--- title: "How Many Bills of Lading Are Required for Compliance With Three-Party Title Transfer in Transit Trade?" description: "Enterprises engaged in outdoor furniture transit trade often face risks such as port detention and customs hold at transshipment ports，and supplementary anti-dumping duty payment during US customs clearance verification，caused by improper matching of the number of bills of lading，especially in scenarios involving multi-port transshipment and letter of credit settlement. It is required to issue 2 bills of lading based on title transfer and compliance requirements，and achieve full-process complian..." url: "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html" language: "en" type: "Q&A" category: "Entrepôt Trade Q&A" datePublished: "2026-10-15" dateModified: "2026-10-15" brand: "Zhongshen Trading China" answerCount: 10 --- # How Many Bills of Lading Are Required for Compliance With Three-Party Title Transfer in Transit Trade? ## Question I am a foreign trade specialist from a Shanghai-based company mainly engaged in outdoor furniture export. I just received a 12-container transit trade order last week: containers are shipped from Dongguan to Port Klang, Malaysia for transshipment, then forwarded to Los Angeles, USA. The purpose is to avoid US anti-dumping duties on Chinese furniture, and the settlement method is irrevocable sight letter of credit. I heard from peers that a company suffered port detention and customs hold at the Malaysian transshipment port due to incorrect number of bills of lading, and was found with inconsistent documents during US customs clearance. They not only paid nearly 100,000 yuan in detention fees but also补缴 23% anti-dumping duty. Now I am very anxious: for this type of transit trade involving three-party title transfer and multi-port transshipment, how many bills of lading are needed to meet the requirements of transshipment port clearance, US customs clearance, and L/C settlement at the same time, and avoid title disputes and compliance risks? ## Answers ### Answer 1 — Best Answer First，complete the pre-document review details: you need to first verify the clear requirements for the number of bills of lading and consignee wording in the terms of the irrevocable sight letter of credit，and confirm the customs transit supervision rules of the transshipment port (Port Klang，Malaysia) -- In 2026，Port Klang requires that transit goods must issue separate first-leg and second-leg bills of lading，and prohibits the use of through bills of lading showing China as the origin. Otherwise，it will be deemed as direct import by US customs and trigger anti-dumping duty verification. Core node connection requires accurate matching: For anti-dumping avoidance transit trade like your case，**2 bills of lading** are required: The consignee of the first-leg bill of lading (Dongguan China - Port Klang Malaysia) shall be the transshipment service provider (or offshore title entity) designated by your company，which is used for transit customs clearance and title transfer at the transshipment port，The consignor of the second-leg bill of lading (Port Klang Malaysia - Los Angeles USA) shall be the transshipment service provider，and the consignee shall be the US buyer (or entity designated by the L/C)，which is used for US customs clearance and L/C presentation. Meanwhile，a transit certificate issued by the transshipment service provider shall be provided together，and submitted to the bank and customs together with the two bills of lading. Contingency plans shall be prepared in advance: If the transshipment port customs requires an additional transit title confirmation bill of lading，you must immediately coordinate with the transshipment service provider to issue a temporary bill of lading marked "no title transfer"，which is only used for regulatory filing at the transshipment port，and shall not be used for presentation or title transfer，If US customs questions the continuity of the bills of lading，you need to prepare the endorsement transfer document of the first-leg bill of lading and the warehousing record of the transshipment port in advance to prove that the goods have not entered the local market of Malaysia. Final compliance implementation requires synchronized completion: Submit the two bills of lading，transit certificate，and other documents required by the L/C to the bank to ensure document consistency，Meanwhile，share the electronic copy of the first-leg bill of lading with the transshipment service provider，complete transit filing at the transshipment port in advance to avoid detention risk. **status:** accepted **Author:** Kevin Lin **Date:** 2026-10-15 ### Answer 2 Regarding customs verification requirements for the number of bills of lading in transit trade, in 2026, China Customs' integrated customs clearance system has realized cross-port joint verification for transit cargo documents. If only one through bill of lading is issued, the system will automatically trigger an alert of "discrepancy between origin and declared transit place", resulting in the goods being detained at the transshipment port, and a transit supervision bond equal to 15% of the cargo value needs to be paid. It is necessary to ensure that the origin of the first-leg bill of lading is China, the origin of the second-leg bill of lading is the