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What are the mandatory compliance control points that must be followed in the full-process operation of Zhoushan re-export trade?
or complex compliance issues.
clearance and fund security.
I am the foreign trade manager of a hardware products export enterprise in Ningbo. Recently, the US has imposed an additional 25% anti-dumping duty on our cast iron hardware products, which has directly eroded most of our profits, so we have to consider adopting Zhoushan re-export trade to avoid tariffs.
However, I have never been exposed to re-export operations before. Last week, I had dinner with a peer and heard that his goods were detained at the port for 12 days during re-export in Zhoushan due to non-compliant bill of lading endorsement. He not only paid 80,000 yuan of liquidated damages to the customer, but also incurred nearly 20,000 yuan of container detention fees. I have been so anxious that I have suffered from insomnia for several consecutive days, and I want to ask about the specific operation: for example, what core documents need to be prepared in advance, what special requirements are there for the re-export process of Zhoushan Port, how to effectively avoid the risks of port detention and customs seizure, whether the comprehensive cost of re-export is much higher than that of direct export, and whether there are compliant cost reduction methods?
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
Pre-document verification for Zhoushan re-export trade should focus on details: Core documents must meet the requirement of "three documents conformity"，that is，the goods description，weight and number of pieces on the bill of lading，manifest and re-export declaration form must be completely matched，and the documents should be submitted to Zhoushan Port Authority for pre-verification 72 hours in advance. Special attention should be paid to the certificate of origin issued by the third-party transit country. It is necessary to confirm that the issuing authority is on the customs white list，the mark of the original exporting country is strictly prohibited in the goods description，and the shipping mark of product packaging should be replaced with the neutral shipping mark of the transit country in advance to avoid triggering customs valuation warning.
Core node connection should strictly follow the principle of "direct quay-side transfer": Re-export operation at Zhoushan Port is mainly based on document exchange at anchorage and direct transfer. It is necessary to confirm the connection window of the transit shipping schedule with the local freight forwarder in advance to ensure that the interval between the departure of the original ship and the arrival of the transit ship does not exceed 48 hours，so as to avoid extra storage fees caused by goods entering the yard. For the payment and receipt link，cross-border RMB payment should be made through the CIPS system，and the remark column must be marked with "payment under re-export trade" to strictly match the capital flow and goods flow.
Abnormal response plans should be deployed in advance: In case of random customs inspection，supporting materials such as the storage agreement of the transit country and the transit transportation contract should be provided as soon as possible，In case of document discrepancy，the declaration should be deleted and re-submitted within 24 hours，and the "priority inspection" channel of Zhoushan Customs should be applied for，If the transit ship is delayed，it is necessary to immediately synchronize with foreign customers to adjust the presentation period of the letter of credit，and apply to the shipping company for an extension of the free storage period of 3-5 days.
Final compliance implementation requires the completion of four-stream filing: After the re-export operation is completed，a full set of materials including the transit bill of lading，certificate of origin of the transit country，re-export declaration form and cross-border payment and receipt vouchers should be submitted to the tax authority for filing，so as to ensure that the goods flow，capital flow，document flow and contract flow are completely consistent，and avoid the subsequent risk of tax correspondence inspection.
Andy GuoYears of service：3Customer Rating：5.0
Supply Chain Management ExpertStart a Chat
For customs declaration of Zhoushan re-export trade, attention should be paid to the logical closed loop of "double declaration": The first declaration is for "inward re-export goods", the "trade mode" on the customs declaration form should be checked as "re-export trade", the "nature of levy and exemption" is "other statutory", and the transit transportation contract and the copy of the order of the foreign consignee should be uploaded simultaneously; The second declaration is for "outward re-export goods", and the customs declaration number of the first declaration should be used as the association number to ensure that the goods description, weight and number of pieces of the two declarations are completely consistent.
In case of valuation dispute, the third-party storage quotation of the transit country and the invoice of transit transportation fee should be provided immediately as evidence to avoid the customs collecting tax according to general trade. In addition, Zhoushan Customs has strict inspection on the ownership of re-export goods. It is necessary to provide the ownership transfer agreement between the original exporter and the transit freight forwarder, clarifying that the ownership of the goods during the re-export period belongs to the transit freight forwarder rather than the original exporter.
