--- title: "Are products manufactured by commissioned overseas professional manufacturers and transported back to China classified as imports?" description: "A beauty brand's cushion BB cream manufactured by a commissioned overseas agent is about to enter China. The enterprise is anxious due to a peer's incident where OEM goods were detained by customs，worrying about huge losses caused by failure to declare as imports，including fines，port demurrage and stock out during e-commerce promotion periods. It is clarified that products manufactured by overseas agents and entering China fall into the import category and require compliance declaration. Enterpr..." url: "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html" language: "en" type: "Q&A" category: "Import Agency Q&A" datePublished: "2026-08-11" dateModified: "2026-08-11" brand: "Zhongshen Trading China" answerCount: 9 --- # Are products manufactured by commissioned overseas professional manufacturers and transported back to China classified as imports? ## Question I am the founder of a beauty brand based in Hangzhou. Last year, we signed a contract manufacturing agreement with an OEM in South Korea to produce cushion BB cream under our own brand. Now the first batch of 12,000 finished products is ready for shipment at Incheon Port, and we have booked a fast vessel departing next Wednesday to Shanghai Yangshan Port. Earlier, I heard someone in an industry group say that OEM products are not considered imports and do not need to go through formal customs declaration procedures. But last week, another peer told me that his OEM goods were detained at Ningbo Port for failing to declare as import goods. He not only had to pay a 30% fine, but also missed the e-commerce promotion, suffering a loss of nearly RMB 500,000. I am very anxious now, fearing that my goods will also have problems after arriving at the port, missing the 618 stock preparation deadline, and facing risks of port demurrage and customs detention. I would like to ask for clarification: Are products manufactured by commissioned overseas agents like mine considered imports? What are the differences in determination standards for different situations? Is there a fast and compliant customs clearance solution? ## Answers ### Answer 1 — Best Answer First of all，we need to clarify a common industry misunderstanding: many enterprises mistakenly believe that self-owned brand products manufactured by commissioned overseas agents are "return of self-owned goods" and do not need to be declared in accordance with import procedures. This is a wrong perception that can easily trigger risks. Operating in accordance with this misunderstanding will trigger a chain of negative reactions: goods will be detained by customs after arriving at domestic ports，resulting in daily increasing port demurrage and container detention fees，and facing administrative penalties of 10%-30% of the cargo value. If it coincides with sales nodes such as e-commerce promotions，it will also lead to stock out，directly causing loss of orders and brand reputation. Physical risk isolation measures: Immediately contact the freight forwarder to suspend the shipment of goods (if not yet loaded on board). If the goods have been loaded，prepare a full set of compliant documents as soon as possible to avoid the inability to clear customs after the goods arrive at the port. **Exclusive Loss Mitigation Tips**: For commissioned OEM goods that have been loaded on board，you can entrust a professional foreign trade agency to apply for the **"declaration at local customs，inspection and release at port"** mode. Submit documents such as commissioned processing agreement，brand intellectual property registration certificate and other relevant documents to the local customs of the enterprise in advance to complete the pre-audit on a priority basis. After the goods arrive at the port，they can be cleared directly，which minimizes customs clearance time and reduces the risk of port demurrage. **status:** accepted **Author:** Daniel Xu **Date:** 2026-08-11 ### Answer 2 From the perspective of customs supervision rules, products manufactured by commissioned overseas agents, whether they are self-owned brands or not, fall into the import category as long as the ownership or actual control of the goods is transferred from overseas to domestic, and enter the country through ports other than special customs supervision zones, and need to be declared in accordance with the general trade import process. It should be noted that if goods enter special supervision zones such as bonded zones for reprocessing, they may not be declared as imports temporarily, but import procedures still need to be completed when they enter the domestic market subsequently. When declaring, documents such as commissioned processing agreement, brand authorization letter, product composition test report, etc. shall be provided. If the documents are incomplete, the customs will directly return the declaration, and even initiate the price review dispute procedure, which will prolong the customs clearance time. **status:** suggested **Author:** Linda Gao **Date:** 2026-08-11 ### Answer 3 From the perspective of international logistics routes, the transportation method of products manufactured by commissioned overseas agents transported back to China will directly affect the import classification. If