---
title: "What customs compliance requirements must be met when filling in the core fields of the 2026 Transit Trade Declaration Form?"
description: "Errors in filling the Transit Trade Declaration Form such as field mismatch and inconsistent supporting documents may easily trigger customs valuation queries or foreign exchange control early warnings. After the tightening of 2026 new regulations，the cost of violations has increased sharply. You need to first complete cross-audit of pre-submission supporting documents，accurately match the logic of core fields，and develop an abnormal correction plan simultaneously，so as to achieve full-chain com..."
url: "https://www.sh-zhongshen.com/en/qa/transit-trade-declaration-form-core-fields-customs-compliance-2026.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-10-27"
dateModified: "2026-10-27"
brand: "Zhongshen Trading China"
answerCount: 7
---

# What customs compliance requirements must be met when filling in the core fields of the 2026 Transit Trade Declaration Form?

## Question

 I am a foreign trade operator at a Shanghai-based enterprise specializing in Southeast Asia transit business. Last week, I handled a natural rubber order transshipped from Malaysia to Brazil. The Transit Trade Declaration Form I submitted yesterday was rejected by customs with the comment "inconsistent ownership transfer logic". The goods have now arrived at the transit port in Singapore, with only 3 days left before transshipment, and I am too anxious to eat. I used to fill out the declaration form based on past experience, but the 2026 new customs regulations have just been tightened. Now I even do not know which core fields of the declaration form need to be strictly matched with the bill of lading, manifest and certificate of origin. I am even more worried that if I make mistakes again, not only will the goods be detained at the port and incur high costs, but the foreign exchange administration will also block my subsequent foreign exchange payment process due to compliance issues. Can you help me sort out the compliant filling requirements? 

## Answers
                            
### Answer 1 — Best Answer

First complete **cross-audit of pre-submission supporting documents**: You need to compare the core information of the bill of lading，manifest，certificate of origin and transit trade contract one by one，focusing on verifying the "ownership transfer node" (must be completely consistent with the date recorded in the transit port warehouse receipt)，"goods description" (must accurately match the product name corresponding to the HS code)，and "circulation path" (must clearly indicate the customs codes of the port of origin，transit port and port of destination). The 2026 new customs regulations require that all transit trade businesses must upload a copy of the transit port warehouse receipt to the exclusive module of the "Single Window"，and no document can be omitted.

Next is **connection of core nodes**: When filling out the declaration form，you need to ensure that the "foreign exchange receipt/payment account" is consistent with the exclusive account agreed in the transit trade contract，the "trade mode code" must select "1210 (Transit Trade)"，and it is strictly forbidden to misuse "1010 (General Trade)". At the same time，clearly mark the NVOCC qualification number of the transit freight forwarder in the "Remarks" column to avoid foreign exchange control early warnings caused by code mismatch.

Then comes **abnormal response plan**: If the declaration form is rejected，you need to contact the transit port freight forwarder within 24 hours to obtain the latest warehouse receipt record，and submit a "supplementary explanation of ownership transfer" to the customs simultaneously，if the time before transshipment is less than 48 hours，you can apply for **emergency compliance filing**，and complete the declaration first with the transshipment letter of guarantee issued by the freight forwarder.

Final compliance implementation: After submitting the declaration form，all supporting documents shall be sorted and retained for no less than 5 years to meet the document management requirements of 2026 customs post-audit，and avoid compliance risks caused by missing documents.

**status:** accepted
**Author:** Michael Zhang
**Date:** 2026-10-28

### Answer 2

The filling of the Transit Trade Declaration Form shall strictly comply with the requirements of Announcement No. 12 of the General Administration of Customs 2026, with the core requirement of "closed-loop logic of ownership transfer". If the issuance date of the transit port warehouse receipt is not indicated in the "ownership transfer node" column during declaration, it will trigger the automatic early warning of the customs valuation system, directly leading to the return of the declaration form. Please note that the customs added the "transit trade ownership traceability code" field in 2026. You need to accurately fill in the unique traceability code provided by the transit port freight forwarder. This field is linked with the manifest system in real time.

If it is filled incorrectly, it will be determined as false declaration and trigger customs inspection. In addition, the "goods value" in the declaration form must be completely consistent with the value stated in the transit trade contract and bill of lading. If there is a deviation of more than ±5%, you need to submit a "price difference explanation" with supporting materials, otherwise it will enter the manual review process and delay customs clearance.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-10-28

### Answer 3

The "circulation path" field in the Transit Trade Declaration Form must be completely consistent with the actual logistics path. The 2026 new customs regulations require that the specific wharf code of the transit port must be indicated, instead of only filling in the port name.

