---
title: "What documents are required for import customs clearance of transit trade and key compliance operation points?"
description: "Enterprises engaged in transit trade often face risks of port detention and cargo seizure due to incomplete documents and process connection errors，and even incur high container detention fees. To address this pain point，full-link control shall be carried out from pre-document review，core node connection，abnormal plan formulation and other aspects. By verifying the authenticity of transit place documents，matching manifest information，and launching emergency document supplement mechanism，the comp..."
url: "https://www.sh-zhongshen.com/en/qa/transit-trade-import-customs-documents-compliance-requirements.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-10-23"
dateModified: "2026-10-23"
brand: "Zhongshen Trading China"
answerCount: 10
---

# What documents are required for import customs clearance of transit trade and key compliance operation points?

## Question

 I am the person in charge of a foreign trade enterprise engaged in import of chemical products via Southeast Asia transit. Last month, a batch of PE plastics transited from Malaysia via Singapore was detained at Shanghai Yangshan Port due to non-compliant certificate of origin from the transit place, which cost more than 120,000 yuan in container detention fees and document modification fees to resolve. Now there is another batch of polypropylene on the same route to be imported, and I am very worried about repeating the same mistake! I want to know what core documents should be prepared in advance for import customs clearance of transit trade? How to verify the authenticity of documents from the transit place? Is there a quick solution plan if we encounter abnormal situations such as cargo seizure and port detention again? In addition, we used to entrust freight forwarders to handle the process, but this time we want to control the core process by ourselves to avoid pitfalls again. Please tell me the specific operation details and compliance points clearly! 

## Answers
                            
### Answer 1 — Best Answer

The first part is **pre-document review details**: three types of core documents shall be verified 3-5 days in advance. The first is the transit bill of lading (transit place，name and voyage of the first/second leg vessel shall be clearly marked). The second is the official non-processing certificate issued by the competent authority of the transit place. The third is the certificate of origin from the country of origin. It is necessary to ensure that the cargo ownership information，cargo description and weight of all documents are completely consistent，so as to avoid the core violation of "document-cargo inconsistency".

For core node connection: 24 hours before the arrival of the goods，the transit trade declaration form shall be submitted to the customs，the above documents shall be uploaded simultaneously，the supervision mode code of "transit trade" (0130) shall be highlighted，and the freight forwarder shall be coordinated to complete the pre-entry of manifest information，so as to ensure real-time matching between manifest and declaration information and avoid port detention caused by information lag.

Abnormal plans shall be formulated in advance: if the customs questions the authenticity of transit，warehousing records of the transit place and logistics track screenshots (including GPS positioning) shall be provided immediately，if there are document defects，the **pre-audit spare document** mechanism can be activated (official contact information of the transit authority shall be kept in advance for supplementary certificate issuance at any time).

Final compliance implementation: after the goods are released，all documents shall be kept for no less than 5 years，and compliance filing for foreign exchange receipt and payment shall be completed simultaneously to ensure consistency of "cargo，document，fund" three flows，which meets the supervision requirements of the State Administration of Foreign Exchange.

**status:** accepted
**Author:** Eric Zhou
**Date:** 2026-10-23

### Answer 2

During import customs clearance of transit trade, the customs valuation link shall focus on the rationality of the transaction price on the first leg bill of lading, warehousing fee and freight at the transit place. If the first leg price is obviously lower than the同期 market price of the same category, the customs will launch the valuation inquiry procedure, and supporting materials such as the first leg procurement contract and transit place logistics bill shall be provided.

If there is a declaration error requiring document deletion and re-declaration, the application shall be submitted within 72 hours after the arrival of the goods, otherwise the port detention warning will be triggered; when deleting and re-declaring, the supervision mode code (0130) shall be marked accurately to avoid classification inconsistency caused by code error, which will lead to cargo seizure risk. At the same time, it shall be noted that transit trade goods shall not be subject to substantial processing at the transit place, otherwise they will be recognized as general trade imports, and high tariffs shall be paid retroactively.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-23

### Answer 3

For the logistics path of transit trade import, ports with direct transit services shall be preferred to avoid cargo ownership risks caused by multiple transits. The first leg bill of lading shall be "order bill of lading", and endorsement transfer shall be completed at the transit place to ensure smooth transfer of cargo ownership from the supplier to the importer.

After the arrival of the goods, an application for extending the free storage period (up to 14 days) shall be submitted to the shipping company in advance to avoid container detention fees caused by delayed document review; in case of container rolling, immediately coordinate the transit freight forwarder to replace the second leg vessel, and update the manifest information to the customs simultaneously to ensure that the declaration information is consistent with the actual logistics track. In addition, a third-party warehousing institution shall be entrusted to supervise cargo ownership at the transit place to avoid unauthorized sale of goods by the supplier.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-10-23

### Answer 4

During import customs clearance of transit trade, enterprises can apply for the value-added tax deferred payment policy, which does not require payment of import value-added tax when goods are released, and declaration and payment can be made after goods are sold, effectively easing the capital pressure of enterprises. It should be noted that three conditions must be met to apply for VAT deferral: first, the enterprise has general taxpayer qualification; second, the final seller of the transit goods is a domestic enterprise; third, complete transit documents (including first/second leg bills of lading, transit place certificates) are retained.

