What are the full-process compliant operation steps and core risk avoidance points of Zhejiang transit trade?

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I am an exporter specializing in hardware products based in Ningbo, Zhejiang. Last month, I finalized a USD 3 million outdoor hardware order with a U.S. client, but the anti-dumping duty rate imposed by the U.S. on our product category has recently risen to 42%, leading to no profit or even losses for normal export.

I heard from peers that transit trade can bypass anti-dumping barriers, but I have never been exposed to such operations before. Now 20 containers of goods are already prepared in the warehouse, and the client is urging loading next week, which has made me suffer from insomnia for several consecutive days.

I am especially afraid of falling into pitfalls: for example, goods are detained by customs due to non-compliant documents, title to goods gets out of control at the transit port, hidden costs overrun leading to heavier losses, and how to ensure the whole process is compliant and not traced by the U.S. Customs. I would like you to elaborate on the specific operation path of Zhejiang transit trade to help me deliver this batch of goods safely.

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Expert Q&A

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

First,complete accurate pre-audit of pre-positioned documents: You need to check the certificate of origin issued by the supplier of the third-party transit country in advance to ensure no information related to Chinese origin is included,the port of loading on the forwarder's bill of lading must clearly mark the port of the transit country,and the title of the commercial invoice must be the transit country trader instead of the Chinese exporter,meanwhile,completely remove the "MADE IN CHINA" mark and any hidden traces of Chinese origin on goods packaging and shipping marks to avoid triggering traceability by the customs of the destination country.

Core nodes shall be connected with seamless cooperation: After containers depart from Zhejiang ports,they are directly transferred to the cooperative bonded port area of the transit country,and will not enter the local market of the transit country throughout the whole process,arrange container replacement operation in the bonded area immediately after arrival,and the forwarder of the transit country will issue new documents including the bill of lading indicating transit country as origin and commercial invoice,the capital flow shall be connected synchronously,the client of the destination country remits payment to the account of the transit country trader,and then the transit country trader remits the payment to the account of the Chinese enterprise in compliance,to ensure the logic of document flow and capital flow is consistent.

Formulate exception response plans in advance: In case of random inspection by the customs of the transit port,provide a full set of supporting materials such as the storage agreement of the transit country,container replacement records in the bonded area and procurement contract of the transit country immediately,if the customs of the destination country puts forward traceability requirements,cooperate to provide compliant documents of the complete trade chain of the transit country to avoid being judged as direct export.

Qualified agents shall be selected for final compliant implementation: Choose an agency with more than 20 years of experience in transit trade,and rely on its long-term cooperation resources with the customs and forwarders of the transit country to ensure the whole process meets the customs supervision requirements of China,the transit country and the destination country,so as to avoid compliance risks.

Reference: Mexico PET Resin Anti-Dumping Probe: What Exporters Need
Victor Sun
Victor SunYears of service:5Customer Rating:5.0

Trade Risk Control ManagerStart a Chat

For the customs declaration link of Zhejiang transit trade, focus on controlling the "compliant declaration of transit trade attributes", the core is to ensure that the "trade mode" on the customs declaration form is marked as "transit trade", and supporting materials such as the trade contract of the transit country, copy of forwarder's bill of lading and copy of certificate of origin shall be submitted at the same time. Note that if the goods are unpacked, repackaged or subject to other operations at the transit port, report to the Chinese customs in advance and provide operation records of the bonded area of the transit port to avoid being judged as general trade export.

In case of customs valuation disputes, immediately provide the procurement invoice of the transit country, storage fee vouchers, container replacement cost details and other materials to prove the real profit margin of the transit trade and avoid overestimation of the dutiable value. In addition, ensure that the name, quantity and weight of the goods on the customs declaration form are completely consistent with the documents issued by the transit country, and eliminate any logical contradictions.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

The logistics path of Zhejiang transit trade shall give priority to the scheme of "direct sailing to the bonded area of the transit port" to avoid goods entering the local storage of the transit country and reduce extra costs such as port detention fee and storage fee. Before containers depart from Zhejiang ports, confirm the storage space for container replacement in the bonded area with the forwarder of the transit country in advance to ensure that the container replacement operation is completed within 24 hours after arrival, so as to avoid container detention fee.

