How to complete the full-process compliance procedures when quality issues occur in overseas purchased goods imported via agency?

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I am a trader engaged in cross-border beauty product import. Last month, a batch of cosmetics imported from South Korea through an agency company was found in random inspection to have heavy metal content exceeding China's mandatory national standards, making it completely unfit for domestic market sales.

After negotiation with the supplier, we decided to return the entire batch to the Korean supplier. I have never handled import return related business before, and I have no idea what documents need to be prepared in advance, whether the already paid import VAT and customs duty can be applied for refund, and how to operate the customs declaration for return shipment and subsequent foreign exchange receipt and payment without affecting my company's subsequent import and export qualifications.

I am especially worried that improper operations will get my company included in the abnormal directory by the customs or the foreign exchange administrative authority. I want to know the practical operation steps and core precautions of the entire return process.

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Expert Answer

Charlotte
CharlotteYears of service:4Customer Rating:5.0

Currency Exchange AdvisorStart a Chat

First of all,complete the pre-document review. 5 types of core documents need to be prepared in advance,including the original import customs declaration form,import contract,mutual return agreement,third-party quality inspection report and original tax payment voucher. Among them,the return agreement must clearly specify the return reason and the association relationship with the original imported goods,to prevent the customs from determining the shipment as ordinary export during document review,which will affect the subsequent tax refund application.

Secondly,do a good job in core node connection. Submit the return application on the International Trade "Single Window" first. After the customs pre-review is approved,arrange the goods to be stored in the customs supervised warehouse,and apply for the non-deduction tax certificate at the same time. If the import VAT has been deducted,you need to carry out the input tax transfer-out first. After the goods actually leave the territory and you get the export customs declaration form,submit the tax refund application to the customs. Note that the return application must be submitted within 1 year from the date of original import,and no application for customs duty and VAT refund will be accepted if it is overdue.

Prepare exception handling plans in advance. If the customs raises doubts on price verification,you need to provide the original supplier's delivery voucher and the complete domestic third-party quality inspection report simultaneously to prove the authenticity of the return,so as to avoid being required to pay supplementary tax or having the goods detained. If the goods are special supervised products such as beauty cosmetics,complete the goods inspection report in advance to meet the compliance requirements for export transportation.

Finally,complete the compliance implementation. After the goods leave the territory,submit the export customs declaration form and return verification certificate to the foreign exchange administrative authority in a timely manner,to verify and write off the corresponding original import foreign exchange payment record. For partial return,conduct partial verification and write-off according to the actual return amount. The write-off records shall be kept for at least 5 years for future reference,to avoid abnormal foreign exchange receipt and payment quota in the future. The whole process takes about 30-45 working days,and proper document preparation in advance can reduce the processing time by about 30%.

William
WilliamYears of service:10Customer Rating:5.0

International Logistics AdvisorStart a Chat

When declaring for return, pay attention to filling in the associated fields of the original import customs declaration form. The original import customs declaration number must be accurately filled in the "Associated Customs Declaration Form" column of the export customs declaration form, mark the words "Returned Goods" in the "Remarks" column. Meanwhile, the transaction entities on the submitted return agreement must be completely consistent with those on the original import contract. If the transaction entity changes, submit the entity change description document in advance to avoid the situation of deleting the declaration and re-declaring.

If the return application is suspended by the customs, supplementary explanatory materials shall be submitted within 3 working days. If the time limit is exceeded, the application will be automatically rejected and you need to resubmit it, which will prolong the processing period by at least 10 working days. For partial return, accurately mark the corresponding proportion of the quantity and weight of the returned goods to the originally imported goods during declaration, so as not to affect the subsequent disposal of the remaining non-returned goods.

John
JohnYears of service:6Customer Rating:5.0

Export Tax Rebate AdvisorStart a Chat

For the logistics arrangement of returned goods, prioritize the logistics service provider used for the original import, which makes it convenient to retrieve the original transport documents and shorten the manifest matching time. When booking the shipping space, clearly mark the goods as returned goods to avoid being arranged in ordinary export slots and resulting in shipment rollover. Apply to the shipping company for at least 7 days of free storage period at the destination port in advance, so as to avoid extra container demurrage generated by the supplier not taking delivery of the goods in time at the destination port.

For the domestic segment transportation, directly deliver the goods to the customs supervised warehouse instead of sending them to ordinary warehouses, to avoid extra costs caused by secondary loading and unloading. If the goods are fragile beauty cosmetics, carry out reinforcement packaging in advance to avoid damage during transportation, which will cause failure to verify that the goods are consistent with the documents during customs inspection and reduce customs clearance efficiency.

