What Are the Full-Process Operation Steps and Precautions for Entrepot Trade in North China?

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I am the head of a hardware accessories export factory based in Tianjin. Last year, due to the additional anti-dumping duties imposed by the US on our product category, we cooperated with a small agency to conduct transshipment. However, our goods were detained at Qingdao Port for a week and almost got seized by customs.

We paid more than 100,000 RMB just for container detention charges and breach of contract penalties! Now we have another two 40-foot containers of goods ready to ship to the US, and we plan to go through North China entrepot trade, but we are afraid of making mistakes again.

We want to know how to operate the entire process correctly from document preparation, logistics connection to final compliance implementation? Especially the unique operation details for entrepot trade at North China ports such as Tianjin and Qingdao, and how to stop losses quickly if abnormality occurs again. We are really anxious about this!

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Expert Q&A

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

Key Account ManagerStart a Chat

Pre-document verification is the core prerequisite of North China entrepot trade. We need to focus on checking the authenticity of certificate of origin issued by suppliers in the transshipment country,and require them to provide corresponding raw material procurement certificates and production records matching the certificate of origin,so as to avoid triggering anti-circumvention investigation in the destination country due to forged documents. Meanwhile,confirm the supervision code (0110) for "entrepot trade" for domestic customs declaration in advance,ensure that the goods description on the manifest,invoice and packing list has no logical conflict with that on the transshipment country's documents,and eliminate any ambiguous expression.

Core node connection requires simultaneous advancement of three links: First,when declaring at domestic ports (Tianjin/Qingdao),inform customs of the transshipment attribute in advance,and apply for "direct transshipment" instead of "transshipment after customs clearance" to reduce supervision risks after goods arrive at the port,Second,the logistics service provider in the transshipment country needs to submit the container swapping plan 24 hours in advance,to ensure that the operations of devanning,container swapping and resealing at the transshipment port are completed within 12 hours,compressing the window of port detention risk,Third,when clearing customs at the destination country,the agent in the transshipment country shall submit the full set of compliance documents at the same time,ensure complete separation from domestic export documents,and avoid associated inspection.

Emergency plans need to cover two high-frequency scenarios: If delay occurs at the transshipment port due to inspection,immediately launch the emergency re-booking plan for alternative transshipment port (e.g. Busan Port),and lock the alternative booking on the same route in advance,If the destination country questions the authenticity of the certificate of origin,the supplier in the transshipment country will cooperate to provide the third-party origin traceability report. For final compliance implementation,retain the full set of documents for at least 5 years,including container swapping photos at transshipment port,seal number records,logistics certificates of transshipment country,etc。to cope with subsequent retrospective inspection by tax authorities or customs.

Reference: Shanghai Port Transshipment Trade: Operations & Challenges
Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

For customs declaration of North China entrepot trade, pay attention to accurate declaration of supervision method, and do not confuse "entrepot trade" (code 0110) with "bonded entrepot trade" (code 1200). If misdeclared as bonded entrepot trade, it will trigger the customs bonded supervision process, forcing goods to enter the bonded warehouse and increasing warehousing cost and transshipment time. In addition, the "final destination country" on the customs declaration shall be truthfully filled as the destination country instead of the transshipment country, otherwise it will be determined as false declaration by customs, resulting in container detention and fines.

In the price verification process, you need to provide container swapping fee certificates and local warehousing invoices from the transshipment country to prove the rationality of the entrepot trade, so as to avoid customs initiating price verification disputes on the grounds of "undervaluation". If you receive a price verification query, you need to submit complete supporting materials such as entrepot trade contract and logistics agreement within 3 working days to strive for quick release.

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

Senior Foreign Trade ConsultantStart a Chat

For logistics routes of North China entrepot trade, prioritize Tianjin Port or Qingdao Port as the domestic departure port. These two ports have dense direct routes to transshipment ports in Japan, South Korea and Southeast Asia, with higher booking stability. In terms of cargo title control, adopt "order bill of lading", and only authorize the endorsement right to the designated agent in the transshipment country, to avoid goods being picked up without bill of lading.