Cindy ChenYears of service：3Customer Rating：5.0
Key Account ManagerStart a Chat
The "direct transit" scheme should be given priority for the logistics path of Zhoushan re-export trade, and routes transiting through other domestic ports should be avoided to reduce the number of cargo loading and unloading and the risk of port detention. In terms of cargo right control, "order bill of lading" should be used, and the endorsement of the bill of lading should indicate "only for Zhoushan re-export, no direct pickup of goods", and the freight forwarder should be required to provide the confirmation letter of direct quay-side transfer immediately after the goods arrive at the port to ensure that the goods do not enter the yard.
In case of container rolling, it is necessary to immediately contact the freight forwarder to apply for the "emergency transit space" of Zhoushan Port, which is reserved exclusively for re-export goods and can arrange transshipment within 48 hours. In terms of free storage period, the basic free storage period for re-export goods in Zhoushan Port is 7 days.
If extension is needed, it can be extended to 14 days with the shipping schedule certificate of the transit ship, without paying extra fees. In addition, it is necessary to confirm the manifest information of the transit ship in advance to ensure that the "cargo destination" on the manifest is the transit country rather than the final importing country.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
Tax planning for Zhoushan re-export trade should focus on VAT deferral and related transaction pricing: First, goods under re-export trade do not enter the domestic circulation link, so enterprises can apply for exemption from import VAT and do not need to carry out VAT deduction. It is necessary to submit the "Filing Form for VAT Exemption for Re-export Trade" to the Zhoushan tax authority in advance, and provide the transit transportation contract and the order of the foreign consignee as supporting materials.
Second, if the enterprise has an affiliated company in the transit country, it is necessary to ensure that the pricing of related transactions complies with the "arm's length principle" of BEPS, that is, the pricing of transit fees should be consistent with the quotation of local third-party freight forwarders, so as to avoid being identified as profit shifting by the tax authority. In addition, the profit of re-export trade should be included in the annual taxable income of the enterprise, and a full set of documents should be retained as the basis for cost deduction, including the invoice of the transit freight forwarder, the freight invoice of the shipping company, etc. If cross-border payment and receipt are involved, the amount and time of payment and receipt should be specified in the tax filing form to ensure that the capital flow matches the document flow.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
Payment and receipt operation of Zhoushan re-export trade should strictly follow the specifications of the CIPS system: First, the subject of payment and receipt must be the contracting party of the re-export trade, that is, the original exporter and the foreign consignee. Payment and receipt through offshore accounts are prohibited to avoid being identified as illegal outflow of funds.
Second, the "transaction code" of the SWIFT message should be filled in with "121010" (payment and receipt under re-export trade), and the postscript of the message should indicate "Zhoushan re-export trade, transit country XX, final destination XX" to ensure that the message information is completely consistent with the information on the customs declaration form. In case of foreign exchange settlement and account balancing problems, the customs declaration form of re-export trade should be used as the basis for foreign exchange settlement, and the customs declaration form of general trade shall not be used as a substitute.
In addition, the Zhoushan Administration of Foreign Exchange has strict inspection on payment and receipt of re-export trade. It is necessary to retain a full set of documents such as transit transportation contract, transit bill of lading and certificate of origin of the transit country in advance for random inspection. If there is a difference between the amount of payment and receipt and the amount on the customs declaration form, relevant fee certificates (such as the service fee invoice of the freight forwarder) should be provided as evidence.
Jason WuYears of service：10Customer Rating：5.0
International Logistics & Supply Chain ManagerStart a Chat
Contract terms of Zhoushan re-export trade should clarify the details of "cargo right transfer" and "force majeure": First, the contract between the original exporter and the transit freight forwarder should clarify that the cargo right of the goods during the re-export period at Zhoushan Port belongs to the transit freight forwarder until the goods are loaded on the transit ship, so as to avoid the joint liability of the original exporter caused by the detention of goods at the port. Second, the contract between the original exporter and the foreign consignee should indicate that "the goods are transited via Zhoushan to the final destination", and clarify that if the goods are delayed due to re-export operation, the transit freight forwarder shall bear the liability for breach of contract, and the original exporter shall only bear the coordination responsibility.
