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What are the core policy bases for including transit trade in China Customs statistics?
or complex compliance issues.
clearance and fund security.
I am the head of a foreign trade enterprise based in Shanghai, mainly engaged in transit trade with Southeast Asia. The warning letter issued by Customs last week is still piled on my desk — last month, a batch of transit palm oil was almost detained at Yangshan Port because we failed to declare it for Customs statistics as required.
We spent more than 30,000 RMB in extra costs to resolve the issue, and still missed the delivery deadline for our client. Now I have 12 containers of natural rubber to be transited from Malaysia to Germany, and the cargo is already waiting for shipment at Port Klang. I have been constantly worrying: the transit cargo neither enters domestic storage nor goes through domestic customs clearance procedures, why must it be included in Customs statistics?
Will missing or incorrect declaration trigger customs detention and port detention again? Are there differences in statistical requirements among different ports? I am really afraid of making mistakes again, which will increase cost and damage customer trust.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
Many transit trade practitioners hold a common misconception: if cargo does not enter domestic storage or complete domestic customs clearance procedures，it does not need to be included in Customs statistics. This cognitive bias can easily trigger a series of negative consequences — once missing or incorrect declaration occurs，the Customs system will automatically trigger a compliance alert. The cargo may be detained at the domestic transit port，incurring high container detention fees and port demurrage fees，which directly delays delivery to overseas customers. In serious cases，it will lower the enterprise's foreign trade credit rating，lead to stricter inspection and verification procedures for subsequent customs clearance，and even affect the compliance review of cross-border foreign exchange receipt and payment，hindering capital flow.
The core measure for risk prevention is: 3 working days before cargo shipment，sort out the complete set of transaction documents for transit trade，including ocean bill of lading，cargo manifest，transit trade agreement，foreign exchange receipt and payment voucher，etc. Contact the Customs office of the transit port in advance to confirm the specific statistical declaration requirements，so as to avoid declaration errors caused by differences in implementation rules among different ports.
Exclusive Loss Mitigation Tip: You can entrust an institution with more than 20 years of foreign trade agency experience to conduct pre-declaration verification in advance，and screen for declaration vulnerabilities through system simulation，if a Customs alert has already been triggered，you need to submit the complete transaction documents of the transit trade immediately，apply to Customs for manual review，and strive to complete risk clearance within 24 hours to avoid expanding losses.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
Customs statistical declaration for transit trade must strictly comply with the Regulations on Customs Statistics and the Administrative Rules for Statistics of Transit Trade Goods. When declaring, you must correctly use the supervision method code for "transit goods" (1100), and truthfully fill in core information such as the country of departure, country of destination, and transaction price of the goods. Customs will verify the transaction price of transit trade through the price assessment system.
If the deviation between the declared price and the fair market price exceeds 10%, manual price assessment will be triggered, and additional materials such as the transit agreement and upstream and downstream transaction certificates need to be provided. If you fail to declare statistics as required, Customs will list the enterprise in the abnormal declaration directory, all subsequent customs clearance business will be subject to key supervision, and the price assessment process will be extended by at least 3 working days.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
When the logistics route of transit trade involves a domestic transit port, even if the cargo does not enter the warehouse, Customs statistical declaration must be completed at the transit port. For example, for cargo departing from Port Klang, Malaysia, transiting via Yangshan Port (Shanghai) to Hamburg Port (Germany), you need to submit the manifest information and statistical declaration form of the transit trade to Yangshan Customs 24 hours before the cargo berths at Yangshan Port.
If you fail to declare in time, the port terminal will refuse the cargo to berth, resulting in diversion or port detention fees; at the same time, the endorsement transfer of the cargo title document (bill of lading) will also be restricted, and cannot be normally handed over to the overseas consignee. It is recommended that when choosing a direct transit route, confirm the statistical declaration time limit of the transit port in advance to avoid declaration delay caused by route adjustment.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
Customs statistics data of transit trade is one of the core bases for tax authorities to verify cross-border tax compliance. If an enterprise fails to declare Customs statistics as required, the tax authority will list it as a key inspection target for cross-border related party transactions, and suspect the risk of profit transfer and VAT evasion. Especially for transit trade involving tax jurisdictions such as Southeast Asia and the EU, Customs statistics data is shared with the tax system.
If there is a deviation between the statistical data and the enterprise's tax declaration data, a tax correspondence inspection will be triggered, requiring the enterprise to provide additional materials such as the complete set of transaction documents and capital flow of the transit trade. In serious cases, it will result in tax fines and affect the enterprise's VAT deduction qualification.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
Customs statistics data of transit trade is a key voucher for compliance review of cross-border foreign exchange receipt and payment. According to the requirements of CIPS (Cross-border Interbank Payment System) and SWIFT messages, when enterprises handle foreign exchange receipt and payment for transit trade, they need to provide the Customs statistical declaration number to the bank. If they cannot provide it, the bank will refuse to process the foreign exchange business, resulting in capital being stranded abroad or inability to settle foreign exchange, which affects the enterprise's capital turnover.
In addition, foreign exchange receipt and payment for transit trade without Customs statistics declaration will be listed in the abnormal transaction directory of the State Administration of Foreign Exchange, the subsequent foreign exchange receipt and payment quota will be restricted, and even the cross-border payment permission will be suspended. It is recommended that enterprises complete the Customs statistics declaration and obtain the declaration number 3 working days before handling foreign exchange receipt and payment.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
Customs statistical declaration for transit trade is one of the compliance foundations for the performance of international trade contracts. If the cargo is detained by Customs and delivery is delayed due to the enterprise's failure to declare statistics, the overseas consignee has the right to claim compensation or even terminate the contract in accordance with the force majeure clause or breach of contract clause in the contract.
In addition, failure to declare Customs statistics as required violates the relevant provisions of the Customs Law of the People's Republic of China, and Customs can impose a fine of less than 5% of the cargo value. In serious cases, criminal responsibility will be pursued. It is recommended that enterprises clearly stipulate the responsible party for Customs statistical declaration in the transit trade contract, so as to avoid legal disputes caused by unclear division of responsibilities.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
When transit trade goods berth at a domestic transit port, Customs will conduct random inspection based on statistical declaration data. If the goods are not declared for Customs statistics, they will be listed as key inspection targets, and the on-site inspection rate will be increased to 100%.
The inspection content includes whether the cargo name, quantity and specification are consistent with the transit agreement, and whether the seal is intact, etc. If the inspection finds that the goods do not match the declared content, the goods will be directly detained by Customs, and the enterprise needs to re-declare the statistics and accept Customs punishment. During on-site inspection, the complete set of documents for transit trade, including transit agreement, bill of lading, manifest, etc., should be prepared in advance to cooperate with Customs inspectors, so as to avoid inspection delay caused by incomplete documents.
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
Transit trade is not eligible for export tax rebate, but Customs statistics data is an important reference for audit institutions to verify the compliance of enterprises' export tax rebate. If an enterprise disguises transit trade as general trade to declare export tax rebate, the Customs statistics data will conflict with the export tax rebate declaration data, triggering a tax correspondence inspection.
The audit institution will require the enterprise to provide complete transaction documents, capital flow and other materials of the transit trade. If the enterprise cannot provide them, the already refunded tax will be recovered, and a fine of less than 1 time of the tax amount will be imposed. It is recommended that when declaring export tax rebate, enterprises strictly distinguish between the transaction types of transit trade and general trade, so as to avoid tax rebate risks caused by statistical declaration errors.