you choose direct shipping to ordinary domestic ports, you need to go through the full process procedures for imported goods, such as bill of lading exchange, inspection declaration and customs declaration. If you choose to ship to Hong Kong for transit first, and then enter the domestic bonded warehouse via cross-border trucks between Hong Kong and Chinese mainland, it may not be regarded as formal import temporarily, and import declaration shall be handled when the goods actually enter the domestic market. It should be noted that when transiting in Hong Kong, it is necessary to ensure that the endorsement of the bill of lading is clear to avoid disputes over cargo ownership. At the same time, a transit buffer time of at least 3 days shall be reserved to prevent delays caused by space shortage at Hong Kong ports, which will affect domestic sales nodes. **status:** suggested **Author:** Andy Guo **Date:** 2026-08-11 ### Answer 4 From the perspective of tax classification, if products manufactured by commissioned overseas agents entering China fall into the import category, they are required to pay import tariffs, value-added tax and consumption tax (if involving taxable consumer goods). If an enterprise regards OEM products as return of self-owned goods and fails to declare, it will face penalties of paying back taxes and late fees, which are calculated at 0.05% per day. At the same time, if the enterprise meets the OEM import policies of the cross-border e-commerce comprehensive pilot zone, it can apply for VAT deferral payment, delaying the payment time of import VAT to after the goods are sold, so as to ease the capital pressure of the enterprise. It should be noted that to apply for VAT deferral, it is necessary to submit materials such as commissioned processing agreement, sales certificate on cross-border e-commerce platforms and other materials to the tax authority in advance to ensure qualification compliance. **status:** suggested **Author:** Cindy Chen **Date:** 2026-08-11 ### Answer 5 From the perspective of foreign exchange receipt and payment compliance, if products manufactured by commissioned overseas agents are classified as imports, enterprises shall pay processing fees and raw material fees to overseas OEMs through formal cross-border payment channels, and truthfully declare the transaction nature as "payment under processing trade" in the monitoring system of the State Administration of Foreign Exchange. If foreign exchange is received and paid not in accordance with the import classification, it will be listed as an abnormal transaction by the State Administration of Foreign Exchange, affecting the subsequent cross-border foreign exchange receipt and payment quota of the enterprise, and even triggering foreign exchange inspection. It should be noted that if an enterprise uses an offshore account to pay processing fees, it shall ensure that the transaction flow is clear and traceable, to avoid being identified as illegal fund transfer. **status:** suggested **Author:** Eric Zhou **Date:** 2026-08-11 ### Answer 6 From the legal perspective, whether products manufactured by commissioned overseas agents entering China belong to imports shall be determined according to the ownership clauses in the commissioned processing agreement. If the agreement stipulates that the ownership of the products belongs to the domestic entrusting party after production is completed, and the entrusting party bears the risk of cargo damage during transportation, the goods shall be declared as imports when entering the country. If the agreement stipulates that the ownership of the products is transferred only after the domestic entrusting party actually signs for the goods, the goods can be regarded as "temporary storage goods" when entering the country, but still need to go through temporary entry procedures with the customs. It should be noted that the ownership of intellectual property rights shall be clearly stipulated in the agreement to avoid customs detention of goods due to brand ownership issues. **status:** suggested **Author:** Kevin Lin **Date:** 2026-08-11 ### Answer 7 From the perspective of on-site customs inspection, if products manufactured by commissioned overseas agents are classified as imports, the customs will inspect them in accordance with the inspection standards for imported goods, including checking whether the brand, specification and composition of the products are consistent with the declaration documents. If the declaration is found to be inconsistent, the goods will be detained. If the enterprise can provide materials such as commissioned processing agreement, brand intellectual property registration certificate, etc., it can apply for priority inspection to shorten the inspection time. It should be noted that the brand logo and origin shall be clearly marked on the package of the goods, to avoid being identified as counterfeit and shoddy products due to unclear origin marking, resulting in confiscation of the goods. **status:** suggested **Author:** Grace Wang **Date:** 2026-08-11 ### Answer 8 From the perspective of export tax rebate, if the domestic entrusting party exports its own raw materials to overseas OEMs for processing, and then transports the finished products back to China, it falls into the category of processing trade with imported materials, and can apply for export tax