If the filled transit port wharf code is inconsistent with the manifest record, the goods will be listed as "abnormal containers" after arriving at the transit port, triggering a second wharf inspection, resulting in additional container detention fees, inspection fees, and even missing the transshipment schedule. In addition, the "freight forwarder qualification" field in the declaration form needs to be filled with the NVOCC qualification number of the transit port freight forwarder.

The 2026 new regulations require that transit trade businesses must be operated by freight forwarders with transit qualification. If you fill in the number of an unqualified freight forwarder, it will be determined that the logistics path is non-compliant, and the goods will be detained at the transit port until compliant materials are supplemented.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-10-28

### Answer 4

The "tax treatment method" field in the 2026 Transit Trade Declaration Form shall be accurately selected according to the attributes of goods circulation. If the goods do not enter the Chinese customs territory, you need to select "no taxation for overseas circulation".

If you mistakenly select "domestic taxation", it will trigger automatic tax calculation by the tax system, resulting in unnecessary value-added tax prepayment costs. In addition, the "foreign exchange receipt/payment amount" in the declaration form must be completely consistent with the gross profit amount in the transit trade contract.

If there is a cross-border related party transaction, you need to submit a "related party transaction pricing explanation" that meets relevant BEPS requirements, otherwise it will be listed as a key inspection object by the tax authority, and you will be required to pay overdue taxes and late fees. Please note that the tax filing of transit trade must be completed simultaneously with the declaration form. If the filing time is later than the declaration time, it will be determined as a tax violation.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-10-28

### Answer 5

The "foreign exchange receipt and payment account" field in the 2026 Transit Trade Declaration Form shall select the special transit trade account filed with the foreign exchange administration. If you use a general trade account for foreign exchange receipt and payment, it will trigger the automatic early warning of the foreign exchange control system, leading to the freezing of foreign exchange payment. In addition, the "SWIFT message number" in the declaration form must be completely consistent with the message number of the actual foreign exchange receipt and payment. The 2026 foreign exchange administration requires that the "exclusive transit trade mark" be marked in the message for foreign exchange receipt and payment of transit trade.

If it is not marked, it will be regarded as abnormal foreign exchange receipt and payment, and enter the manual review process of the foreign exchange administration, delaying the time of fund arrival. Please note that the time difference between foreign exchange receipt and payment for transit trade shall be controlled within 90 days. If it exceeds 90 days, you need to submit a "foreign exchange receipt and payment extension explanation" with supporting materials, otherwise it will be listed as a foreign exchange violation.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-27

### Answer 6

The "ownership transfer certificate" field in the Transit Trade Declaration Form shall be attached with a copy of the ownership transfer clause in the transit trade contract. The 2026 customs regulations require that the ownership transfer must be completed at the transit port.

If the ownership transfer node agreed in the contract is within the Chinese territory, it will be determined as false transit trade and trigger customs legal inspection. In addition, the "force majeure clause" field in the declaration form shall be filled with the number of the force majeure clause in the transit trade contract.

If the goods encounter a force majeure event at the transit port, you can apply for extended customs declaration with this number to avoid risks such as port detention fees and cargo seizure. Please note that the ownership transfer clause in the transit trade contract must be clear and definite. If there is ambiguous expression, it will be regarded as inconsistent ownership transfer logic by the customs, and the declaration form will be directly returned.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-27

### Answer 7

The "tax refund qualification" field in the 2026 Transit Trade Declaration Form shall select "no tax refund qualification", because transit trade goods do not enter the Chinese customs territory and are not eligible for export tax refund. If you mistakenly select "qualified for tax refund", it will trigger the automatic early warning of the tax refund system, leading to the rejection of the tax refund declaration, and even be listed as a tax refund violation, affecting the subsequent general trade tax refund qualification. In addition, the "document retention period" field in the declaration form shall be filled with "5 years", which meets the 2026 requirements of the State Taxation Administration for the retention of tax refund documents.

If the retention period is less than 5 years, it will be listed as a key inspection object by the tax authority, and you will be required to repay the refunded taxes and pay late fees. Please note that transit trade documents must be stored separately from general trade documents. If they are mixed, it will be regarded as non-compliant document management and trigger tax inspection.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-27

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