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Why is no formal customs declaration required for transit trade? What is the core compliance basis behind it?
or complex compliance issues.
clearance and fund security.
I am a foreign trade salesman mainly engaged in transit trade in Southeast Asia. Last week, I just received a natural rubber order for transit from Malaysia to the EU. The goods have arrived at the transit warehouse in Shanghai Yangshan Port.
I stayed up all night to sort out the entire set of customs declaration documents and prepared to submit them, but the cooperating freight forwarder suddenly said that no customs declaration is required for transit trade. I was panicked immediately — this completely contradicts the import and export process training I received before. Now I refresh the logistics page more than a dozen times every day, for fear of missing any step and triggering customs detention.
I will not only have to pay a penalty of nearly 10% to the client, but also affect the company's customs credit rating, making it difficult to obtain transit shipping space in the future. I really can't figure out why no customs declaration is required for transit trade? Is it applicable to all transit scenarios? Are there any hidden compliance boundaries I haven't noticed?
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
First，we need to expose a common industry misunderstanding: transit trade does not mean "completely free of any customs procedures". Many practitioners mistakenly think that no customs declaration means no interaction with the customs at all，which is a typical cognitive bias.
If you operate according to this misunderstanding and fail to submit the transit manifest filing to the customs，the goods will be judged as "suspected smuggling goods" after entering the domestic transit port，triggering a chain reaction including cargo detention and doubled demurrage fees at 1,200 yuan per container per day. In severe cases，the company's customs credit rating will be downgraded，and it will not be able to enjoy the priority arrangement policy for transit shipping space for 1 to 3 years.
The core of physical risk isolation is to ensure that the goods are always in the customs-supervised bonded transit area and do not enter the domestic circulation market — this is the core prerequisite for transit trade to skip import and export customs declaration. The goods only complete manifest switching and vessel connection at the transit port，and there is no domestic ownership transfer or actual delivery.
Exclusive Risk Mitigation Tips: Submit the Transit Trade Confirmation Letter to the customs of the transit port 3 working days in advance，keep the full through bill of lading，transit sales and purchase contract，and goods certificate of origin throughout the process，and synchronize the transit vessel dynamics to the customs supervision department every 5 days to avoid abnormal inspection due to information lag.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
The core basis for transit trade to skip import and export customs declaration is the clause on "transit goods bonded supervision" in the Customs Bonded Supervision Measures. Since the goods only stay in the bonded area of the domestic transit port and do not enter the domestic sales link, there is no need to declare core customs declaration elements such as import and export tariff codes and dutiable value to the customs, but the Transit Goods Manifest Filing Form must be submitted, indicating the port of departure, port of destination, transit contract number and other information of the goods.
If the filing form is not submitted, the customs system will automatically trigger a "goods abnormal warning". Afterwards, a deposit equivalent to 3 times the cargo value must be submitted to apply for cargo release, and the deposit can only be refunded after providing the destination port customs clearance certificate after the transit is completed. The entire process will take at least 15 working days.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
The core of the operation of transit trade skipping customs declaration is to ensure that the ownership of the goods has not been transferred within the territory throughout the process. The connection between the goods from the inbound transit port to the outbound vessel must be completed within the bonded logistics center.
It is strictly forbidden to tow the goods to non-bonded areas for unpacking or repackaging. If repackaging is required due to special circumstances, a bonded packaging operation permit must be applied to the logistics park in advance, otherwise it will be regarded as "domestic goods processing" and trigger the requirements of supplementary customs declaration and tariff payment.
In addition, the vessel space for transit must be confirmed 72 hours in advance to avoid the goods staying in the bonded area for an overdue period due to container being skipped. Overdue storage for more than 10 days will result in a bonded storage surcharge of 800 yuan per container per day being charged by the customs.
Michael ZhangYears of service：6Customer Rating：5.0
Customs Declaration & Compliance ExpertStart a Chat
Transit trade skipping customs declaration directly affects the tax treatment logic. Since the goods do not enter the domestic circulation, there is no need to pay import tariffs, value-added tax and consumption tax, and the export tax rebate policy does not apply.
Practitioners should note that the profits from transit trade must be included in the taxable income of corporate income tax, and all documents such as the full bill of lading, transit contract, and payment receipts must be kept as the core basis for tax authority verification. If complete documents are not kept, the tax authorities will judge the transit profits as "unknown domestic income", recover corporate income tax at a rate of 25%, and impose a late fee of 0.05% per day.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
Under the premise of transit trade skipping customs declaration, the payment and receipt operations must strictly follow the "three flows consistent" principle, that is, the amount of foreign exchange received must be consistent with the cargo value agreed in the transit contract, and the payment object must be the overseas upstream supplier. It is strictly forbidden to use domestic personal accounts for payment and receipt. If the deviation between the received foreign exchange amount and the contract cargo value exceeds 5%, the Transit Trade Payment and Receipt Difference Statement must be submitted to the State Administration of Foreign Exchange in advance. Otherwise, it will be included in the foreign exchange "watch list", and subsequent payment and receipt operations must be reviewed with documents submitted one by one, and the single payment amount shall not exceed 50,000 US dollars.
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
In the operation mode of transit trade skipping customs declaration, the ownership transfer clause must be clearly stipulated in the contract, and it must be stated that "the goods only stay in the bonded area of the domestic transit port, and the ownership is transferred directly from the upstream supplier to the downstream overseas purchaser" to avoid being judged as domestic goods sales due to ambiguous ownership agreement.
In addition, a "transit delay exemption clause" must be added to the contract, clearly stating that no penalty shall be paid to the downstream purchaser if the transit is delayed due to customs supervision reasons. At the same time, the upstream supplier is required to provide the goods certificate of origin to avoid anti-dumping investigations triggered by the destination country's customs due to origin issues.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
The operation mode of transit trade skipping customs declaration can effectively reduce supply chain costs, the core of which is to reduce labor costs, document costs and tariff capital occupation costs of import and export customs declaration, with an average cost reduction of about 1,200 yuan per container. However, the selection of transit ports needs to be planned in advance.
Priority should be given to ports with the "bonded transit integration" qualification, such as Shanghai Yangshan Port and Shenzhen Yantian Port. The transit manifest filing of these ports can be automatically reviewed online, which improves the operation efficiency by about 40%. At the same time, a transit goods inventory early warning mechanism must be established to ensure that the transit stay time does not exceed 14 days, so as to avoid additional bonded storage costs.