transshipment port, the container number and seal number of the two bills of lading are completely consistent, and the consignee of the first-leg bill of lading must be a registered title entity at the transshipment port, and cannot be directly filled as the US buyer. Otherwise, it will be deemed as direct export and trigger anti-dumping duty verification. **status:** suggested **Author:** Victor Sun **Date:** 2026-10-15 ### Answer 3 The number of bills of lading for transit trade needs to match the title control requirements of the transshipment route. If the "direct transshipment" mode is adopted (goods do not enter the transshipment port warehouse and change ships directly), 2 bills of lading are required: The first-leg bill of lading is used for export customs clearance at Chinese ports and ship changing at the transshipment port, and the second-leg bill of lading is used for customs clearance at the destination port; If the "warehousing transshipment" mode is adopted (goods enter the transshipment port warehouse for container reloading), an additional warehousing bill of lading from the transshipment port is required to prove the warehousing and container reloading of the goods at the transshipment port, so as to prevent the destination port customs from deeming the goods as "origin fraud". It should be noted that the container seal number of all bills of lading must be updated to the special seal of the transshipment service provider after container reloading, and the first-leg bill of lading must be blank endorsed to facilitate the transshipment service provider to complete title transfer quickly. **status:** suggested **Author:** Linda Gao **Date:** 2026-10-15 ### Answer 4 The number of bills of lading in transit trade directly affects the compliance of cross-border tax planning. In 2026, OECD's tax rules for transit trade clearly stipulate that if only one through bill of lading is issued, it will be deemed as a "direct cross-border transaction" and cannot enjoy the VAT deferral policy of the transshipment port. A VAT equal to 10% of the cargo value needs to be paid at the transshipment port, and US customs will require supplementary payment of anti-dumping duty (about 22.96% of the cargo value). Two bills of lading are required: The transaction corresponding to the first-leg bill of lading is the title transfer from "China to transshipment port", which can enjoy the VAT deferral policy of the transshipment port; The transaction corresponding to the second-leg bill of lading is the title transfer from "transshipment port to USA", which can be declared according to the origin rules of the transshipment country to avoid US anti-dumping duty. It is necessary to ensure that the transaction amount corresponding to the two bills of lading is consistent with the customs declaration amount, so as to avoid triggering related party transaction verification under BEPS. **status:** suggested **Author:** Cindy Chen **Date:** 2026-10-15 ### Answer 5 The number of bills of lading for transit trade needs to match the compliance requirements of cross-border foreign exchange receipt and payment. In 2026, the State Administration of Foreign Exchange of China requires that for transit trade foreign exchange supervision, bills of lading corresponding to the amount of foreign exchange receipt and payment must be provided. If only one through bill of lading is issued, it will be deemed as "incomplete documents", resulting in delayed posting of foreign exchange, and even being included in the foreign exchange verification blacklist. Two bills of lading are required: The first-leg bill of lading corresponds to the foreign exchange payment from China to the transshipment port (payment to domestic factory), the second-leg bill of lading corresponds to the foreign exchange receipt from USA to China (payment from US buyer), the difference in cargo value between the two bills of lading must be consistent with the profit of the transit trade, and "transit trade first-leg/second-leg bill of lading number" must be indicated in the SWIFT message to facilitate automatic verification by the SAFE system. **status:** suggested **Author:** Lucas Liu **Date:** 2026-10-15 ### Answer 6 The number of bills of lading in transit trade directly affects the legal validity of title transfer. If only one through bill of lading is issued, the title will be directly transferred from the domestic factory to the US buyer, and the transshipment service provider cannot exercise title control. If the buyer refuses to pay under the L/C, there is no way to stop loss by detaining the goods. Two bills of lading are required: The consignee of the first-leg bill of lading is the transshipment service provider, and the title belongs to the transshipment service provider until the transshipment service provider issues the second-leg bill of lading; The consignor of the second-leg bill of lading is the transshipment service provider, and the title is transferred to the US buyer. At the same time, the L/C must clearly require the submission of original and copy of the two bills of lading, and the first-leg bill of lading must be accompanied by the title transfer endorsement document from the transshipment service provider, so as to avoid legal disputes caused by unclear title ownership. **status:** suggested **Author:** Grace Wang **Date:** 2026-10-15 ### Answer 7 The number of bills of lading for transit trade needs to match the on-site inspection requirements of the transshipment port. In 2026, the on-site inspection rules of Port Klang Malaysia clearly stipulate that transit goods must submit two bills of lading (first-leg and second-leg), and inspectors will check whether the container number, seal number and cargo name of the two bills of lading are consistent. If only one through bill of lading is submitted, it will be deemed as "document inconsistency" and trigger devanning inspection. The inspection fee is about 1200 MYR per container, and the detention fee is about 80 MYR per container per day. It is necessary to ensure that the seal number of the first-leg bill of lading is the factory seal from the domestic factory, the seal number of the second-leg bill of lading is the transshipment seal from the transshipment service provider, and the cargo name on the two bills of lading must use the customs code of the transshipment port, so as to avoid triggering origin inspection. **status:** suggested **Author:** Evelyn Li **Date:** 2026-10-15 ### Answer 8 The number of bills of lading for transit trade needs to match the compliance requirements of cargo packaging. If the cargo is outdoor furniture, it may involve IPPC marking for wooden packaging. In 2026, the inspection rate of US Customs for wooden packaging from China is as high as 35%. If only one through bill of lading is issued, the wooden packaging will be deemed as originating from China, triggering fumigation inspection. Two bills of lading are required: The packaging information of the first-leg bill of lading is filled as "wooden packaging with Chinese IPPC marking", which is used for packaging replacement at the transshipment port; The packaging information of the second-leg bill of lading is filled as "wooden packaging with Malaysian IPPC marking", which is used for US customs clearance. It is necessary to ensure that the packaging information on the two bills of lading is consistent with the actual packaging, the first-leg bill of lading is accompanied by the fumigation certificate for the wooden packaging, and the second-leg bill of lading is accompanied by the packaging replacement certificate from the transshipment port, so as to avoid triggering packaging compliance verification. **status:** suggested **Author:** Eric Zhou **Date:** 2026-10-15 ### Answer 9 The number of bills of lading in transit trade directly affects the export tax refund compliance of domestic factories. In 2026, the State Taxation Administration of China clearly stipulates in the export tax refund rules for transit trade that domestic factories can only apply for tax refund for goods exported under the first-leg bill of lading. If only one through bill of lading is issued, it will be deemed as "direct export to USA", cannot enjoy the tax refund preference for transit trade, and even be deemed as "false export" and trigger tax verification. Two bills of lading are required: The consignor of the first-leg bill of lading is the domestic factory, the consignee is the transshipment service provider, which is used for the domestic factory's export tax refund declaration; The consignor of the second-leg bill of lading is the transshipment service provider, the consignee is the US buyer, which is used for settlement of the transit trade. It is necessary to ensure that the cargo value and quantity of the two bills of lading are consistent with the amount on the domestic factory's VAT invoice, meeting the requirement of four-consistency. **status:** suggested **Author:** Jason Wu **Date:** 2026-10-15 ### Answer 10 The number of bills of lading for transit trade needs to match the requirements of supply chain cost control. In 2026, the transshipment cost of transit trade is about 3-5% of the cargo value. If only one through bill of lading is issued, it will lead to a 20% increase in ship changing and warehousing costs at the transshipment port, because through bills of lading cannot enjoy the transit preferential policy of the transshipment port. Two bills of lading are required: The first-leg bill of lading is used to lock the space from China to the transshipment port, and enjoy the space discount for transit goods (15% off the regular space rate); The second-leg bill of lading is used to lock the space from the transshipment port to USA, and enjoy the destination space discount at the transshipment port (10% off the regular space rate). It is necessary to ensure that the interval between space bookings of the two bills of lading does not exceed 48 hours, so as to avoid the increase of warehousing cost at the transshipment port. Meanwhile, the cargo location in the inventory system must be updated synchronously to ensure that the inventory data is consistent with the bills of lading. **status:** suggested **Author:** Andy Guo **Date:** 2026-10-15 ## Related Categories - [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-agency/) - [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/) - [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": "How Many Bills of Lading Are Required for Compliance With Three-Party Title Transfer in Transit Trade?", "text": "I am a foreign trade specialist from a Shanghai-based company mainly engaged