At the same time, avoid confusing transit trade with general trade. If it is recognized as general trade, import value-added tax and late fees shall be paid retroactively; in addition, the overall tax cost can be reduced by optimizing the tax structure of the transit place and making use of the low tax rate policy of the transit place.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-23

### Answer 5

Foreign exchange receipt and payment for transit trade shall be made via RMB cross-border payment through the CIPS system to ensure that the capital flow is consistent with the cargo flow. SWIFT messages shall be clearly marked with the "transit trade" transaction code (121010), and documents such as transit bill of lading and transit place certificate shall be uploaded to the cross-border financial blockchain platform of the State Administration of Foreign Exchange simultaneously to complete compliance filing of foreign exchange receipt and payment.

In case of capital return, an explanation shall be submitted to the State Administration of Foreign Exchange within 3 working days to avoid being included in the watch list; in addition, avoid using offshore accounts for foreign exchange receipt and payment of transit trade, otherwise it will trigger foreign exchange supervision warning and affect subsequent cross-border payment authority.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-23

### Answer 6

For transit trade import, the cargo ownership transfer clause for the transit place shall be clearly specified in the procurement contract to avoid the risk of unauthorized transfer of cargo ownership due to collusion between the supplier and the transit freight forwarder. If letter of credit settlement is adopted, the L/C terms shall be strictly reviewed to avoid soft clauses such as "the non-processing certificate of the transit place shall be confirmed by the issuing bank", otherwise it will lead to unsuccessful foreign exchange settlement.

In addition, force majeure clauses shall be agreed in the contract to clarify the division of port detention liability caused by force majeure factors such as port congestion and epidemic situation in the transit place, so as to avoid legal disputes caused by unclear responsibility; at the same time, background investigation shall be carried out on the qualification of the transit freight forwarder to ensure that it has legal international freight forwarding qualification.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-10-23

### Answer 7

After the arrival of transit trade goods, the authenticity of container seals shall be verified emphatically during on-site customs inspection, which shall be completely consistent with the seal number on the bill of lading. If the seal is damaged or the number is inconsistent, an application for appraisal by a third-party institution shall be submitted immediately.

In case of unpacking inspection, prepare goods samples and MSDS report (for dangerous goods) in advance, and cooperate with customs officers to verify the packaging, weight, cargo description and other information of the goods to avoid cargo seizure caused by document-cargo inconsistency. In addition, it shall be noted that the packaging of transit goods shall not be marked with origin information other than the country of origin, otherwise it will be recognized as false transit and face high fines; if the goods are chemical products, submit the inspection application to the customs in advance to avoid port detention caused by failure to conduct inspection.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-23

### Answer 8

For import customs clearance of chemical products in transit trade, dangerous goods packaging conforming to UN standards shall be adopted. The packaging shall be marked with correct UN number, dangerous goods logo and other information, and the MSDS report issued by an authoritative institution shall be provided simultaneously to ensure that the cargo classification and transportation conditions in the report are consistent with the actual situation.

If the goods are hygroscopic chemical products such as polypropylene, moisture-proof reinforced packaging shall be adopted, desiccants shall be placed in the container and moisture-proof film shall be laid to avoid moisture damage to the goods, which will lead to unqualified judgment during customs inspection. In addition, it shall be noted that the shipping mark information on the packaging shall be completely consistent with the cargo description on the bill of lading and declaration form, so as to avoid document-cargo inconsistency caused by inconsistent shipping marks, which will lead to cargo seizure risk.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-10-23

### Answer 9

After the import customs clearance of transit trade, all documents (including transit bill of lading, transit place certificate, foreign exchange receipt and payment vouchers) shall be kept for no less than 5 years to meet the document filing requirements of the tax authority. If the enterprise is also engaged in general trade export, the documents of transit trade and general trade shall be stored separately to avoid export tax rebate review failure caused by confusion.

In addition, it shall be noted that transit trade goods shall not be used for export tax rebate. If transit goods are passed off as general trade exports to apply for tax rebate, it will trigger tax letter investigation and face the risk of tax repayment and fines; at the same time, regular internal audit of transit trade documents shall be carried out to ensure the authenticity and compliance of documents.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-10-23

### Answer 10

For supply chain planning of transit trade import, ports with high transit efficiency (such as Singapore Port, Hong Kong Port) shall be preferred to shorten transit time and reduce logistics costs. A cost actuarial model shall be established, which includes first leg freight, transit place warehousing fee, customs clearance fee and other costs for dynamic calculation, so as to select the transit path with the optimal cost.

In addition, long-term cooperative relations shall be established with transit freight forwarders to obtain more favorable logistics prices, and an inventory linkage strategy shall be established to adjust the import volume of transit goods according to market demand and avoid inventory backlog. It shall be noted that the supply chain structure of transit trade shall meet the supervision requirements of the State Administration of Foreign Exchange and the customs, ensure the consistency of "cargo, document, fund" three flows, and avoid operational risks caused by non-compliant structure.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-23

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