rebate in accordance with relevant policies for re-export of processing with imported materials. However, it should be noted that for the export of raw materials under processing trade with imported materials, export declaration procedures shall be completed, and the finished products shall be transported back to China within the specified time limit. If the specified time limit is exceeded, the export tax rebate policy cannot be enjoyed, and the tax refunded when the raw materials are exported shall also be repaid. In addition, enterprises shall properly keep documents such as processing with imported materials manual, export declaration form, import declaration form, etc. for the audit of tax authorities. **status:** suggested **Author:** Michael Zhang **Date:** 2026-08-11 ### Answer 9 From the perspective of supply chain planning, whether products manufactured by commissioned overseas agents are operated as imports shall be decided in combination with the overall supply chain layout of the enterprise. If the target market of the enterprise is mainly domestic, and the transportation cost of OEM products is high, it can be considered to transfer the OEM production capacity to the domestic bonded zone, so that the goods do not need to be declared as imports, and can be processed and stored directly in the bonded zone, reducing import tariffs and logistics costs. If the target market of the enterprise covers both domestic and overseas markets, the mode of "overseas OEM + bonded zone transit" can be adopted to flexibly adjust the flow of goods, which not only meets the needs of the domestic market, but also quickly exports goods to overseas markets, improving the flexibility of the supply chain. **status:** suggested **Author:** Victor Sun **Date:** 2026-08-11 ## Related Categories - [Export Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-agency/) - [Export Tax Rebate Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-tax-rebate/) - [Customs Declaration Q&A](https://www.sh-zhongshen.com/en/qa/cat-customs-declaration/) - [Freight Forwarding Q&A](https://www.sh-zhongshen.com/en/qa/cat-freight-forwarding/) - [Forex Settlement Q&A](https://www.sh-zhongshen.com/en/qa/cat-forex-settlement/) - [Entrepôt Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-entrepot-trade/) - [General Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-general-trade/) ## Related Resources - [Trade Services](https://www.sh-zhongshen.com/en/services/) - [Trade Cases](https://www.sh-zhongshen.com/en/cases/) - [Trade Wiki](https://www.sh-zhongshen.com/en/wiki/) - [Trade Class](https://www.sh-zhongshen.com/en/guide/) - [Global Trade Services](https://www.sh-zhongshen.com/en/country/) ## Structured Data ```json [ { "@context": "https://schema.org", "@type": "QAPage", "inLanguage":"en", "isPartOf": { "@id":"https://www.sh-zhongshen.com/en/#website" }, "publisher":{ "@id":"https://www.sh-zhongshen.com/en/#organization" }, "mainEntity": { "@type": "Question", "name": "Are products manufactured by commissioned overseas professional manufacturers and transported back to China classified as imports?", "text": "I am the founder of a beauty brand based in Hangzhou. Last year, we signed a contract manufacturing agreement with an OEM in South Korea to produce cushion BB cream under our own brand. Now the first batch of 12,000 finished products is ready for shipment at Incheon Port, and we have booked a fast vessel departing next Wednesday to Shanghai Yangshan Port. Earlier, I heard someone in an industry group say that OEM products are not considered imports and do not need to go through formal customs declaration procedures. But last week, another peer told me that his OEM goods were detained at Ningbo Port for failing to declare as import goods. He not only had to pay a 30% fine, but also missed the e-commerce promotion, suffering a loss of nearly RMB 500,000. I am very anxious now, fearing that my goods will also have problems after arriving at the port, missing the 618 stock preparation deadline, and facing risks of port demurrage and customs detention. I would like to ask for clarification: Are products manufactured by commissioned overseas agents like mine considered imports? What are the differences in determination standards for different situations? Is there a fast and compliant customs clearance solution?", "answerCount": 9, "upvoteCount": 6, "datePublished": "2026-08-11T12:54:13Z", "dateModified": "2026-08-11T12:54:55Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "First of all，we need to clarify a common industry misunderstanding: many enterprises mistakenly believe that self-owned brand products manufactured by commissioned overseas agents are "return of self-owned goods" and do not need to be declared in accordance with import procedures. This is a wrong perception that can easily trigger risks. Operating in accordance with this misunderstanding will trigger a chain of negative reactions: goods will be detained by customs after arriving at domestic ports，resulting in daily increasing port demurrage and container detention fees，and facing administrative penalties of 10%-30% of the cargo value. If it coincides with sales nodes such as e-commerce promotions，it will also lead to stock out，directly causing loss of orders and brand reputation. Physical risk isolation measures: Immediately contact the freight forwarder to suspend the