In addition, the content of "soft clause avoidance" should be added to the contract to prohibit the foreign consignee from requiring the consignee of the bill of lading to be directly marked as the customer of the final importing country, so as to avoid the loss of control of cargo right. In case of L/C settlement, the issuing bank should be required to delete the clause of "providing the certificate of origin of the original exporting country" and replace it with "providing the certificate of origin of the transit country" to ensure that the L/C terms are consistent with the re-export operation.
Lucas LiuYears of service：8Customer Rating：5.0
Senior Operations ConsultantStart a Chat
The following details should be paid attention to in the on-site inspection of Zhoushan re-export trade: First, the mark of the original exporting country must be completely removed from the shipping mark of the goods packaging, including the laser marking on the product and the printed words on the packaging. If it cannot be removed, it should be re-wrapped with neutral packaging to avoid being identified as general trade goods by the customs.
Second, supporting materials such as the storage agreement of the transit country and the transit transportation contract should be provided during customs inspection, and the date of the materials should be before the arrival of the goods to avoid being identified as supplementary made afterwards. In case of container unpacking inspection, the freight forwarder should be arranged to be present in advance to ensure that the packaging of the goods is not damaged during the unpacking process, and at the same time, it should be explained to the customs that the goods are only for re-export and do not enter the domestic market.
In addition, Zhoushan Customs has strict inspection on the seals of re-export goods. Disposable seals approved by the customs should be used, and the seal number should be marked on the customs declaration form and bill of lading simultaneously. If the seal is damaged, it is necessary to immediately apply to the customs for re-sealing to avoid being identified as abnormal transfer of cargo right.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
For export tax rebate of Zhoushan re-export trade, attention should be paid to the inspection of "four-stream consistency": First, goods under re-export trade do not fall into the scope of export tax rebate, so export tax rebate cannot be applied for. It is necessary to submit the "Statement of No Tax Rebate for Re-export Trade" to the tax authority in advance to avoid tax risks caused by false declaration. Second, it is necessary to ensure that the goods flow, capital flow, document flow and contract flow are completely consistent, that is, the transportation path of the goods is "original exporting country -> Zhoushan -> transit country -> final importing country", the capital flow is "foreign consignee -> original exporter", the document flow is "transit bill of lading, certificate of origin of transit country, re-export declaration form", and the contract flow is "re-export trade contract between original exporter and foreign consignee".
If the enterprise carries out general trade and re-export trade at the same time, the accounts of the two types of business should be accounted for separately, so as to avoid the cost of re-export trade being included in the cost of general trade, leading to abnormal export tax rebate amount. In addition, a full set of documents should be retained for at least 5 years for the correspondence inspection of the tax authority, including the invoice of the transit freight forwarder, the freight invoice of the shipping company, the re-export declaration form, etc.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
Supply chain planning of Zhoushan re-export trade should focus on "cost actuarial calculation" and "inventory linkage": First, it is necessary to establish a cost actuarial model for re-export trade, including the calculation of various expenses such as sea freight, transit fee, document fee and port detention fee, and compare the cost of direct export (including anti-dumping duty) to determine the profit space of re-export trade. Second, it is necessary to establish long-term cooperative relations with local freight forwarders and shipping companies in Zhoushan to strive for preferential sea freight and transit fees.
Generally, enterprises with long-term cooperation can enjoy a fee discount of 10%-15%. In terms of inventory linkage, if the enterprise has a warehouse in Zhoushan, the goods to be re-exported can be stored in the warehouse in advance to avoid the port detention fee caused by the delay of the transit ship after the original ship arrives at the port, but it is necessary to ensure that the goods in the warehouse are in neutral packaging without the mark of the original exporting country.
In addition, the transit country for re-export should be dynamically adjusted according to the tariff policy of the final importing country. If a transit country is blacklisted by the final importing country, it should be immediately replaced with other eligible transit countries to avoid tariff risks.