What specifications should be followed to fill in all information on a bill of lading for an entrepot trade operation?
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We are a foreign trade enterprise engaged in the export of light industrial small commodities from East China. Recently, due to anti-dumping against China by the destination country, we have adjusted our trade route to engage in third-country transit entrepot trade, which is the first time our company has operated an entrepot trade business. Last week, the freight forwarder provided a draft bill of lading for us to confirm the filling content.
I filled it based on the experience of general trade operations before, but the more I filled, the more flustered I became, fearing that any mistake would cause problems. I heard from a colleague before that a company made an error in filling in the bill of lading for entrepot trade, which led to customs detention at the destination port, and the customs also verified the fact of entrepot trade. The anti-dumping duty was not reduced at all, and they were also fined additionally.
I am not sure about several core contents now: whether the consignee should be a third party in the transit country or the final buyer? Should the goods description show the place of origin? How should the shipper be filled in to comply with regulations? I want to figure out the correct filling rules.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
There are three common misunderstandings in filling in bills of lading for entrepot trade in the industry: First，directly displaying the final consignee in the consignee column of the bill of lading，Second，clearly marking the place of origin as China in the goods description，Third，still filling in the actual domestic shipper as the shipper. These three errors seem trivial，but in reality，they will trigger a chain of negative reactions.
If the final consignee is directly marked，the customs of the destination country can directly trace the actual place of departure of the goods，which will easily confirm the fact that entrepot trade is used to avoid anti-dumping duties. The minimum requirement is to pay the full anti-dumping duty retroactively，and the worst case is direct cargo detention and fines，even being recorded in the blacklist to affect the customs clearance of all subsequent goods. If the place of origin information is filled incorrectly，it will also lead to inconsistent tax numbers in the transit country，making it impossible for the transit country to issue a valid certificate of origin，and the entire subsequent trade chain will be interrupted. In addition，high demurrage and container detention fees may be incurred.
The core operation of physical risk isolation is: fill in the consignee column of the entrepot trade bill of lading with the cooperative customs clearance company in the transit country，which facilitates subsequent endorsement transfer of the bill of lading to the final buyer，do not mark specific place of origin information in the goods description column，only show basic information such as goods name，specifications，weight，etc。fill in the shipper column with the cooperative trade entity in the transit country，matching the information of the certificate of origin issued by the transit country.
If the bill of lading has already been filled incorrectly，contact the shipping company immediately to apply for deleting the order and re-declaring，and complete the modification within seven days after the ship sails. Most shipping companies will not charge high amendment fees，and it will not affect the subsequent customs clearance process. In daily operations，the special filling requirements for entrepot trade must be clearly marked in the booking confirmation letter provided to the freight forwarder，so as to avoid mistakes in the draft and delay.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
After the bill of lading for entrepot trade is filled in, it needs to be compared with the declaration information of the customs declaration form to ensure that core information such as goods name, weight, container number, seal number, etc. are completely consistent. If it is an entrepot trade that exchanges documents through the transit country, the information of the original ocean bill of lading needs to match the information of the forwarder's bill of lading issued by the transit country. Once there is an information deviation, the customs will directly trigger manual inspection and require the provision of a complete set of materials such as trade contracts, capital flows, etc. to prove the authenticity of the trade.
Information errors will lead to deleting the order and re-declaring, and will also trigger customs price verification, suspecting under-declaration of tax evasion. If there is a discrepancy between the declaration information and the bill of lading information, prepare a complete set of trade chain materials as soon as possible, take the initiative to explain the situation to the customs, and cooperate with the inspection, so as to avoid being identified as false declaration and affecting the enterprise's credit rating.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
During the transit process of entrepot trade, the process of bill of lading endorsement transfer is involved. When filling in the bill of lading, reserve an endorsement position. When filling in the consignee as the transit country's company, ensure that the company name is completely consistent with the name filed by the transit country, so as to avoid the endorsement being invalid and the goods title cannot be transferred normally.
If it is a full-container entrepot trade, it is necessary to clearly mark the transit port on the bill of lading. When changing ships, notify the shipping company in time to update the bill of lading information, so as to avoid mis shipment to other ports.
If container detention occurs at the transit port, incorrect bill of lading information will lead to inability to complete the container pickup procedures normally and incur additional container detention fees. Therefore, all information must be checked carefully before signing, especially the relevant markings for transit operations, to reduce the additional costs incurred by subsequent amendments.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
The information filled in the bill of lading for entrepot trade will affect subsequent tax declarations, including the VAT declaration of the transit country and the import duty calculation of the final destination country. If the trade entity information on the bill of lading does not match the actual tax payment entity, it will lead to the failure to handle VAT deferral normally, and the full amount of VAT needs to be prepaid, occupying the enterprise's cash flow.
For entrepot trade involving related party transactions, the bill of lading information must be consistent with the pricing data of related party transactions, so as to avoid being identified as profit transfer by the tax authority, triggering BEPS-related investigations, and requiring the payment of enterprise income tax and withholding tax. When filling in the bill of lading, confirm the entity information in the tax structure in advance, ensure that all documents match the trade structure, and reduce tax risks.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
The compliance requirements for foreign exchange settlement and payment in entrepot trade require that the bill of lading information be consistent with the foreign exchange settlement and payment entities, otherwise it will affect the foreign exchange settlement verification, and be judged as abnormal foreign exchange settlement and payment, affecting the normal use of the enterprise's offshore accounts and domestic settlement accounts. If cross-border RMB settlement is used, the goods title information on the bill of lading must be consistent with the transaction information of the CIPS message.
Inconsistent information will lead to the message being returned, and the capital liquidation cannot be completed normally. Before filling in the bill of lading, confirm the core information requirements with the settlement bank, ensure that the transaction entity, goods information and capital flow information are consistent, meet the verification requirements of foreign exchange compliance, and avoid the problem of funds being suspended and unable to be settled.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
In entrepot trade, the bill of lading is the core certificate of goods title. Incorrect filling will lead to disputes over the ownership of goods title. Once a trade dispute occurs, inconsistent bill of lading information will affect the claim of goods title, and even lead to loss of both goods and funds.
For entrepot trade settled by letter of credit, the bill of lading filling must strictly comply with the terms of the letter of credit, to avoid discrepancies leading to bank refusal of payment. If a bank guarantee is required to ensure the transfer of goods title, the consignee information on the bill of lading must be consistent with the entity in the guarantee, otherwise the guarantee will be invalid. When filling in the bill of lading, check it one by one against the trade contract and letter of credit terms, avoid soft clause traps, and protect your own legitimate rights and interests.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
If it is an entrepot trade with domestic shipment, the bill of lading information will affect the document filing for export tax refund, requiring the bill of lading information to be consistent with the information of the export contract, foreign exchange settlement voucher, and packing list. Otherwise, it will trigger the tax authority's letter investigation, be identified as non-compliant documents, deny the export tax refund, and even require the payment of the refunded tax.
For the export tax refund declaration of entrepot trade, file the relevant entrepot trade agreement and copy of the bill of lading together, ensuring that the issuance time of the bill of lading, goods information and declaration information are completely consistent. If the bill of lading information is incorrect, amend the order and re-file in time, so as to avoid affecting the tax refund process and causing unnecessary losses to the enterprise.