What specifications should be followed to complete customs declaration procedures when conducting entrepot trade?
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I am a foreign trade enterprise engaged in cross-border building materials wholesale, and recently received my first entrepot trade order. The goods will be shipped from Southeast Asia to Europe, transiting via Shanghai Bonded Area for storage. I have only done general import and export trade before, and have no experience in entrepot customs declaration at all.
Now I am stuck here and don't know how to operate. I heard that customs declaration requirements vary in different scenarios for entrepot trade; if declared incorrectly, not only will high demurrage fees be generated, but also the customs credit rating of our enterprise may be affected.
The ship departure is less than ten days away, I am so anxious that I can't sleep. I just want to figure out how to declare customs for entrepot trade in different scenarios, what materials need to be prepared in advance, and what pitfalls must be avoided?
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
Entrepot trade should be operated in scenarios based on whether the goods enter China’s customs territory，the customs declaration requirements of the two scenarios differ greatly，and can be promoted step by step according to the entire chain nodes.
Pre-documentation verification is the core prerequisite for the entire process. Regardless of the scenario，complete documents such as the entrepot trade contract，cargo ownership transfer certificate，and transit instruction documents must be prepared in advance. For goods entering domestic bonded regulatory areas，the transit warehousing agreement signed with the bonded warehouse must also be prepared in advance. During the verification process，confirm that the ownership transfer logic of the entire trade chain is clear and there are no document conflicts.
Core nodes should be operated corresponding to scenarios: for goods that do not enter China’s customs territory and only transit overseas，no customs declaration procedures need to be completed with domestic customs，only the carrier needs to complete transit manifest declaration，for goods entering bonded regulatory areas for transit，when the goods enter the territory，first go through import record-filing with customs，and when the goods are transferred out for departure，go through export record-filing. The entire process can be completed online through the Golden Phase II system.
Exceptional plans need to be set in advance. If there is a valuation inquiry，complete trade cost documents must be prepared in advance to prove the rationality of the entrepot price difference，if on-site inspection is encountered，cooperate with customs to provide a full set of ownership documents. Finally，for compliant implementation，keep a full set of documents，and all relevant documents shall be retained for at least 5 years for future customs inspections.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
Valuation is the core focus of customs review, and most declaration errors and violations occur in the valuation stage. The transaction price of entrepot trade should include reasonable price differences in the entire trade chain; if the declared price deviates significantly from the market reasonable range, customs valuation inquiry will be triggered, prolonging customs clearance time, and in serious cases, it will be identified as incorrect price declaration, affecting the customs credit rating of the enterprise.
When declaring, proactively attach documents such as third-country purchase contracts, original manufacturer invoices, and cargo ownership transfer agreements to clearly explain the reasons for the price difference. If a valuation dispute has already arisen, provide transaction data of similar entrepot trade in the same period to assist customs in completing price consultations and clearing customs as soon as possible. If there are cases of suspension or delayed processing, organize a full set of documents in time to apply for cancellation and re-declaration, to avoid additional demurrage fees.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
Cargo ownership control and logistics declaration in the transit stage of entrepot trade must match customs declaration. If the goods are transited at domestic ports, the endorsement transfer process of the bill of lading must be consistent with the ownership information in the customs declaration. If a change of transit port is required, declare the port change information to customs in advance, adjust the manifest data, and avoid inconsistencies between manifest information and customs declaration information that may lead to cargo detention.
If the transit goods need to be stored at the port, apply for the corresponding free storage period in advance. Goods beyond the free storage period will generate high detention fees and storage fees, increasing trade costs. When selecting a transit plan, confirm the customs declaration requirements for entrepot trade at the transit port in advance. The regulatory details vary slightly among different ports; make advance connections to avoid situations such as rejected containers, overbooked space leading to delayed ship schedules, which affect customs declaration timeliness.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
The customs declaration stage of entrepot trade must be compliant with the tax structure. If goods enter domestic bonded areas for transit, apply for VAT deferral, no value-added tax is required to be paid during the import stage, reducing capital occupation and financial costs. If related transactions are involved in entrepot trade, the declared price in customs declaration must comply with the arm's length principle to avoid triggering BEPS-related investigations.
If non-resident enterprise income is involved, confirm the withholding tax payment requirements in advance, and declare the corresponding information at the customs declaration stage to avoid tax compliance risks. The tax treatment of entrepot trade varies in different scenarios; sort out the trade chain in advance, match the corresponding tax policies, ensure that the logic of customs declaration and tax treatment is consistent, avoid contradictions that trigger regulatory inspections.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Customs declaration information of entrepot trade must be consistent with cross-border payment and foreign exchange information. When making payments and receiving foreign exchange, provide the corresponding customs declaration record information to the payment institution. If RMB cross-border payment is used, ensure that the trade information of the CIPS message matches the customs declaration information, to avoid verification of payment and foreign exchange.
The time limit for payment and foreign exchange for entrepot trade must match the time limit for import and export in customs declaration; avoid long-term outstanding balances. If the goods are transited overseas without domestic customs procedures, retain a full set of trade documents, including purchase contracts, bills of lading, and cargo ownership transfer documents, for foreign exchange compliance verification, ensuring that the entire payment and foreign exchange process meets foreign exchange regulatory requirements and avoids impacting subsequent business operations.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
When transit goods of entrepot trade are inspected, first confirm the integrity of the seal. If the seal is damaged, take photos and retain evidence immediately, and notify the customs inspector. Entrepot goods are generally original-packaged goods that have not entered domestic circulation; no additional container opening and sorting are required. Cooperate with customs to provide the full set of customs declaration documents and ownership documents, and explain the transit purpose of the goods.
If customs requires testing and appraisal, promptly provide the corresponding MSDS or product manual of the goods, cooperate with the testing process, shorten the inspection processing time, and avoid additional demurrage fees. If there are objections to the test report results, apply for re-inspection within the specified time limit to safeguard legitimate rights and interests.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
Entrepot trade generally does not involve export tax refund, but if the goods are purchased domestically and then transshipped, confirm whether they meet the refund requirements. The customs declaration record information must be consistent with foreign exchange receipt information, cargo flow information, and invoice information, meeting the four-flow consistency verification requirements.
If tax refund is required, prepare documents for filing in advance, organize and archive the customs declaration record form, bill of lading, contract, and foreign exchange receipt voucher of entrepot trade, and cooperate with the tax authority to complete correspondence inspection, avoiding tax refund failure due to incomplete documents. If the declaration is cross-monthly, complete pre-declaration verification in the declaration system in advance, confirm that the data is correct before formal declaration, reduce the probability of declaration errors, and avoid delaying the tax refund progress.