---
title: "What Types of Bills of Lading Are Involved in the Whole Process of Entrepot Trade? What Are Their Core Functions?"
description: "Some entrepot trade practitioners have cognitive misunderstandings about bill of lading types，cargo ownership and circulation specifications，which easily trigger cascading risks such as cargo title disputes，port demurrage and customs detention. It is necessary to clarify that entrepot trade involves three types of bills of lading: first-leg，transfer and last-leg. Bills of lading in each link must strictly match the flow of cargo title. Through pre-document review，connection control of core nodes..."
url: "https://www.sh-zhongshen.com/en/qa/types-and-core-functions-of-bills-of-lading-in-transshipment-trade.html"
language: "en"
type: "Q&A"
category: "Entrepôt Trade Q&A"
datePublished: "2026-10-16"
dateModified: "2026-10-16"
brand: "Zhongshen Trading China"
answerCount: 9
---

# What Types of Bills of Lading Are Involved in the Whole Process of Entrepot Trade? What Are Their Core Functions?

## Question

 I am an exporter of hardware and electrical machinery. I tried entrepot trade for the first time last month to avoid the anti-dumping duty imposed by the United States. I only did direct shipment before and only had contact with ocean bills of lading. Now my freight forwarder has given me two bills of lading for the first leg and transfer leg, and said there will be another one for the last leg, which completely confused me! I just heard last week that a peer's cargo was detained at the transit port for 12 days due to improper bill of lading circulation in entrepot trade. It not only incurred nearly 20,000 yuan in port demurrage, but also almost missed my client's delivery deadline. Now I am very anxious: how many types of bills of lading are there in entrepot trade? How is the cargo ownership of bills of lading in different links determined? Will cargo detention or cargo title loss be caused by non-compliant bills of lading? 

## Answers
                            
### Answer 1 — Best Answer

The whole process of entrepot trade involves three types of bills of lading，and full-link control is required starting from pre-document review. In the pre-review stage，it is necessary to focus on checking whether the consignor and consignee information of the **first-leg bill of lading** is consistent with the filing subject of the transit warehouse，ensure that the transit warehouse is qualified to operate entrepot cargo，and confirm that the "transportation clause" on the bill of lading is marked as "transshipment" instead of "direct shipment"，so as to avoid triggering anti-dumping investigation in the destination country.

For the connection of core nodes，after the first-leg bill of lading is issued by the forwarder at the port of departure，it shall be delivered to the transit warehouse service provider. After the service provider completes the cargo re-boxing operation，it will issue the **transfer bill of lading**. The consignor of the transfer bill of lading shall be the subject of the transit warehouse，and the consignee shall match the consignor of the last-leg bill of lading，the last-leg bill of lading is issued by the forwarder at the destination port，and the consignee is directly marked as the final purchaser，ensuring that the flow of cargo title is clear and traceable.

For contingency plans，it shall be agreed in advance: if cargo is detained due to inconsistent bill of lading information at the transit port，the transit warehouse service provider shall submit the corrected bill of lading and entrepot trade qualification certificate within 24 hours，and coordinate with the local customs broker to apply for port demurrage reduction，if there is a cargo title dispute，the endorsement records and circulation vouchers of bills of lading in each link shall be immediately retrieved，and evidence shall be presented through the third-party neutral status of the transit warehouse.

In the final compliance implementation stage，three types of bills of lading together with entrepot trade contracts，payment vouchers，certificates of origin and other documents shall be uniformly archived，to ensure the consistency of "document flow，cargo flow and capital flow"，and avoid being determined as fake entrepot trade by customs.

**status:** accepted
**Author:** Evelyn Li
**Date:** 2026-10-16

### Answer 2

The bill of lading in entrepot trade is one of the core documents for customs valuation and compliance verification. When verifying the authenticity of entrepot trade, customs will compare the cargo description, quantity and weight of first-leg, transfer and last-leg bills of lading.

If there is any discrepancy, it will directly trigger valuation doubt, and even be identified as fake entrepot trade. If the transportation route on the bill of lading does not match the entrepot route declared on the customs declaration, customs will launch a traceability investigation and require the enterprise to provide supplementary materials such as re-boxing records and storage vouchers from the transit warehouse.

If the materials cannot be submitted within the specified time limit, the cargo will be detained, and the enterprise can pick up the cargo only after paying a security deposit. In addition, the endorsement record of the bill of lading in entrepot trade shall be consistent with the receiving and payment subject of capital flow, so as to avoid being determined as profit transfer through related party transactions.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-16

### Answer 3

Cargo title control of bills of lading in different links of entrepot trade directly determines cargo safety. The title of the first-leg bill of lading belongs to the consignor, which needs to be endorsed and transferred to the transit warehouse service provider before the cargo arrives at the transit port, to ensure that the service provider has the right to operate re-boxing; the title of the transfer bill of lading belongs to the transit warehouse service provider, and the last-leg transportation can only be arranged after it is endorsed and transferred to the last-leg forwarder; the title of the last-leg bill of lading directly belongs to the final purchaser, and the endorsement shall be completed before the cargo arrives at the destination port.

