Connect & Solve
Trade Q&A
Whether goods under entrepot trade entering or exiting China's customs territory need to be included in customs statistics?
or complex compliance issues.
clearance and fund security.
I am a salesperson at a foreign trade company in Shanghai mainly engaged in entrepot trade from Southeast Asia to Europe. Just received a 5 million RMB natural rubber entrepot trade order last week, planned to transit via Yangshan Bonded Port Area. I heard from peers chatting before that some entrepot trade does not need to be included in customs statistics, while some must be declared for statistics, but no one clarified the specific rules. Just now the customs broker called suddenly to ask whether I need to declare according to the statistical caliber of entrepot trade, and I panicked instantly — if I make a mistake in declaration, will it lead to cargo detention and customs seizure?
If I fail to include the statistics as required, will it affect the company's customs credit rating? The customer is in a hurry for this order, and the liquidated damages account for 8% of the goods value. I am now restless, just want to figure out whether entrepot trade is included in customs statistics? Are there differences in statistical requirements among different operation modes?
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
Many foreign trade enterprises have a common misconception: they think all entrepot trade does not need to be included in customs statistics，which is actually a misreading of the statistical caliber. The core judgment standard of customs statistics is whether the goods actually enter and exit China's customs territory — if the goods directly enter China's customs territory from abroad and then exit，regardless of whether they pass through the bonded supervision sites，they must be included in the statistics，if the goods only transit in the bonded supervision sites and do not actually enter China's customs territory (i.e。the "inside the territory but outside the customs" mode)，they do not need to be included in the statistics.
Misjudging the statistical requirements may trigger a series of negative reactions: for example，reporting the required statistical entrepot trade as non-statistical transit trade will lead to the discrepancy between customs statistics data and actual cargo flow，trigger customs audit，and the goods may be detained at port and seized，resulting in daily container detention fees and port detention fees of thousands of yuan，if you fail to declare the statistical data as required，it will also affect the enterprise's customs credit rating. After downgrade，not only the customs clearance time will be halved，but also preferential policies such as bonded warehousing and fast customs clearance will be lost.
The key to physical risk isolation is to clarify the customs territory flow of goods: if the goods need to enter China's domestic warehouse before being re-exported，they must be declared according to the statistical caliber of entrepot trade in advance，if the goods only transit in "inside the territory but outside the customs" places such as bonded port areas and comprehensive bonded zones，and directly change ships for export，you can apply for exemption from statistical declaration with entrepot trade documents.
Exclusive Risk Mitigation Tip: For high-value entrepot trade orders，you can apply for "pre-statistics determination" from the local customs 3 working days in advance，and arrange customs declaration after obtaining the official determination opinion，if you have made a wrong declaration，you need to submit the Statistical Data Correction Application within 24 hours after the goods enter the territory，and attach supporting materials such as title of goods certificate and transit agreement，to strive for exemption from punishment.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
When declaring entrepot trade, it is necessary to match the corresponding supervision mode code to clarify the statistical attribute: if the goods actually enter and exit China's customs territory, "entrepot trade" (supervision mode code 0130) shall be used for declaration, which must be included in customs statistics; if the goods only transit in the bonded supervision sites without entering the territory, "bonded supervision site entrepot trade" (supervision mode code 1234) shall be used for declaration, which does not need to be included in regular statistics.
If the supervision code is selected incorrectly when declaring, it will trigger warnings from the customs document examination system, leading to declaration return, deletion and re-declaration, and even customs audit with pending handling. At this time, you need to timely submit supporting materials such as transit agreement and title transfer certificate to apply for manual examination, so as to avoid affecting subsequent customs clearance.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The logistics path of entrepot trade directly determines whether it should be included in customs statistics: if the path is "abroad - China customs territory warehouse - abroad", the goods actually enter and exit the customs territory and must be included in the statistics; if the path is "abroad - China bonded supervision sites - abroad" direct transshipment path, the goods are always in the "inside the territory but outside the customs" state and do not need to be included in the statistics.
In logistics operation, it is necessary to confirm the qualification of the bonded site in advance to ensure that the goods do not enter the territory during transit, and require the shipping company to issue a "through bill of lading" to clarify that the title of goods has not been transferred within China, so as to avoid mis-statistics due to vague logistics documents. If the goods accidentally enter the territory, you need to immediately apply to the customs for changing the supervision mode and adjusting the statistical declaration.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
Whether entrepot trade is included in customs statistics will indirectly affect tax treatment: the entrepot trade included in the statistics needs to be marked as "entrepot trade income" in VAT declaration, and no VAT needs to be paid; the bonded entrepot trade not included in the statistics needs to include income in "cross-border service income", which also enjoys VAT exemption policy, but it is necessary to retain transit vouchers and through bills of lading from the bonded sites for future reference.
If the tax is not declared according to the statistical caliber, it may trigger tax investigation, requiring the enterprise to provide matching certificates of cargo flow, capital flow and document flow. If it cannot be provided, the enterprise will be required to pay back VAT and late payment fees.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
The customs statistics status of entrepot trade will affect the compliance review of foreign exchange receipt and payment: the entrepot trade included in the statistics needs to provide customs statistical declaration form to the bank when receiving and paying foreign exchange. The bank will compare the declaration form information with the State Administration of Foreign Exchange (SAFE) system, and handle the receipt and payment after confirmation; the bonded entrepot trade not included in the statistics needs to provide transit certificates and through bills of lading from the bonded supervision sites.
The bank does not need to compare customs statistics data, but needs to verify the authenticity of the title of goods certificate. If the statistical status does not match the foreign exchange receipt and payment materials, the enterprise will be listed as a "concerned enterprise" by SAFE, and the subsequent foreign exchange receipt and payment quota will be restricted. At this time, you need to submit supplementary supporting materials to apply for lifting the restriction.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
The customs statistics requirements of entrepot trade need to be clearly agreed in the contract to avoid legal risks: if the goods need to be included in customs statistics, it should be noted in the contract that "the goods enter and exit China's customs territory for entrepot trade", and agree that the declarer is responsible for declaring according to the statistical caliber; if the goods do not need to be included in the statistics, it should be noted that "the goods only transit in China's bonded supervision sites and do not enter China's customs territory".
If the contract agreement does not match the actual operation, leading to wrong statistical declaration, it may cause breach of contract disputes between the buyer and the seller. At this time, the customs statistical determination opinion shall be used as evidence to negotiate and adjust the contract terms, or resolve the dispute through arbitration.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
Neither included nor not included in customs statistics, entrepot trade does not fall within the scope of export tax rebate, which is a common misconception among enterprises. If an enterprise mistakenly declares entrepot trade income as export tax rebate income, it will trigger tax rebate audit warning. The tax department will require the enterprise to return the refunded tax and may impose a fine.
In document management, it is necessary to separate the entrepot trade declaration forms (whether included in statistics or not) from the export tax rebate declaration forms, and retain transit agreements and foreign exchange receipt and payment vouchers for no less than 5 years for tax rebate audit verification. If you have mistakenly declared tax rebate, you need to timely submit a correction application to the tax department and actively return the tax refunded, so as to strive for lenient punishment.