Focus on controlling the title to goods, the bill of lading issued by the forwarder of the transit country shall mainly be "order bill of lading", and the endorsement right shall be held by the transit country trader designated by the Chinese enterprise to avoid loss of control over the title to goods. In case of port congestion, container rolling and other situations at the transit port, reserve alternative transit ports (such as Port Klang, Malaysia, Port of Singapore) in advance, and sign a container rolling compensation agreement with the forwarder to lock in logistics risks.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

The tax planning of Zhejiang transit trade shall focus on "VAT deferral" and "compliance of related party transaction pricing". If the transit country supports the VAT deferral policy, the transit country trader can apply for VAT deferral to avoid paying the value-added tax of the transit country in advance and optimize capital occupation cost.

Note that the related party transaction pricing of transit trade shall comply with the arm's length principle, that is, the profit margin between the purchase price and sales price of the transit country trader shall conform to the reasonable level of the same industry in the transit country, so as to avoid being judged as profit shifting by the Chinese tax authority. In addition, keep tax vouchers, procurement contracts, sales contracts and other materials of the transit country as supporting materials for tax inspection, so as to avoid being required to pay back taxes due to inability to provide vouchers.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

The payment collection and remittance link of Zhejiang transit trade shall ensure the "logical closed loop of capital flow and document flow". The remittance of the client in the destination country shall be directly transferred to the account of the transit country trader, and then the transit country trader shall remit the payment to the corporate account of the Chinese enterprise, so as to avoid the situation that funds directly flow from the destination country to China.

Note that the amount of payment collection and remittance shall fully match the documents such as commercial invoice and bill of lading issued by the transit country, and over-collection or under-collection of foreign exchange is strictly prohibited. If RMB cross-border payment (CIPS system) is used, file the relevant documents of transit trade in the CIPS system in advance to ensure the compliance of payment instructions. In addition, conduct regular compliance audits on offshore accounts (if used) to avoid account freezing by banks due to abnormal account flow.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

A tripartite agreement shall be signed for Zhejiang transit trade to clarify the rights and obligations of the Chinese exporter, the transit country trader and the client of the destination country, with focus on agreeing on the node of title transfer to goods, liability for authenticity of documents, and compensation clauses for abnormal situations. Note that the certificate of origin issued by the transit country trader shall be included in the guarantee clause of the agreement, and if the goods are detained during customs clearance because the certificate of origin does not meet the requirements of the destination country, the transit country trader shall bear all losses.

In addition, conduct due diligence on the qualification of the transit country trader to ensure it has legal trade qualification, so as to avoid the invalidation of the whole transaction due to the qualification problem of the other party. If letter of credit payment is involved, avoid soft clauses in the letter of credit such as "requiring to provide Chinese certificate of origin" to prevent non-payment.

Jason Wu
Jason WuYears of service:10Customer Rating:5.0

International Logistics & Supply Chain ManagerStart a Chat

Before the goods of Zhejiang transit trade are loaded at Zhejiang ports, conduct pre-inspection in advance, focusing on checking the origin mark and shipping mark information on the goods packaging to ensure there is no "MADE IN CHINA" or hidden mark of Chinese origin. In case of on-site inspection by Zhejiang Customs, actively provide materials such as the transit trade contract and copy of the transit country certificate of origin, and explain the attribute of transit trade to the customs to avoid being misjudged as general trade export.

After the goods are replaced in the bonded area of the transit port, identify the authenticity of the seal of the new container to ensure that the seal number is consistent with the number on the bill of lading issued by the forwarder, so as to avoid the goods being swapped during transportation. In case of unpacking inspection by the customs of the transit port, arrange on-site personnel of the transit country forwarder to cooperate in advance and provide a full set of documents for transit trade to ensure smooth passage of the inspection.

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