shipment of goods (if not yet loaded on board). If the goods have been loaded，prepare a full set of compliant documents as soon as possible to avoid the inability to clear customs after the goods arrive at the port. Exclusive Loss Mitigation Tips : For commissioned OEM goods that have been loaded on board，you can entrust a professional foreign trade agency to apply for the "declaration at local customs，inspection and release at port" mode. Submit documents such as commissioned processing agreement，brand intellectual property registration certificate and other relevant documents to the local customs of the enterprise in advance to complete the pre-audit on a priority basis. After the goods arrive at the port，they can be cleared directly，which minimizes customs clearance time and reduces the risk of port demurrage.", "upvoteCount": 6, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#acceptedAnswer", "datePublished": "2026-08-11T13:22:25Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "From the perspective of customs supervision rules, products manufactured by commissioned overseas agents, whether they are self-owned brands or not, fall into the import category as long as the ownership or actual control of the goods is transferred from overseas to domestic, and enter the country through ports other than special customs supervision zones, and need to be declared in accordance with the general trade import process. It should be noted that if goods enter special supervision zones such as bonded zones for reprocessing, they may not be declared as imports temporarily, but import procedures still need to be completed when they enter the domestic market subsequently. When declaring, documents such as commissioned processing agreement, brand authorization letter, product composition test report, etc. shall be provided. If the documents are incomplete, the customs will directly return the declaration, and even initiate the price review dispute procedure, which will prolong the customs clearance time.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-2", "datePublished": "2026-08-11T13:19:05Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "From the perspective of international logistics routes, the transportation method of products manufactured by commissioned overseas agents transported back to China will directly affect the import classification. If you choose direct shipping to ordinary domestic ports, you need to go through the full process procedures for imported goods, such as bill of lading exchange, inspection declaration and customs declaration. If you choose to ship to Hong Kong for transit first, and then enter the domestic bonded warehouse via cross-border trucks between Hong Kong and Chinese mainland, it may not be regarded as formal import temporarily, and import declaration shall be handled when the goods actually enter the domestic market. It should be noted that when transiting in Hong Kong, it is necessary to ensure that the endorsement of the bill of lading is clear to avoid disputes over cargo ownership. At the same time, a transit buffer time of at least 3 days shall be reserved to prevent delays caused by space shortage at Hong Kong ports, which will affect domestic sales nodes.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-3", "datePublished": "2026-08-11T13:17:40Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "From the perspective of tax classification, if products manufactured by commissioned overseas agents entering China fall into the import category, they are required to pay import tariffs, value-added tax and consumption tax (if involving taxable consumer goods). If an enterprise regards OEM products as return of self-owned goods and fails to declare, it will face penalties of paying back taxes and late fees, which are calculated at 0.05% per day. At the same time, if the enterprise meets the OEM import policies of the cross-border e-commerce comprehensive pilot zone, it can apply for VAT deferral payment, delaying the payment time of import VAT to after the goods are sold, so as to ease the capital pressure of the enterprise. It should be noted that to apply for VAT deferral, it is necessary to submit materials such as commissioned processing agreement, sales certificate on cross-border e-commerce platforms and other materials to the tax authority in advance to ensure qualification compliance.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-4", "datePublished": "2026-08-11T13:17:19Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "From the perspective of foreign exchange receipt and payment compliance, if products manufactured by commissioned overseas agents are classified as imports, enterprises shall pay processing fees and raw material fees to overseas OEMs through formal cross-border payment channels, and truthfully declare the transaction nature as "payment under processing trade" in the monitoring system of the State Administration of Foreign Exchange. If foreign exchange is received and paid not in accordance with the import classification, it will be listed as an abnormal transaction by the State Administration of Foreign Exchange, affecting the subsequent cross-border foreign exchange receipt and payment quota of the enterprise, and even triggering foreign exchange inspection. It should be noted that if an enterprise uses an offshore account to pay processing fees, it shall ensure that the transaction flow is clear and traceable, to avoid being identified as illegal fund transfer.