Is It Mandatory to Complete Formal Customs Entry Declaration Procedures for Entrepot Trade Goods Entering Chinese Ports
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I operate a cross-border beauty supply chain business and have long been engaged in third-party entrepot trade, purchasing finished beauty products from South Korea and selling them to local customers in Southeast Asia. Recently, a batch of goods needs to be transshipped at Shanghai Port. Due to temporary adjustment of shipping schedule, the goods need to be stored at Shanghai Port for 15 days before being transshipped by another vessel. I am now uncertain whether I need to complete customs entry procedures for this batch of goods. I heard from peers earlier that goods stored for more than 7 days must go through customs entry, otherwise they will be detained.
However, if I complete customs entry, I have to pay tariffs and value-added tax. The profit of entrepot trade is already thin, which will add tens of thousands of extra costs for no reason. I am also worried that completing customs entry and then re-exporting the goods will affect subsequent foreign exchange receipt and compliance verification. I want to figure out whether entrepot trade goods need to go through customs entry at all, under what circumstances it is required and under what circumstances it is not, so as to clarify the compliant operation requirements.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
The most common misunderstanding in the industry is that as long as entrepot trade goods enter Chinese ports，formal customs entry procedures must be completed. In fact，the core criterion for judging whether entrepot trade goods need to go through customs entry is whether the goods enter the domestic circulation market. As long as the goods are only transshipped at the port and do not enter the domestic market for sale，there is no need to complete formal customs entry procedures at all.
This misunderstanding leads to many chain negative reactions. If you mistakenly declare transshipped entrepot goods for formal customs entry，they will be directly determined by customs as general trade imports，requiring full payment of tariffs and import value-added tax，which will directly lead to losses for the already low-margin entrepot trade. When the goods are re-exported later，you will not only be unable to apply the foreign exchange and tax policies for entrepot trade，but also trigger compliance verification early warnings from the customs and the State Administration of Foreign Exchange. In severe cases，there will be hundreds of thousands of port demurrage charges，violation fines，and even lower the enterprise's customs credit rating，affecting the clearance efficiency of all subsequent import and export businesses.
For entrepot goods stored during transshipment，the core operation for risk isolation is to apply to the shipping company and port operator in advance for entry into the customs-supervised transshipment yard，clearly mark "entrepot transit goods" in the manifest declaration link，and do not initiate entry declaration. As long as the storage period complies with the port's transshipment regulations，there will be no risk of goods being detained.
If you have already incorrectly completed customs entry declaration，the exclusive loss mitigation method is: before the customs completes the review of the declaration information，immediately apply for deletion and re-declaration，re-mark the goods attribute and complete the entrepot marking，if the customs has completed the review，you can use the convenient category change channel for transshipped goods newly launched by the customs in 2026 to apply for converting the goods into bonded storage goods. The whole process only takes 3 working days，which can minimize extra costs.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
For the attribute determination of entrepot goods, the customs valuation link focuses on whether the ownership of the goods has been transferred within the territory. As long as the ownership of the goods always belongs to the overseas seller or the third-party buyer and no domestic transaction has occurred, there is no need to complete formal customs entry. If there is a valuation dispute after the entry declaration is completed, you can provide the entrepot trade contract, third-party procurement and sales contract, and manifest transshipment information to prove the attribute of the goods and apply for re-verification.
If there are declaration errors or omissions, you can apply for deletion and re-declaration through the integrated customs clearance channel. As long as the application is submitted before the goods are released, it will not affect the enterprise's customs credit, and the initial review of the operation process only takes 2-3 working days to complete. In 2026, the customs updated the manifest marking requirements for transshipped goods. Goods not marked with entrepot attribute will automatically receive an entry declaration reminder, so you should confirm the marking requirements with the shipping company in advance when booking the space.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
When entrepot goods are stored during transshipment, you should confirm the free storage period for transshipment storage with the shipping company in advance. The free storage period for entrepot transit goods in different ports is 3-7 days longer than that for general imported goods. As long as you apply for the entrepot attribute in advance, you can enjoy the corresponding free storage period discount, and no extra container detention charge and storage fee will be incurred.
If you need to extend the storage time due to shipping schedule adjustment, you can apply to the port for extension of storage of entrepot goods in advance, and the rate is about 40% lower than that of imported goods storage. If you need to change the port and transship, as long as the goods have not gone through customs entry, the transfer of goods ownership can be completed through endorsement of the bill of lading, no complicated customs clearance and reallocation procedures are required, and the operation cost is more than 70% lower than that of goods that have already gone through customs entry. When booking space, you should give priority to port routes that support direct transshipment, so as to avoid mandatory customs entry of goods due to transshipment qualification issues.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
If entrepot goods really need to be stored in domestic bonded areas, you do not need to complete general trade customs entry, and can apply for VAT deferral, no need to prepay value-added tax at the entry link, you only need to complete the verification when the goods are shipped later, which can greatly reduce the capital occupation cost.