in outdoor furniture export. I just received a 12-container transit trade order last week: containers are shipped from Dongguan to Port Klang, Malaysia for transshipment, then forwarded to Los Angeles, USA. The purpose is to avoid US anti-dumping duties on Chinese furniture, and the settlement method is irrevocable sight letter of credit. I heard from peers that a company suffered port detention and customs hold at the Malaysian transshipment port due to incorrect number of bills of lading, and was found with inconsistent documents during US customs clearance. They not only paid nearly 100,000 yuan in detention fees but also补缴 23% anti-dumping duty. Now I am very anxious: for this type of transit trade involving three-party title transfer and multi-port transshipment, how many bills of lading are needed to meet the requirements of transshipment port clearance, US customs clearance, and L/C settlement at the same time, and avoid title disputes and compliance risks?", "answerCount": 10, "upvoteCount": 3, "datePublished": "2026-10-15T11:24:01Z", "dateModified": "2026-10-15T11:31:09Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "First，complete the pre-document review details: you need to first verify the clear requirements for the number of bills of lading and consignee wording in the terms of the irrevocable sight letter of credit，and confirm the customs transit supervision rules of the transshipment port (Port Klang，Malaysia) -- In 2026，Port Klang requires that transit goods must issue separate first-leg and second-leg bills of lading，and prohibits the use of through bills of lading showing China as the origin. Otherwise，it will be deemed as direct import by US customs and trigger anti-dumping duty verification. Core node connection requires accurate matching: For anti-dumping avoidance transit trade like your case， 2 bills of lading are required: The consignee of the first-leg bill of lading (Dongguan China - Port Klang Malaysia) shall be the transshipment service provider (or offshore title entity) designated by your company，which is used for transit customs clearance and title transfer at the transshipment port，The consignor of the second-leg bill of lading (Port Klang Malaysia - Los Angeles USA) shall be the transshipment service provider，and the consignee shall be the US buyer (or entity designated by the L/C)，which is used for US customs clearance and L/C presentation. Meanwhile，a transit certificate issued by the transshipment service provider shall be provided together，and submitted to the bank and customs together with the two bills of lading. Contingency plans shall be prepared in advance: If the transshipment port customs requires an additional transit title confirmation bill of lading，you must immediately coordinate with the transshipment service provider to issue a temporary bill of lading marked "no title transfer"，which is only used for regulatory filing at the transshipment port，and shall not be used for presentation or title transfer，If US customs questions the continuity of the bills of lading，you need to prepare the endorsement transfer document of the first-leg bill of lading and the warehousing record of the transshipment port in advance to prove that the goods have not entered the local market of Malaysia. Final compliance implementation requires synchronized completion: Submit the two bills of lading，transit certificate，and other documents required by the L/C to the bank to ensure document consistency，Meanwhile，share the electronic copy of the first-leg bill of lading with the transshipment service provider，complete transit filing at the transshipment port in advance to avoid detention risk.", "upvoteCount": 3, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#acceptedAnswer", "datePublished": "2026-10-15T13:15:17Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "Regarding customs verification requirements for the number of bills of lading in transit trade, in 2026, China Customs' integrated customs clearance system has realized cross-port joint verification for transit cargo documents. If only one through bill of lading is issued, the system will automatically trigger an alert of "discrepancy between origin and declared transit place", resulting in the goods being detained at the transshipment port, and a transit supervision bond equal to 15% of the cargo value needs to be paid. It is necessary to ensure that the origin of the first-leg bill of lading is China, the origin of the second-leg bill of lading is the transshipment port, the container number and seal number of the two bills of lading are completely consistent, and the consignee of the first-leg bill of lading must be a registered title entity at the transshipment port, and cannot be directly filled as the US buyer. Otherwise, it will be deemed as direct export and trigger anti-dumping duty verification.