Does the value of off-shore entrepot trade transshipped via third parties in 2026 fall within the customs import/export statistical scope?
Importing from China?
Need help with sourcing, customs or shipping?
Your China Import Partner
Reliable sourcing and import agency services.
I am the person in charge of an enterprise mainly engaged in photovoltaic module entrepot trade. I have been doing Southeast Asian entrepot business for 3 years. The conventional path is to transport modules manufactured in China to Singapore transit warehouse for container re-stuffing, then send them to the EU to avoid anti-dumping and countervailing duties.
The customs just updated trade statistics and inspection rules in 2026, which I have not fully grasped. Last week, a peer enterprise in the same park had 12 arriving containers detained and was fined 270,000 due to issues with the value declaration of entrepot trade.
I currently have 8 containers in transit and am worried that my operations will violate regulations. I want to clarify whether entrepot trade will be included in the customs import/export statistical scope, cross-border foreign exchange compliance inspection scope, and export tax refund qualification verification items, and what operations I need to adjust to avoid violations.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
First，clarify the latest 2026 rules: entrepot trade is divided into two categories based on the flow of cargo rights and the declarant to determine whether it is included in the statistical/inspection scope. If during the transit link，the cargo rights do not transfer from a domestic entity to a third overseas party，and the offshore entrepot is entirely held by the domestic entity，it is not included in the customs import/export trade statistical scope，but will be included in the core scope of cross-border foreign exchange receipts and payments compliance inspection. If during the transit link，the cargo rights have been transferred to a domestic or overseas third party，and there is an import declaration action for domestic sales transit，it will be included in the import/export statistics.
When reviewing supporting documents，pay attention to three core points: fully retaining authentic documents for container re-stuffing at the transit port，including re-stuffing photos，seal number records，and third-party warehouse certificates，no forged transit certificates of origin，SWIFT payment and receipt messages must clearly mark "entrepot trade" and cannot be mixed with general trade payments/receipts for declaration，if your business does not involve import and re-export of goods at all，you cannot apply for export tax refunds，otherwise it will directly trigger tax bureau verification.
The connection of core nodes should ensure 100% matching of transit records and logistics tracks，AIS ship positioning information cannot be tampered with. For emergency plans，if customs inspection is encountered，submit the full set of cargo right transfer certificates for entrepot trade，full-link logistics tracks，and transaction contracts immediately to avoid being judged as false trade. Compliance implementation requires maintaining a monthly ledger of entrepot trade receipts and payments，filing them one-to-one with logistics documents，and retaining them for no less than 10 years.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
The 2026 customs valuation criteria for entrepot trade have been clarified: only transshipment transactions where goods actually enter and exit China's customs territory and cause an increase or decrease in domestic material stock will be included in the import/export trade statistical scope. Pure offshore transit, where goods do not actually enter and exit the customs territory, do not need to submit import/export declarations and will not be included in the statistical scope.
If an enterprise incorrectly declares offshore entrepot trade as general trade, it will directly trigger a valuation early warning; at minimum, the declaration will be deleted and re-declared, and at maximum, a fine of 5% to 30% of the value of the goods will be imposed for false declaration. If an incorrect declaration has already occurred, submit supporting materials proving that cargo rights have not transferred within the territory immediately and apply to modify the declaration category to avoid triggering subsequent inspection processes.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Logistics tracks of entrepot trade will be included in customs risk control big data comparison. In 2026, global port logistics data has achieved network sharing with 87 major trading countries; transit port re-stuffing records, container seal number change records, and storage stay duration will be automatically synchronized to the domestic customs database.