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-5", "datePublished": "2026-08-11T13:16:25Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } , { "@type": "Answer", "text": "From the legal perspective, whether products manufactured by commissioned overseas agents entering China belong to imports shall be determined according to the ownership clauses in the commissioned processing agreement. If the agreement stipulates that the ownership of the products belongs to the domestic entrusting party after production is completed, and the entrusting party bears the risk of cargo damage during transportation, the goods shall be declared as imports when entering the country. If the agreement stipulates that the ownership of the products is transferred only after the domestic entrusting party actually signs for the goods, the goods can be regarded as "temporary storage goods" when entering the country, but still need to go through temporary entry procedures with the customs. It should be noted that the ownership of intellectual property rights shall be clearly stipulated in the agreement to avoid customs detention of goods due to brand ownership issues.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-6", "datePublished": "2026-08-11T13:01:53Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "From the perspective of on-site customs inspection, if products manufactured by commissioned overseas agents are classified as imports, the customs will inspect them in accordance with the inspection standards for imported goods, including checking whether the brand, specification and composition of the products are consistent with the declaration documents. If the declaration is found to be inconsistent, the goods will be detained. If the enterprise can provide materials such as commissioned processing agreement, brand intellectual property registration certificate, etc., it can apply for priority inspection to shorten the inspection time. It should be noted that the brand logo and origin shall be clearly marked on the package of the goods, to avoid being identified as counterfeit and shoddy products due to unclear origin marking, resulting in confiscation of the goods.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-7", "datePublished": "2026-08-11T12:59:03Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } , { "@type": "Answer", "text": "From the perspective of export tax rebate, if the domestic entrusting party exports its own raw materials to overseas OEMs for processing, and then transports the finished products back to China, it falls into the category of processing trade with imported materials, and can apply for export tax rebate in accordance with relevant policies for re-export of processing with imported materials. However, it should be noted that for the export of raw materials under processing trade with imported materials, export declaration procedures shall be completed, and the finished products shall be transported back to China within the specified time limit. If the specified time limit is exceeded, the export tax rebate policy cannot be enjoyed, and the tax refunded when the raw materials are exported shall also be repaid. In addition, enterprises shall properly keep documents such as processing with imported materials manual, export declaration form, import declaration form, etc. for the audit of tax authorities.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-8", "datePublished": "2026-08-11T12:57:07Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "From the perspective of supply chain planning, whether products manufactured by commissioned overseas agents are operated as imports shall be decided in combination with the overall supply chain layout of the enterprise. If the target market of the enterprise is mainly domestic, and the transportation cost of OEM products is high, it can be considered to transfer the OEM production capacity to the domestic bonded zone, so that the goods do not need to be declared as imports, and can be processed and stored directly in the bonded zone, reducing import tariffs and logistics costs. If the target market of the enterprise covers both domestic and overseas markets, the mode of "overseas OEM + bonded zone transit" can be adopted to flexibly adjust the flow of goods, which not only meets the needs of the domestic market, but also quickly exports goods to overseas markets, improving the flexibility of the supply chain.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/overseas-professional-contracted-manufacturing-products-import-categorization-check.html#suggestedAnswer-9", "datePublished": "2026-08-11T12:54:55Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } ] } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ {"@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.sh-zhongshen.com/en/"},{"@type": "ListItem", "position": 2, "name": "Q&A", "item": "https://www.sh-zhongshen.com/en/qa/"},{"@type": "ListItem", "position": 3, "name": "Import Agency Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-import-agency/"} ,{"@type": "ListItem", "position": 4, "name": "Are products manufactured by commissioned overseas professional manufacturers and transported back to China classified as imports?"} ] } ] ```