The container swapping process requires full video monitoring, retain complete video records of devanning, container swapping and sealing, to ensure no damage or substitution of goods during transshipment. Application for free storage period shall be communicated with the transshipment port logistics service provider in advance, generally 3-5 days of free storage can be applied.

If extension is needed due to inspection delay, submit written application in advance and pay a small amount of deposit. If container rolling off occurs, activate the alternative route immediately, prioritize other shipping companies on the same route, to ensure goods are re-shipped within 72 hours.

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

Supply Chain Management ExpertStart a Chat

For tax planning of North China entrepot trade, focus on VAT deferral and related party transaction pricing. As an intermediary of entrepot trade, domestic enterprises can apply for zero VAT rate declaration, but need to provide full set of documents for entrepot trade, including procurement contract, sales contract and logistics certificates from the transshipment country.

If cross-border related party transactions are involved, ensure the transaction price conforms to the arm's length principle, to avoid transfer pricing adjustment by tax authorities. In addition, the tax cost of the transshipment country shall be calculated in advance, for example, some Southeast Asian countries levy 0.5%-1% service tax on entrepot trade, which shall be included in the overall cost.

If the enterprise has an overseas company in the transshipment country, it can use local preferential tax policies, such as Singapore's income tax reduction policy for entrepot trade, to reduce the overall tax cost. But it is necessary to pay attention to tax compliance, retain all tax documents for at least 7 years to cope with inspection by tax authorities.

Victor Sun
Victor SunYears of service:5Customer Rating:5.0

Trade Risk Control ManagerStart a Chat

For payment and settlement of North China entrepot trade, adopt "cross-border RMB settlement" or SWIFT-compliant US dollar settlement, avoid using offshore accounts for illegal payment and collection. If RMB settlement is adopted, conduct transactions through CIPS system to ensure the consistency of capital flow, goods flow and document flow.

When making payment or collection, note "entrepot trade payment" in the bank remark, and provide materials such as entrepot trade contract, invoice and logistics certificate, to avoid the bank judging the transaction as suspicious and freezing the account. Lock the exchange rate in advance during settlement to avoid losses caused by exchange rate fluctuations.

If collection delay occurs, immediately communicate with the destination country customer, and at the same time require the transshipment country agent to provide proof of goods shipment, and apply to the bank for delayed settlement. In addition, regularly check the transaction records of offshore accounts to avoid account cancellation by the bank due to abnormal transactions.

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

International Logistics & Supply Chain ManagerStart a Chat

The North China entrepot trade contract shall clearly define the responsibilities of the transshipment country agent, especially the cargo damage compensation responsibility and document authenticity guarantee responsibility during container swapping. Add "force majeure clause" to the contract, covering delays caused by epidemics, strikes and other force majeure at the transshipment port, and clearly define the division of responsibilities between the two parties. If letter of credit settlement is adopted, avoid soft clauses, such as uncontrollable clauses like "requirement to provide non-objection certificate issued by destination country customs".

Transfer of cargo title shall be completed through bill of lading endorsement, do not transfer cargo title only by oral agreement. In addition, purchase full-range cargo insurance for goods, the insurance coverage covers all risks from domestic departure port, transshipment port to destination port, including cargo damage, port detention, customs detention, etc. If cargo damage occurs, submit insurance claim application within 72 hours, and retain all evidence materials including photos, videos, inspection reports, etc.

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

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

For supply chain planning of North China entrepot trade, establish a "dual transshipment port" strategy, lock routes from Tianjin/Qingdao to Busan and Singapore at the same time as alternative transshipment ports, to avoid overall supply chain interruption caused by delay of a single transshipment port. Adopt the "full cost model" for cost accounting, which includes costs of all links such as domestic customs declaration fee, logistics fee, container swapping fee at transshipment port, warehousing fee, destination customs clearance fee, etc., to avoid missing hidden costs.

In terms of inventory linkage, separate the cargo inventory of entrepot trade from domestic production inventory, establish an independent inventory account to ensure accurate inventory data. Prioritize "FOB Domestic Departure Port" as the trade term, transfer the risks of transshipment port and destination port to the transshipment country agent to reduce your own risk. In addition, regularly evaluate the cost-effectiveness of entrepot trade, if the anti-dumping duty rate decreases, consider direct export to avoid the extra cost of entrepot trade.

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