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-2", "datePublished": "2026-10-15T13:03:34Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } , { "@type": "Answer", "text": "The number of bills of lading for transit trade needs to match the title control requirements of the transshipment route. If the "direct transshipment" mode is adopted (goods do not enter the transshipment port warehouse and change ships directly), 2 bills of lading are required: The first-leg bill of lading is used for export customs clearance at Chinese ports and ship changing at the transshipment port, and the second-leg bill of lading is used for customs clearance at the destination port; If the "warehousing transshipment" mode is adopted (goods enter the transshipment port warehouse for container reloading), an additional warehousing bill of lading from the transshipment port is required to prove the warehousing and container reloading of the goods at the transshipment port, so as to prevent the destination port customs from deeming the goods as "origin fraud". It should be noted that the container seal number of all bills of lading must be updated to the special seal of the transshipment service provider after container reloading, and the first-leg bill of lading must be blank endorsed to facilitate the transshipment service provider to complete title transfer quickly.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-3", "datePublished": "2026-10-15T12:59:16Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "The number of bills of lading in transit trade directly affects the compliance of cross-border tax planning. In 2026, OECD's tax rules for transit trade clearly stipulate that if only one through bill of lading is issued, it will be deemed as a "direct cross-border transaction" and cannot enjoy the VAT deferral policy of the transshipment port. A VAT equal to 10% of the cargo value needs to be paid at the transshipment port, and US customs will require supplementary payment of anti-dumping duty (about 22.96% of the cargo value). Two bills of lading are required: The transaction corresponding to the first-leg bill of lading is the title transfer from "China to transshipment port", which can enjoy the VAT deferral policy of the transshipment port; The transaction corresponding to the second-leg bill of lading is the title transfer from "transshipment port to USA", which can be declared according to the origin rules of the transshipment country to avoid US anti-dumping duty. It is necessary to ensure that the transaction amount corresponding to the two bills of lading is consistent with the customs declaration amount, so as to avoid triggering related party transaction verification under BEPS.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-4", "datePublished": "2026-10-15T12:59:02Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "The number of bills of lading for transit trade needs to match the compliance requirements of cross-border foreign exchange receipt and payment. In 2026, the State Administration of Foreign Exchange of China requires that for transit trade foreign exchange supervision, bills of lading corresponding to the amount of foreign exchange receipt and payment must be provided. If only one through bill of lading is issued, it will be deemed as "incomplete documents", resulting in delayed posting of foreign exchange, and even being included in the foreign exchange verification blacklist. Two bills of lading are required: The first-leg bill of lading corresponds to the foreign exchange payment from China to the transshipment port (payment to domestic factory), the second-leg bill of lading corresponds to the foreign exchange receipt from USA to China (payment from US buyer), the difference in cargo value between the two bills of lading must be consistent with the profit of the transit trade, and "transit trade first-leg/second-leg bill of lading number" must be indicated in the SWIFT message to facilitate automatic verification by the SAFE system.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-5", "datePublished": "2026-10-15T12:39:00Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } , { "@type": "Answer", "text": "The number of bills of lading in transit trade directly affects the legal validity of title transfer. If only one through bill of lading is issued, the title will be directly transferred from the domestic factory to the US buyer, and the transshipment service provider cannot exercise title control. If the buyer refuses to pay under the L/C, there is no way to stop loss by detaining the goods. Two bills of lading are required: The consignee of the first-leg bill of lading is the transshipment service provider, and the title belongs to the transshipment service provider until the transshipment service provider issues the second-leg bill of lading; The consignor of the second-leg bill of lading is the transshipment service provider, and the title is transferred to the US buyer. At the same time, the L/C must clearly require the submission of original and copy of the two bills of lading, and the first-leg bill of lading must be accompanied by the title transfer endorsement document from the transshipment service provider, so as to avoid legal disputes caused by unclear title ownership.