If the transit warehouse service provider fails to issue the transfer bill of lading in time, it will lead to the failure of normal arrangement of last-leg transportation and trigger demurrage risk; if the endorsement of the bill of lading is not continuous, it will lead to the failure of normal transfer of cargo title, and even the situation that the cargo is taken away by a third party.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-16

### Answer 4

The information of bills of lading in entrepot trade directly affects the compliance of cross-border tax planning. If the consignor of the first-leg bill of lading is a domestic enterprise, the consignor of the transfer bill of lading is an overseas transit warehouse entity, and the consignor of the last-leg bill of lading is an overseas trading company, tax base optimization can be realized through structural design, avoiding domestic enterprises being identified as direct export and paying value-added tax.

However, if the cargo description on the bill of lading does not match the commodity code declared for tax, it will trigger a tax correspondence investigation, requiring the enterprise to provide all documents of the entrepot trade. If the business authenticity cannot be proved, the tax will be recovered and late payment surcharge will be added. In addition, the marking of transportation cost on the bill of lading shall be consistent with the freight payment voucher in capital flow, so as to avoid being identified as cost inflation.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-16

### Answer 5

The circulation of bills of lading in entrepot trade shall be strictly matched with the foreign exchange collection and payment process. The first-leg bill of lading corresponds to the payment between the domestic enterprise and the transit warehouse service provider, which shall be completed through the Cross-border Interbank Payment System (CIPS), and the remark of the payment voucher shall be marked "first-leg freight and cargo payment for entrepot trade"; the transfer bill of lading corresponds to the payment between the transit warehouse service provider and the overseas trading company, which shall be completed through the SWIFT system, and the remark is marked "transfer cargo payment for entrepot trade"; the last-leg bill of lading corresponds to the payment between the overseas trading company and the final purchaser, which shall be consistent with the payment clauses agreed in the entrepot trade contract.

If the subject and amount of bill of lading information do not match those of the collection and payment voucher, the bank will determine it as non-compliant foreign exchange collection and payment, which will affect the enterprise's foreign exchange settlement qualification.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-16

### Answer 6

The bill of lading in entrepot trade is the core legal document for defining cargo ownership and breach of contract liability. If the first-leg bill of lading does not clearly mark the "transshipment clause" and does not agree on the responsible party for transshipment and re-boxing, once the cargo is damaged at the transit port, it is easy to cause a breach of contract dispute between the consignor and the transit warehouse service provider.

The transfer bill of lading needs to clearly agree on the time node of cargo title transfer, so as to avoid the situation that "cargo has been transferred but cargo title has not been changed"; the last-leg bill of lading needs to be marked with "to order" endorsement, so as to avoid malicious encroachment of cargo title by a third party. In addition, the circulation process and dispute resolution method of bills of lading shall be clearly specified in the entrepot trade contract. Once a cargo title dispute occurs, arbitration or litigation can be initiated directly based on bill of lading information and contract clauses.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-10-16

### Answer 7

The bill of lading in entrepot trade is the core comparison document for on-site inspection. During inspection at the transit port, customs will check whether the seal number on the bill of lading is consistent with the seal number of the actual cargo. If there is any discrepancy, the cargo will be identified as swapped and directly detained; during inspection at the destination port, customs will compare the cargo description and quantity of the last-leg bill of lading and the first-leg bill of lading.

If there is any discrepancy, it will be identified as fake entrepot trade and trigger anti-dumping duty recovery. In addition, the transportation time on the bill of lading shall be consistent with the time node of storage vouchers and re-boxing records. If there is a time difference, customs will determine that the cargo stays at the transit port for too long, which is suspected of local sales, and local taxes and fees shall be paid.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-16

### Answer 8

The information of bills of lading in entrepot trade affects the compliance verification of export tax refund. If an enterprise mistakenly declares entrepot trade as direct export, the "transshipment" clause on the bill of lading does not match the "direct shipment" declared for tax refund, which will trigger a tax correspondence investigation, requiring the enterprise to provide all documents of the entrepot trade.

If the business authenticity cannot be proved, the tax refund qualification will be canceled and the already refunded tax will be recovered. In addition, the consignor and consignee information on the bill of lading shall be consistent with the foreign exchange collection voucher and contract subject for tax refund declaration.

If there is any inconsistency, it will be identified as capital reflux and trigger anti-tax avoidance investigation. Entrepot trade enterprises shall uniformly archive three types of bills of lading together with tax refund documents, and the storage period shall be no less than 5 years.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-10-16

### Answer 9

The type and circulation process of bills of lading in entrepot trade affect the cost and efficiency of the supply chain. Choosing the "full set bill of lading" circulation mode can ensure cargo title security, but it will increase the document processing cost and time in the transit link; choosing the "telex release bill of lading" circulation mode can improve circulation efficiency, but it will increase cargo title risk.

Enterprises need to choose appropriate bill of lading types according to factors such as cargo value, transportation distance and destination country policies, and at the same time realize real-time synchronization of bill of lading information through the supply chain system, ensuring that subjects in each link can obtain bill of lading information in time and avoid transportation delays. In addition, the bill of lading circulation cost shall be included in the supply chain cost actuarial model, and the overall supply chain cost can be reduced by optimizing the bill of lading circulation process.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-16

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