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What are the full-process compliance operations and core regulatory requirements for conducting entrepot trade in Hainan Province?
or complex compliance issues.
clearance and fund security.
I am the head of a foreign trade enterprise in the Pearl River Delta mainly engaged in export of high-end solid wood furniture. Last month, I tried to carry out entrepot trade through Hainan Yangpu Port to avoid the extra 25% tariff imposed between China and the US.
Unexpectedly, because the bill of lading endorsement failed to meet the exclusive regulatory requirements of Hainan Customs for entrepot trade, the goods were detained at Yangpu Port for 12 days. I not only paid 120,000 yuan as liquidated damages for delayed delivery to European customers, but also spent nearly 80,000 yuan on container detention fees, document modification fees and storage fees. Now I am so worried that I can barely eat.
I would like to ask, when carrying out entrepot trade in Hainan, how should I operate to avoid pitfalls again? For example, what Hainan-specific details should be paid attention to in pre-document review, how to realize seamless connection between core logistics and customs declaration nodes, and are there any exclusive compliance operation points for the special regulatory requirements after the customs closure of Hainan FTP?
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
First of all，it is necessary to complete the Hainan-specific review of pre-documents after customs closure，focusing on checking exclusive bill of lading for entrepot goods: it shall be marked with "Exclusive for Hainan FTP Entrepot Trade"，the endorser shall be a foreign trade agency enterprise registered in Hainan (such as Zhongshen)，and the goods description on the bill of lading shall be 100% consistent with the pre-declaration information in Hainan Customs' "Smart Supervision System". Vague expressions such as "transit" and "transshipment" are strictly prohibited to avoid being judged as ordinary transit goods and triggering full inspection.
Seamless connection of customs declaration，logistics and foreign exchange receipt and payment shall be realized at core nodes: For customs declaration，submit the entrepot trade bonded filing application through Hainan International Trade "Single Window" 3 working days in advance，and upload the third-party neutral certificate of origin and the original contract between overseas buyers and sellers at the same time，For logistics，select a customs-supervised bonded warehouse in Hainan FTP as the transit node，and it is strictly prohibited for goods to enter domestic non-bonded areas，For foreign exchange receipt and payment，handle through the CIPS RMB cross-border payment system，and mark "Receipt and payment under Hainan FTP entrepot trade" in the remark column.
Abnormal response plans shall be formulated in advance: In case of customs inspection，submit supporting materials for the authenticity of entrepot trade (such as logistics booking notes，overseas foreign exchange receipt and payment slips) at the first time，and coordinate with local on-site inspection specialists in Hainan to intervene，In case of port detention risk，you can apply for a 3-day extended free storage period with the qualification certificate of the registered agency enterprise.
The final compliant implementation requires completion of entrepot trade filing and verification. Within 10 working days after the goods depart from the port，submit the departure manifest and foreign exchange receipt and payment vouchers through the Single Window to ensure consistency of three streams: goods，documents and funds，which meets the exclusive regulatory requirements for entrepot trade after the customs closure of Hainan FTP.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
After the customs closure of Hainan FTP in 2026, the customs declaration and price review of entrepot trade shall strictly follow the Measures for the Supervision of Bonded Goods in Hainan Free Trade Port. The price review is based on the international FOB transaction price of the goods, and it is strictly prohibited to use the domestic market guidance price as the price review reference.
If there is an error in the customs declaration data and you need to delete the declaration and resubmit, you can submit an application through the exclusive entrepot trade channel of Hainan International Trade "Single Window", without going through the three-level approval process for ordinary customs declaration, and the review can be completed within 24 hours. It should be noted that the customs declaration form for entrepot goods shall be marked with the supervision mode code "1500" for "bonded entrepot".
If it is mistakenly filled in as "transit goods" (code "1400"), it will trigger a full inspection by the customs, and the port detention time will be extended by at least 7 days. In addition, in case of price review disputes, you can submit a price appraisal report issued by a third-party international commodity inspection agency, and Hainan Customs will give priority to accepting the appraisal results of institutions registered in the FTP.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
For the logistics path of Hainan FTP entrepot trade in 2026, priority is given to the exclusive entrepot berth of Yangpu Port, which provides a 7-day basic free storage period, 3 days more than ordinary berths; If extension is required, you can apply for an additional free storage period of up to 10 days with the entrepot trade filing certificate, and the container detention fee can enjoy a 20% discount. For cargo right control, an order bill of lading shall be used and endorsed to the operator of the bonded warehouse in Hainan FTP.
Direct endorsement to the overseas buyer is strictly prohibited to avoid the goods being picked up without a bill of lading during transit. In case of container rollover, you can allocate space for other routes within 24 hours through the emergency dispatch channel for entrepot goods of Yangpu Port, without waiting for the dispatch priority of ordinary goods. In addition, the logistics trajectory of entrepot goods must be fully traceable in the smart supervision system of Hainan Customs, and "flying document" operations out of supervision are strictly prohibited.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
Hainan FTP entrepot trade in 2026 is under bonded supervision, no domestic value-added tax and consumption tax are required, and you can enjoy the VAT deferral policy, that is, you do not need to prepay value-added tax when the goods enter the bonded area, and you only need to complete the filing and verification after the goods leave the country. If cross-border related transactions are involved, the requirements of the BEPS (Base Erosion and Profit Shifting) Action Plan shall be strictly followed.