When choosing a transit plan, prioritize ports with data recognition agreements with China's customs, avoid gray transit ports without data interoperability, otherwise it will directly trigger a logistics track anomaly early warning and lead to goods being detained. At the same time, apply for a transit port free storage period of at least 14 days in advance to avoid high demurrage fees caused by customs inspection.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
Business income from entrepot trade will not be included in the export tax refund calculation scope. In 2026, the tax bureau clearly stipulates that only goods that actually clear customs for export and belong to general trade goods that have paid value-added tax in domestic production processes meet the application conditions for export tax refunds. Goods that are only transshipped and not actually exported cannot apply for refunds.
If an enterprise mixes entrepot trade income into general trade income for refund declaration, it will be identified as fraudulent export tax refunds; at minimum, the refund will be recovered and a fine of 1 to 5 times will be imposed, and at maximum, criminal responsibility of relevant persons will be pursued. Enterprises can reduce tax costs in transit through VAT deferral, without profiting through illegal refund declarations.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
Cross-border receipts and payments of entrepot trade will be included in the key inspection scope of the State Administration of Foreign Exchange. The cross-border capital flow monitoring system launched in 2026 has achieved automatic comparison with customs logistics data; the difference between income and expenditure of entrepot trade must not exceed 15% of the value of the goods.
When receiving and making foreign exchange payments, prioritize settlement through the Cross-Border Interbank Payment System channel; the transaction description in the SWIFT message must clearly mark "offshore entrepot trade", and cannot use vague expressions such as "general trade payment" or "goods trade payment", otherwise it will directly trigger receipt/payment suspension, and funds can be frozen for up to 6 months.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Cargo right transfer contracts of entrepot trade will be included as core materials in customs trade authenticity inspection. The latest judicial interpretation on international trade disputes in 2026 clarifies that cargo right transfer in entrepot trade must have clear written agreements, and cannot only rely on bill of lading endorsement as the only cargo right transfer voucher.
When signing an entrepot trade contract, clearly stipulate the ownership of cargo rights and risk division clauses during transit, and add force majeure fallback clauses to clarify the responsibility division when transit ports encounter customs inspection or policy changes, to avoid the loss of both goods and payments. If a third transit service provider is involved, sign an exclusive service agreement to avoid the leakage of commercial information by the service provider.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Container seal records of entrepot trade will be included as core inspection items in on-site inspection. The 2026 customs inspection system has achieved full-track traceability of electronic seals; the seal numbers changed at the transit port must be truthfully declared in logistics documents, and seal change records cannot be concealed.
When encountering customs container inspection, submit re-stuffing photos at the transit port, third-party warehouse inspection certificates, and factory inspection reports of the origin of goods immediately to avoid being judged as concealed origin. If goods are sent for testing, follow up on the inspection progress in time and submit corresponding entrepot trade supporting materials to shorten the inspection duration.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
Documents of entrepot trade will not be included in the export tax refund document filing scope, but will be included in the verification materials for tax bureau verification. The tax bureau's four-stream verification system in 2026 has achieved automatic comparison of logistics, capital flow, contract flow, and invoice flow; invoices for entrepot trade cannot be issued as special invoices for export tax refunds, and can only be issued as ordinary value-added tax invoices.
Enterprises must separately establish a document ledger for entrepot trade, retaining transaction contracts, logistics tracks, payment/receipt vouchers, and transit certificates one-to-one, with a retention period of no less than 10 years. If a tax bureau verification notice is received, submit the full set of supporting materials for entrepot trade immediately to demonstrate the authenticity of the business and avoid being identified as issuing false invoices.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The value of entrepot trade goods will be included as a core item in enterprise supply chain cost accounting. The latest International Commercial Terms in 2026 clarify that entrepot trade can flexibly switch between CIF and FOB trade terms according to transit needs to reduce logistics costs in transit.
Enterprises can deploy goods in advance at core transit ports such as Singapore and Malaysia through inventory linkage strategies, shorten overall transportation time, and reduce anti-dumping and countervailing duty costs. At the same time, establish a cost actuarial model for entrepot trade, including transit fees, re-stuffing fees, and compliance costs in the accounting scope, to avoid profit inversion.