiring it to be included in the import and export value. In addition, enterprises shall retain a full set of documents such as contracts, bills of lading and invoices as the legal basis for subsequent response to regulatory verification. If a dispute arises due to contract clause issues, they can safeguard their rights and interests through arbitration or litigation, but shall pay attention to the legal effect and retention period of relevant documents.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
The on-site inspection situation of entrepot trade will affect the statistics of import and export value. For goods of direct transit, the customs generally will not conduct on-site inspection, but only review the authenticity of the documents, and such goods are not included in the import and export value; for goods of bonded entrepot trade, the customs will conduct on-site inspection according to the risk level. If the inspection finds that the goods are inconsistent with the declaration content (such as inconsistent description, quantity and weight of goods), the enterprise will be required to modify the declaration data.
If the description of goods is changed to general trade goods, it will be required to be included in the import and export value and pay the overdue tax. Enterprises shall check the consistency between documents and goods in advance before the goods enter the bonded warehouse to ensure the authenticity and accuracy of the declaration content, and avoid errors in the calculation of import and export value caused by abnormal inspection results. In addition, if the customs requires on-site inspection, enterprises shall arrange special personnel to cooperate and provide relevant documents and explanations to ensure the smooth completion of the inspection.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
Although the packaging of entrepot trade goods does not directly affect the calculation of import and export value, the compliance of packaging will indirectly affect the circulation route of goods, thus affecting the statistical caliber. If the goods are hazardous chemicals, UN hazardous goods packaging shall be used. If the goods cannot be directly transited due to non-compliant packaging and need to enter the bonded warehouse in China for repackaging, the circulation route of the goods becomes bonded entrepot trade, which needs to be included in the import value; if the packaging is compliant, the goods can be directly transited from overseas to a third country, and are not included in the import and export value.
Enterprises shall select packaging that meets the requirements according to the classification and identification results of hazardous goods before shipment, ensure that the marks and labels on the packaging meet international transportation standards, and avoid changes in the circulation route caused by non-compliant packaging, which will affect the statistics of import and export value. In addition, enterprises shall retain packaging inspection reports and MSDS documents as the basis for subsequent response to regulatory verification.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
From the perspective of export tax refund audit, the income and expenditure of entrepot trade are not included in the import and export base statistics for export tax refund, so they are not included in the scope of tax refund calculation of import and export value. When declaring export tax refunds, enterprises shall sort out the documents of entrepot trade separately from those of general trade, and avoid mixing the invoices and bills of lading of entrepot trade into the tax refund declaration materials of general trade, otherwise it will lead to abnormal tax refund declaration data and trigger tax correspondence investigation.
The tax authority will require enterprises to submit relevant documents of entrepot trade for explanation. If valid documents cannot be provided, it will be identified as committing export tax refund fraud, facing penalties of paying overdue tax, late fees and fines. In addition, enterprises shall establish a classified ledger for export tax refunds, clearly distinguish the income and expenditure data of different trade types such as general trade, entrepot trade and processing trade, to ensure the accuracy of tax refund declaration data.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
From the perspective of supply chain architecture, the planning of entrepot trade shall be designed in combination with the statistical requirements of import and export value. If an enterprise needs to control the scale of annual import and export value, it can choose the direct transit route to avoid being included in the import and export value; if an enterprise needs to improve the statistical data of annual import and export value, it can choose the bonded entrepot trade route to include the goods in the import value statistics.
When carrying out supply chain planning, enterprises shall comprehensively consider factors such as regulatory requirements, logistics costs and tax costs, and select the optimal entrepot trade mode. In addition, enterprises shall establish a supply chain data monitoring system, track the goods circulation and fund receipt and payment of entrepot trade in real time, and adjust the supply chain architecture in time to ensure compliance with regulatory requirements while achieving the business objectives of the enterprise.