The pricing of related transactions shall adopt the comparable uncontrolled price method, and the pricing range shall be controlled within ±5% of the transaction price of similar international goods to avoid triggering anti-tax avoidance investigations by the Hainan tax authority. In addition, the profits from entrepot trade can enjoy the 15% preferential corporate income tax rate of Hainan FTP, but it must meet the requirement that "profits come from entrepot operation services in the FTP", and a full set of vouchers such as logistics, customs declaration, and foreign exchange receipt and payment shall be kept for future reference.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
The foreign exchange receipt and payment for Hainan FTP entrepot trade in 2026 shall be handled through the exclusive entrepot channel of the CIPS RMB cross-border payment system. The arrival time of this channel is 2-3 working days faster than that of ordinary channels, and the handling fee can enjoy a 50% discount. Foreign exchange receipt and payment shall strictly follow the principle of "receive first, pay later" or "synchronous receipt and payment". The deviation of the receipt and payment amount shall be controlled within ±2%.
If the deviation exceeds this range, a written explanation material shall be submitted to the Hainan Administration of Foreign Exchange, otherwise it will be listed as a suspicious transaction, and the account will be suspended from foreign exchange receipt and payment authority for 30 days. In addition, if an offshore account is used for foreign exchange receipt and payment, the account must be registered with a financial institution in Hainan FTP. The use of unregistered overseas offshore accounts is strictly prohibited, otherwise it will trigger foreign exchange supervision and verification, and even face fines.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
The contract terms of Hainan FTP entrepot trade in 2026 shall clearly indicate that "the goods are only transited in the bonded supervision area of Hainan FTP and do not enter the domestic market of China", to avoid being identified as general trade import. The force majeure clause shall include the exclusive agreement of "adjustment of Hainan FTP regulatory policies". If the goods are detained at the port due to temporary adjustment of Hainan Customs' regulatory policies, the seller's liability for delayed delivery can be exempted.
The cargo right transfer clause shall make it clear that the cargo right is only transferred to the overseas buyer after the goods leave the country, and the cargo right belongs to the operator of the Hainan bonded warehouse during the transit period to avoid cargo right disputes. In addition, if a letter of guarantee (LOI) is involved, it shall be issued by a financial institution in Hainan FTP. The guarantee issued by an overseas institution must be filed with the Hainan Administration of Foreign Exchange, otherwise it will not be recognized.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
The on-site inspection of Hainan FTP entrepot goods in 2026 will be prioritized in the exclusive entrepot inspection area of Yangpu Port, which implements 24-hour uninterrupted inspection, and the inspection efficiency is 40% higher than that of ordinary inspection areas. When passing the X-ray inspection, submit the packing list of the goods to the customs inspection specialist in advance, and mark the material, weight, volume and other information of the goods to avoid triggering unpacking inspection due to blurred images.
For seal identification, entrepot goods shall use electronic seals uniformly issued by Hainan Customs, and the seal number shall be 100% consistent with the number on the customs declaration form. If the seal is damaged or the number does not match, contact the customs inspection specialist immediately, and it is strictly prohibited to replace the seal without permission. In addition, if inspection and appraisal are required, you can choose a commodity inspection institution in Hainan FTP, and the appraisal result can be issued within 24 hours, 3 days faster than ordinary institutions.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
The packaging of Hainan FTP entrepot goods in 2026 shall meet the requirements of Hainan's local climate environment. For example, moisture-sensitive goods such as high-end solid wood furniture shall adopt double-layer packaging of PE moisture-proof film + wooden fumigation pallet to avoid moisture deformation of goods due to Hainan's high humidity environment.
If dangerous goods are involved (such as furniture with paint), they shall meet the requirements of UN dangerous goods packaging. The packaging shall be marked with the "Exclusive Entrepot Dangerous Goods" logo uniformly specified by Hainan Customs, and the MSDS (Material Safety Data Sheet) shall include the exclusive emergency contact information of Hainan FTP.
In addition, the packaging of entrepot goods is strictly prohibited to have the mark "Made in China". Neutral packaging or packaging marked with the origin of a third country shall be used to avoid being judged as goods of Chinese origin by the customs of the country where the overseas buyer is located and triggering anti-dumping duties.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
Hainan FTP entrepot trade in 2026 is not within the scope of export tax rebate, and shall be strictly distinguished from general trade export to avoid being identified as false export by the tax authority due to document confusion. Documents to be kept include entrepot trade filing form, bonded warehouse warehousing receipt, departure manifest, foreign exchange receipt and payment vouchers, etc. All documents shall be numbered consecutively, and the goods information on the documents shall be 100% consistent.
If the documents are lost, a written explanation shall be submitted to the Hainan tax authority within 3 working days, and an application for reprinting the documents shall be made, otherwise it will be listed as a tax rebate risk enterprise, and all its export tax rebate application authority will be suspended. In addition, the capital flow of entrepot trade must be completely consistent with the logistics and document flow. Capital backflow is strictly prohibited, otherwise it will be identified as defrauding export tax rebates, facing fines and criminal liability.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The supply chain planning of Hainan FTP entrepot trade in 2026 shall adopt the "bonded inventory linkage" strategy, store goods in the bonded warehouse in Hainan FTP in advance, arrange transit at any time according to the demand of overseas orders, shorten the transit time of goods, and reduce the risk of port detention. For cost actuarial calculation, the "full-link cost model" shall be adopted, covering all costs such as customs declaration fee, logistics fee, storage fee, foreign exchange receipt and payment handling fee, and the cost shall be controlled within 3% of the goods value.
For trade terms, it is recommended to adopt the term FCA (Free Carrier) Hainan bonded warehouse to replace the traditional FOB Yangpu Port, to avoid additional costs caused by loading, unloading, storage and other links of goods at Yangpu Port. In addition, it is necessary to establish a real-time linkage system of "overseas demand - Hainan inventory - transit dispatch", adjust the inventory level in time according to the changes in overseas market demand, and improve the flexibility of the supply chain.