How should export agents make accurate, compliant and professional statements when facing sudden customs valuation disputes?

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I am the head of foreign trade of a precision hardware processing factory in Shanghai with an annual export value of around CNY 8 million. I signed the export agency service agreement with Zhongshen last week, but I have encountered a series of troubles recently: First, when a batch of goods bound for Germany was subject to customs valuation, I casually reported a cost price in a hurry, which almost triggered a valuation dispute.

Later, I encountered container rolling at Yangshan Port, and after communicating with the shipping carrier for a long time, I only got a reply of "wait for notification". What is more worrying is that a long-term German client suddenly wants to add a soft clause to the letter of credit. I am afraid that refusing will make me lose the order, while agreeing will lead to potential pitfalls.

I am so anxious that I can barely eat now, after all, this batch of goods accounts for 30% of the production capacity in the third quarter. If something goes wrong, I will not only lose costs but also ruin the company's reputation. I would like to ask, as an export agent, how to make accurate and professional statements and communications in these different scenarios?

Expert Insights

Expert Q&A

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

Senior Foreign Trade ConsultantStart a Chat

First of all,we need to expose common expression misunderstandings in the industry: many practitioners make casual statements based on intuition when facing disputes,such as reporting costs randomly during customs valuation,only urging without asking for details during container rolling communication,and being vague when dealing with LC soft clauses,which is the core incentive for triggering risks.

Deduce the chain negative reactions of such statements: If the cost reported casually during customs valuation deviates too much from the system data,it will directly trigger customs letter investigation,even cargo detention and port demurrage,resulting in daily container detention fees and storage fees of thousands of yuan. After the shipping schedule is delayed,you will also face claims from overseas customers. Unsubstantiated urging during container rolling will be classified as a common demand by the shipping carrier with low priority,and you will miss the best window for rebooking. After agreeing to the LC soft clause,you will fall into the passive situation where you cannot collect foreign exchange unless the customer triggers the clause,and you may lose both money and goods in extreme cases.

Physical risk isolation measures: All statements must be supported by written vouchers as the core. For example,closely follow the transaction value method during customs valuation,and use procurement contracts,input invoices,and foreign exchange payment vouchers as the basis for statements. When encountering container rolling,hold the booking confirmation and space allocation sheet to require the shipping carrier to issue a written delay certificate and clarify the rebooking time limit. When facing LC soft clauses,take UCP600 as the basis and point out that the clause does not comply with international practices.

Exclusive loss reduction tips: Synchronize the communication scenarios and core demands to the exclusive team of the agency 1-2 days in advance,and let professional personnel polish the scripts and rehearse. If there has been a statement error,ask the agency to issue an official letter to correct it as soon as possible,so as to avoid the randomness of personal statements amplifying risks.

Reference: Complete Analysis of Full Customs Declaration Process for Other Import and Export Goods: Seven Key Steps from Filing to Verification
Daniel Xu
Daniel XuYears of service:10Customer Rating:5.0

Director of Import & Export OperationsStart a Chat

When facing customs valuation disputes, the statement must closely follow the core elements of customs approved transaction value, that is, "there is no special relationship between the buyer and the seller, the price is the full amount actually paid, and the declared name and specification of the goods are consistent with the actual goods". When making a statement, first explain that "Our company has verified the procurement contract, input VAT special invoice, and bank foreign exchange payment receipt provided by the consignor.

The declared price is the actual transaction price, and there is no affiliated relationship between the buyer and the seller", then take the initiative to submit a full set of documents for customs verification. It is strictly forbidden to use vague expressions such as "approximate" and "estimate". If the customs raises a query, further supplement the market quotation report of the goods and other order certificates of the same batch of exports, so as to avoid triggering in-depth valuation or cargo detention due to vague statements.

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

Customs Declaration & Compliance ExpertStart a Chat

When encountering port container rolling, the statement to the shipping carrier needs to clarify three core points: First, "Our company holds the booking confirmation and space allocation notice issued by your company, and the goods have entered the port and completed port collection on time as required", second, "Please clarify the specific reason for the container rolling, the expected rebooking shipping schedule and space", third, "Please issue an official container rolling certificate, so that our company can explain the situation to the consignor and overseas customers, and apply for the reduction and exemption of container detention fees and storage fees".