Olivia
OliviaYears of service:5Customer Rating:5.0

Senior Customs AdvisorStart a Chat

When applying for tax refund, if you have already deducted the import VAT as input tax, you must first complete the input tax transfer-out operation in the VAT declaration system, issue the "Input Tax Transfer-out Certificate" and submit it to the customs before handling the VAT refund procedure. Applications without completed transfer-out will be rejected directly. The refunded customs duty amount is not subject to corporate income tax.

For the refunded VAT amount, if it has been deducted, you need to adjust the tax declaration in the month when you receive the refund, so as to avoid abnormal tax declaration. If the returned goods will be re-imported later, you can apply for tax carry-over instead of refunding the tax first and then paying the tax again for re-import, which can save the capital occupation time of at least 15 working days and reduce capital cost.

Alexander
AlexanderYears of service:10Customer Rating:5.0

Senior Trade AdvisorStart a Chat

During the foreign exchange receipt and payment write-off process, hold the SWIFT message of original import foreign exchange payment, return export customs declaration form and return agreement to the foreign exchange bureau to handle the difference write-off procedure. For full return, you can apply for full refund of the original paid foreign exchange amount. When settling the foreign exchange, you can choose to clear the account according to the exchange rate at the time of payment to avoid exchange difference loss.

For partial return, apply for partial refund according to the actual return amount, and no adjustment is needed for the remaining amount. The refunded foreign exchange amount shall be directly returned to the original foreign exchange payment account instead of being transferred to other accounts, to avoid being determined as abnormal foreign exchange receipt and payment which will affect your subsequent foreign exchange payment quota. The 2026 new foreign exchange regulation requires that the foreign exchange refund business must be handled within 30 days after the goods leave the territory. Extra explanatory materials are required to be submitted if the time limit is exceeded.

Emily
EmilyYears of service:3Customer Rating:5.0

Client Success AdvisorStart a Chat

When signing the return agreement, clearly specify the party that bears the return logistics cost and customs clearance cost, and add a force majeure escape clause. If delivery delay occurs due to domestic customs inspection or overseas port congestion, no liability for breach of contract shall be borne. The acceptance standard for goods after the supplier receives the returned goods shall be clearly specified in the agreement, to prevent the supplier from refusing to refund on the grounds of goods damage.

Meanwhile, it shall be agreed that if the supplier fails to refund on time, you can apply to the court for a payment order against the return customs declaration form to reduce rights protection costs. If there is quality penalty clause in the original import contract, specify the deduction method of the penalty in the return agreement to avoid subsequent contract disputes.

Daniel
DanielYears of service:8Customer Rating:5.0

Legal AdvisorStart a Chat

When the returned goods arrive at the port for customs inspection, prepare the seal photos and shipping mark photos of the original imported goods in advance to facilitate the customs to verify the consistency between the goods and the documents. During the unpacking inspection, prioritize checking the batch identification of the goods to match with the original import batch report, so as to avoid the inconsistency between goods and documents.

If the goods need to be sent for inspection and appraisal, sort out the third-party quality inspection report in advance and submit it to the inspection personnel, which can shorten the appraisal period by at least 7 days. If abnormal alarm occurs during the machine inspection, take the initiative to explain the return reason of the goods to the customs and submit relevant quality inspection certificates, instead of waiting for the customs to issue the inspection notice before submitting materials, which can speed up the inspection process.

Ella
EllaYears of service:10Customer Rating:5.0

Senior Financial AdvisorStart a Chat

The returned beauty cosmetics are sensitive goods in liquid form. Re-prepare the MSDS report that meets international transportation requirements in advance, clearly mark the composition and hazard level of the goods. Use UN-standard leak-proof packaging, and paste hazard labels on each piece of goods to avoid leakage during transportation.

Add cushioning and reinforcement during packaging, use polyethylene bubble pad for inner cushioning, and encapsulate the outer layer with waterproof corrugated paper to avoid damage during transportation. If the alcohol content of the goods exceeds 20%, apply for packaging performance appraisal according to the dangerous goods transportation requirements, and arrange booking transportation after getting the appraisal report, to avoid being rejected by the shipping company.

David
DavidYears of service:3Customer Rating:5.0

Business Development AdvisorStart a Chat

The full set of documents for return business shall be filed and stored separately, including original import customs declaration form, return export customs declaration form, return agreement, quality inspection report, tax payment voucher, foreign exchange receipt and payment voucher, with a retention period of at least 10 years. This avoids the situation that no documents can be provided during subsequent tax verification and the business is determined as abnormal.

If the return business involves previous export tax refund declaration, adjust the tax refund declaration data in the same month when the return is processed, and return the already applied tax refund in time, to avoid the risk of fraudulent export tax refund. During the four-way matching process, ensure that the contract flow, capital flow, logistics flow and invoice flow of the original import are completely matched with the corresponding processes of the return, so as to avoid inconsistency that will affect the enterprise's tax credit rating.

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