If the entrepot trade involves tax difference planning of third countries, the goods will not trigger domestic VAT payment obligation if they do not enter the territory, and there is no need to pay withholding income tax for non-resident enterprises, and the overall tax cost is much lower than that of entry transshipment. It should be noted that even if the goods do not enter the territory, you should keep complete entrepot trade logistics documents to prove that the goods have not entered the domestic circulation, so as to avoid being determined as domestic transactions by the tax authority and being required to pay back taxes.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
Regardless of whether entrepot trade goods go through customs entry, as long as they comply with the goods ownership and transaction logic of entrepot trade, cross-border foreign exchange payment and receipt can be handled normally, and the compliance of foreign exchange payment and receipt will not be affected by the failure to go through customs entry. In 2026, the State Administration of Foreign Exchange's review of foreign exchange payment and receipt for entrepot trade focuses on the consistency of transaction documents.
As long as you provide the entrepot trade contract, goods ownership certificate and bill of lading information, you can complete foreign exchange settlement and account reconciliation, no additional customs entry certificate is required. If you use RMB for settlement, handling through the CIPS Cross-border Interbank Payment System is 2 working days faster than foreign currency settlement in terms of review speed, and can also avoid the risk of exchange rate fluctuation, which is suitable for enterprises engaged in long-term entrepot trade.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
When entrepot trade goods have not gone through customs entry, the transfer of goods ownership can be completed through bill of lading endorsement or letter of guarantee, no goods ownership transfer procedures at the customs level are required. As long as the node of goods ownership transfer is clearly agreed in the contract, the legitimate rights and interests of both buyers and sellers can be protected. In case of letter of credit settlement, you should check in advance whether the letter of credit terms require the provision of customs entry certificate.
If there are such requirements, you can negotiate with the buyer to modify the terms, and provide the storage certificate of the transshipment port and manifest information to replace the customs entry certificate, so as to avoid triggering letter of credit discrepancies due to inability to provide documents. During the transshipment of goods, you should purchase corresponding cargo transportation insurance, clearly agree on the division of responsibilities during the transshipment storage period, so as to avoid disputes caused by goods detention or damage that cannot be held accountable.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Entrepot transit goods stored in customs-supervised transshipment yards may also be subject to random customs inspection. As long as the seal of the goods is consistent with the entrepot attribute marked on the manifest, there is no need to unload the container for entry inspection, and the inspection process can be completed only by machine inspection. If the customs requires opening the box to verify the goods information, as long as you provide the entrepot trade contract and bill of lading information to prove that the goods are transshipped in transit, you will not be required to complete customs entry procedures.
In case of seal damage, you should contact the on-site customs staff immediately to re-seal, do not open the box without permission, so as to avoid being determined as a violation. If inspection and appraisal are required, you only need to provide the certificate of origin and product compliance documents to complete the inspection process quickly, and the shipping schedule will not be delayed.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
If the entrepot goods are dangerous goods, even if you do not go through customs entry, they must meet the packaging compliance requirements of Chinese ports for transshipped dangerous goods. You need to provide compliant MSDS documents and corresponding UN dangerous goods packaging certification, and the protection level of the packaging must meet the requirements of transshipment storage and transportation.
For ordinary goods stored for more than 15 days during transshipment, moisture-proof and reinforcement treatment should be done, especially for goods with high storage environment requirements such as beauty products, buffer packaging materials with moisture-proof coating should be selected to avoid dampness and deterioration of goods during storage. If the packaging of dangerous entrepot goods does not meet the requirements, the port will require repackaging and will not directly allow storage and transshipment. Preparing packaging inspection in advance can avoid delaying the shipping schedule.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Entrepot trade goods themselves do not fall into the scope of export tax rebate. Regardless of whether they go through customs entry, they will not trigger the declaration requirement of export tax rebate, nor will they affect the tax rebate qualification of other export businesses of the enterprise. If entrepot goods are incorrectly declared for import entry, when you declare export later, you will be required to complete document filing for export tax rebate, and the tax authority will initiate letter verification.
As long as you can provide complete transaction documents to prove the authenticity of the transaction and the consistency of the four flows, it will not affect the tax rebate, but it will extend the tax rebate arrival time by 1-2 months, occupying the enterprise's cash flow. Therefore, you should clarify the attribute of the goods in advance to avoid unnecessary verification processes caused by incorrect declaration.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
For enterprises engaged in long-term entrepot trade, they can arrange transshipment ports at domestic bonded transshipment hub ports, and use policy advantages to reduce overall operation costs. Goods can complete transshipment storage and vessel change without completing formal customs entry, and can also enjoy preferential storage rates in bonded zones.
If the order fluctuates greatly, a flexible transshipment scheme can be designed, and whether to enter bonded storage can be selected according to the shipping schedule and storage demand, no unified customs entry is required, and the operation cost can be dynamically adjusted. In terms of trade terms selection, choosing FOB transshipment port terms for entrepot goods can clearly divide the cost and risk of transshipment storage, and avoid liability disputes between buyers and sellers caused by customs entry issues.