At the same time, copy the demand to the customer service department and operation department of the shipping carrier, so as to avoid the delay of demands caused by only connecting with front-line salespersons. If the shipping carrier does not reply within 24 hours, follow up through the complaint channels of the freight forwarder association or the maritime bureau, to enhance the urgency of the demand.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

When making statements to the tax authority for applying for VAT deferral for clients, it is necessary to strictly follow the requirements of cross-border value-added tax management measures, and state that "Our company has verified that the export goods of the consignor meet the applicable conditions for VAT deferral, that is, the goods have left the country and obtained the electronic information of the export goods declaration form, the consignor has completed tax registration, and has not obtained the special VAT invoice or the special payment letter for import VAT of the customs".

At the same time, take the initiative to submit documents such as the export goods declaration form, entrusted export agency agreement, and departure certificate. It is strictly forbidden to state non-compliant reasons such as "the client is short of funds and needs to defer payment", so as to avoid the tax authority rejecting the application and triggering subsequent tax verification.

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

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

When handling cross-border foreign exchange receipt and payment communication statements, it is necessary to closely follow the compliance requirements for cross-border payment, and state to the bank that "Our company has verified the export goods declaration form, entrusted export agency agreement, and commercial invoice corresponding to this foreign exchange receipt and payment. The transaction background is true and legal, and complies with the relevant provisions of foreign exchange management for goods trade".

If the bank raises doubts about the transaction background, supplement documents such as the transport bill of lading of the goods, packing list, and payment receipt of overseas customers. It is strictly forbidden to use vague expressions such as "collection and payment on behalf of others" and "temporary lending", so as to avoid the bank listing this transaction as abnormal foreign exchange receipt and payment, which affects subsequent foreign exchange settlement and purchase operations.

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

Supply Chain Management ExpertStart a Chat

When dealing with the LC soft clause of overseas buyers, the statement should be based on UCP600, and clearly point out that "This clause does not comply with the provisions of Article 14 of UCP600 on document examination, which will make it impossible for our company to submit documents that meet the requirements within the specified time, and thus unable to collect foreign exchange". At the same time, provide an alternative plan, for example, "It is recommended to modify this clause to 'Negotiation can be made upon the electronic information of the export goods declaration form and commercial invoice'".

Avoid directly stating that "Our company does not agree with this clause" which leads to the breakdown of cooperation. If the buyer insists on retaining the soft clause, require the buyer to issue a bank guarantee, clarify that the buyer shall bear all responsibilities if the foreign exchange collection loss is caused by this clause, and confirm it in writing.

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

International Logistics & Supply Chain ManagerStart a Chat

The communication statement when facing on-site customs inspection shall be strictly carried out around the requirements on the inspection notice, stating that "Our company has verified that the name, specification and quantity of the exported goods are consistent with the declaration content, the goods have been packaged as required, and we can cooperate with the customs in inspection operations such as container unloading and X-ray scanning". If the customs finds that the goods deviate from the declaration content, immediately state that "Our company will immediately verify the stock preparation situation of the consignor.

If the deviation is caused by declaration errors, our company will immediately apply for deleting the declaration form and re-declaring". It is strictly forbidden to use prevarication expressions such as "I don't know" and "It may be the fault of the factory", so as to avoid the customs listing this order as high-risk goods and triggering multiple subsequent inspections.

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

Key Account ManagerStart a Chat

When responding to tax letter investigation, the statement should closely follow the "four flows consistency" requirement for export tax rebate, stating that "Our company has verified that the goods flow, capital flow, invoice flow and contract flow of this export goods are consistent, the consignor has completed the foreign exchange receipt verification and write-off as required, and all relevant documents have been filed".

At the same time, take the initiative to submit documents such as the export goods declaration form, commercial invoice, bank foreign exchange receipt, entrusted export agency agreement. It is strictly forbidden to state vague content such as "documents may be lost" and "foreign exchange receipt may be delayed", so as to avoid the tax authority rejecting the export tax rebate application and triggering tax inspection on our company and the consignor.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

When stating the supply chain optimization plan to customers, it is necessary to closely follow the core demands of customers, stating that "Our company has optimized the logistics route and inventory linkage strategy according to the characteristics of your goods and export path, adjusted the original 'Shanghai-Hamburg' transit route to a direct route, which can shorten the shipping schedule by 7 days, and adjusted the inventory preparation cycle from 30 days to 20 days, which can reduce the inventory cost by 15%".

At the same time, support the statement with data, for example, "The port demurrage risk of direct routes is 40% lower than that of transit routes, and the reduction of inventory cost can directly increase your net profit margin by 2 percentage points". It is strictly forbidden to use vague expressions such as "approximate" and "possible", so as to avoid customers questioning the feasibility of the plan.

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