Is transshipment trade operated in China in 2026 compliant with customs supervision requirements?
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I am a salesperson of a foreign trade company, mainly engaged in transshipment trade from Southeast Asia to Europe. Last year, our goods were detained by customs due to non-standard documents at the transit port, resulting in a loss of more than RMB 100,000.
Now in 2026, we want to restart this business, but we heard that the domestic transshipment trade policy has changed, and we wonder if it is still feasible now. In addition, our goods are shipped from Malaysia to Singapore for transit and then to Germany. Previously, all payment and receipt were processed through offshore accounts.
Now supervision is stricter, will there be any problems? Also, what documents are required for transshipment trade? Are there any new requirements? The value of our goods this time is about RMB 1.2 million, and we do not want any more mistakes.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
Carrying out transshipment trade within the territory of China in 2026 is legal and compliant，but you must strictly abide by the supervision requirements of multiple departments. The core definition of transshipment trade is that goods do not actually enter the Chinese territory for circulation，only domestic enterprises act as intermediaries to complete the transfer of goods ownership and document circulation，and overseas consignors directly deliver goods to overseas consignees.
Pre-document review is the core，it is necessary to ensure the consistency of three streams: goods ownership transfer certificate，transit port storage certificate and full set of bills of lading. The customs intelligent document review system has been upgraded in 2026. If there are logical contradictions in the documents，such as too short stay time at the transit port and no trace of goods ownership transfer，it will directly trigger controlled inspection.
Two points should be paid attention to for the connection of core nodes: first，choose transit ports with transshipment trade qualifications such as Singapore and Dubai，confirm the transit operation process without goods ownership transfer in advance，and avoid being identified as violation of domestic bonded storage regulations，second，payment and receipt shall be completed through banks with cross-border RMB settlement qualification using the CIPS system，and illegal operations through offshore accounts are strictly prohibited.
For abnormal contingency plans，if you encounter customs controlled inspection，you can make an appointment for the fast inspection channel for transshipment trade launched in 2026 in advance，and provide complete evidence of the goods ownership transfer chain at the first time，including sales contracts，payment vouchers，bill of lading endorsement records，etc。to reduce port detention losses.
For final compliant implementation，the full set of business materials shall be retained for at least 3 years，including transit port expense vouchers，goods ownership transfer agreements，etc。for tax correspondence and customs verification. The whole process shall ensure the unification of three streams: goods ownership，capital and documents，to avoid touching the regulatory red line.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
The core of customs document review for transshipment trade lies in the "proof of separation between goods ownership and logistics". In 2026, a special document review module for transshipment trade has been added to the customs system, which will automatically compare the goods ownership transfer time and logistics trajectory.
If the time difference between the transit port storage certificate submitted by the enterprise and the bill of lading transit time is less than 24 hours, it will directly trigger manual review. It should be noted that transshipment trade goods shall not enter domestic warehouses outside China's special customs supervision areas, otherwise they will be identified as general trade imports.
In case of valuation disputes, official storage vouchers of overseas transit ports can be submitted as evidence. The customs has opened a fast response channel for transshipment trade valuation in 2026, which can complete the review within 3 working days.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The logistics path of transshipment trade should focus on goods ownership control and cost optimization. In 2026, major global transit ports have launched exclusive storage yards for transshipment goods, which can provide storage certificates without goods ownership transfer. It is necessary to select freight forwarders that use order bills of lading, complete the transfer of goods ownership through endorsement transfer, and avoid directly delivering goods to overseas consignees resulting in loss of goods ownership.
In case of space shortage or port change requirements, you can give priority to the direct transit route of Singapore Port, whose free storage period can be up to 14 days, which can effectively reduce container detention fees. At the same time, the words "transshipment trade" shall be clearly marked on the bill of lading to avoid being identified as domestic cargo transportation by customs.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
The tax treatment of transshipment trade should avoid BEPS risks. In 2026, China's tax authorities have included transshipment trade in the supervision scope of cross-border related transactions.
If domestic intermediaries conduct transshipment trade with overseas related parties, they need to prepare related transaction pricing documents in advance. Transshipment trade goods do not enter the Chinese territory, so there is no need to pay domestic value-added tax, but the expense vouchers of overseas transit ports shall be retained for tax correspondence.
For transshipment trade involving the EU region, you can apply for VAT deferral to avoid paying value-added tax in advance at the transit port and reduce capital occupation costs. It should be noted that the profits from transshipment trade shall be declared and taxed in accordance with the provisions of the Enterprise Income Tax Law of China, and income shall not be concealed through offshore accounts.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Cross-border payment and receipt for transshipment trade shall strictly comply with foreign exchange administration regulations. In 2026, the State Administration of Foreign Exchange has upgraded the cross-border payment and receipt monitoring system, which will automatically compare the goods ownership transfer, logistics trajectory and capital flow of transshipment trade.
RMB payment and receipt shall be completed through the CIPS system, and illegal operations through offshore accounts under the SWIFT system shall be avoided. The amount of payment and receipt for transshipment trade shall fully match the goods value and transit port expenses, and there shall be no idle capital flow or large amount of payment and receipt without reasonable reasons.
If you need to optimize the foreign exchange settlement rate, you can choose a bank with cross-border exchange rate risk hedging qualification, and lock in exchange rate risks through forward foreign exchange settlement contracts. At the same time, transaction vouchers for payment and receipt shall be retained for verification by the foreign exchange administration department.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
The contract terms of transshipment trade shall clarify the responsibilities of all parties to avoid legal risks. In 2026 international trade disputes, goods ownership disputes of transshipment trade account for 32%. It is necessary to clarify the storage responsibility of the transit port, bill of lading endorsement process and goods ownership transfer time in the contract.
If letter of credit settlement is used, soft clauses shall be avoided, such as requiring transit port certificates that cannot be obtained. Force majeure clauses shall be added to the contract to clarify the division of responsibilities for transit port congestion, customs inspection and other situations.
At the same time, overseas freight forwarders shall be required to provide goods ownership guarantees to ensure the safety of goods at the transit port. In case of goods ownership disputes, arbitration can be conducted through the China International Economic and Trade Arbitration Commission, which has opened a fast arbitration channel for transshipment trade disputes in 2026, and the award can be completed within 6 months.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
On-site customs inspection of transshipment trade shall focus on the verification of goods ownership certificates and logistics trajectories. In 2026, customs inspection personnel will focus on checking the port of shipment, transit port and port of destination of the bill of lading, as well as the signing time of the goods ownership transfer agreement.
If the goods are subject to controlled inspection, the official storage certificate of the transit port, goods ownership transfer agreement and full set of bills of lading shall be provided at the first time. It should be noted that transshipment trade goods shall not carry Chinese labels or domestic transportation marks, otherwise they will be identified as domestic goods.
In case of abnormal machine inspection, you can apply for unpacking inspection, and provide the certificate of origin and packing list of the goods as evidence. The customs has launched a fast release mechanism for transshipment goods inspection in 2026. If the materials are complete, the inspection and release can be completed within 2 hours.