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-6", "datePublished": "2026-10-15T12:22:31Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } , { "@type": "Answer", "text": "The number of bills of lading for transit trade needs to match the on-site inspection requirements of the transshipment port. In 2026, the on-site inspection rules of Port Klang Malaysia clearly stipulate that transit goods must submit two bills of lading (first-leg and second-leg), and inspectors will check whether the container number, seal number and cargo name of the two bills of lading are consistent. If only one through bill of lading is submitted, it will be deemed as "document inconsistency" and trigger devanning inspection. The inspection fee is about 1200 MYR per container, and the detention fee is about 80 MYR per container per day. It is necessary to ensure that the seal number of the first-leg bill of lading is the factory seal from the domestic factory, the seal number of the second-leg bill of lading is the transshipment seal from the transshipment service provider, and the cargo name on the two bills of lading must use the customs code of the transshipment port, so as to avoid triggering origin inspection.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-7", "datePublished": "2026-10-15T11:59:09Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "The number of bills of lading for transit trade needs to match the compliance requirements of cargo packaging. If the cargo is outdoor furniture, it may involve IPPC marking for wooden packaging. In 2026, the inspection rate of US Customs for wooden packaging from China is as high as 35%. If only one through bill of lading is issued, the wooden packaging will be deemed as originating from China, triggering fumigation inspection. Two bills of lading are required: The packaging information of the first-leg bill of lading is filled as "wooden packaging with Chinese IPPC marking", which is used for packaging replacement at the transshipment port; The packaging information of the second-leg bill of lading is filled as "wooden packaging with Malaysian IPPC marking", which is used for US customs clearance. It is necessary to ensure that the packaging information on the two bills of lading is consistent with the actual packaging, the first-leg bill of lading is accompanied by the fumigation certificate for the wooden packaging, and the second-leg bill of lading is accompanied by the packaging replacement certificate from the transshipment port, so as to avoid triggering packaging compliance verification.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-8", "datePublished": "2026-10-15T11:43:16Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } , { "@type": "Answer", "text": "The number of bills of lading in transit trade directly affects the export tax refund compliance of domestic factories. In 2026, the State Taxation Administration of China clearly stipulates in the export tax refund rules for transit trade that domestic factories can only apply for tax refund for goods exported under the first-leg bill of lading. If only one through bill of lading is issued, it will be deemed as "direct export to USA", cannot enjoy the tax refund preference for transit trade, and even be deemed as "false export" and trigger tax verification. Two bills of lading are required: The consignor of the first-leg bill of lading is the domestic factory, the consignee is the transshipment service provider, which is used for the domestic factory's export tax refund declaration; The consignor of the second-leg bill of lading is the transshipment service provider, the consignee is the US buyer, which is used for settlement of the transit trade. It is necessary to ensure that the cargo value and quantity of the two bills of lading are consistent with the amount on the domestic factory's VAT invoice, meeting the requirement of four-consistency.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-9", "datePublished": "2026-10-15T11:40:55Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } , { "@type": "Answer", "text": "The number of bills of lading for transit trade needs to match the requirements of supply chain cost control. In 2026, the transshipment cost of transit trade is about 3-5% of the cargo value. If only one through bill of lading is issued, it will lead to a 20% increase in ship changing and warehousing costs at the transshipment port, because through bills of lading cannot enjoy the transit preferential policy of the transshipment port. Two bills of lading are required: The first-leg bill of lading is used to lock the space from China to the transshipment port, and enjoy the space discount for transit goods (15% off the regular space rate); The second-leg bill of lading is used to lock the space from the transshipment port to USA, and enjoy the destination space discount at the transshipment port (10% off the regular space rate). It is necessary to ensure that the interval between space bookings of the two bills of lading does not exceed 48 hours, so as to avoid the increase of warehousing cost at the transshipment port. Meanwhile, the cargo location in the inventory system must be updated synchronously to ensure that the inventory data is consistent with the bills of lading.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/transit-trade-three-party-title-transfer-compliance-bill-of-lading-quantity.html#suggestedAnswer-10", "datePublished": "2026-10-15T11:31:09Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } ] } }, { "@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": "Entrepôt Trade Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-entrepot-trade/"} ,{"@type": "ListItem", "position": 4, "name": "How Many Bills of Lading Are Required for Compliance With Three-Party Title Transfer in Transit Trade?"} ] } ] ```