Is two-time declaration mandatory for re-export trade customs clearance?

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I am a foreign trade manager engaged in re-export trade in Southeast Asia. Recently, we have a shipment of goods sent from Shanghai Port to Singapore, then transshipped to Vietnam. I heard from peers before that re-export trade requires two customs declarations, but our new staff only submitted one declaration during operation, and now we are worried about possible problems.

The goods have already arrived at the port of Singapore, and the freight forwarder is urging us to handle the follow-up procedures, but I am not sure whether it is mandatory to submit the second supplementary declaration, and I am also afraid that supplementary declaration will incur extra costs or lead to customs penalties. I want to know whether two declarations are mandatory for re-export trade, and how to remedy the situation if a declaration is missed.

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Expert Answer

Robert
RobertYears of service:6Customer Rating:5.0

Warehouse Management AdvisorStart a Chat

The requirement of two customs declarations for re-export trade is not absolute,and shall be determined according to the specific trade mode and customs supervision requirements. Taking Shanghai Port as an example,if the goods do not enter the local market at the transit port (such as Singapore) and only undergo transit storage or ship change,the second declaration may not be required,but it shall meet the customs supervision conditions for "transit goods".

For pre-document review,it is necessary to focus on checking whether the "transit clause" on the bill of lading clearly indicates "for transit only",and at the same time ensure that documents such as the certificate of origin and packing list are consistent with the transit route. In terms of core node connection,it is necessary to submit a transit application to the local customs through the freight forwarder before the goods arrive at the transit port,so as to avoid the goods being misjudged as imported goods.

If the second customs declaration has been missed,you shall immediately contact the freight forwarder at the transit port,provide proof that the goods have not entered the local market (such as storage agreement,ship change bill of lading),and apply to the customs for supplementary transit filing. In the contingency plan,if the goods have been detained by the customs,you shall submit the trade contract and logistics track certificate,explain the re-export intention,and strive for exemption from import duties and value-added tax.

The final compliance implementation shall ensure the "consistency of four streams": the logistics track (shipping company bill of lading,transit warehouse receipt),capital flow (foreign exchange settlement route),document flow (customs declaration form,certificate of origin) and contract flow (re-export trade contract) are fully matched,so as to avoid customs verification caused by inconsistent information.

Ella
EllaYears of service:10Customer Rating:5.0

Senior Financial AdvisorStart a Chat

The core of two customs declarations in re-export trade lies in "whether the ownership of goods is transferred or substantive processing is carried out". If the transit port is only a logistics node and the goods are not cleared into the local market, the second declaration is not required, but transit filing shall be handled at the customs of the transit port. Taking Shanghai Customs as an example, for transit filing, you need to submit the Customs Declaration Form for Transit Goods and transit agreement, indicating the final destination of the goods.

If the goods are unpacked, sorted or operated in other ways at the transit port, they may be regarded as imported goods, and import declaration shall be handled before export declaration, namely two declarations. If the declaration is missed, you shall submit the unprocessed certificate to the customs of the transit port and apply for correcting the declaration status, so as to avoid port detention fees and fines.

Sophia
SophiaYears of service:7Customer Rating:5.0

Senior Customs AdvisorStart a Chat

The logistics route of re-export trade determines the number of customs declarations. Direct transit (goods do not land) does not require a second declaration, but the shipping company shall provide a "through bill of lading" and mark the transit information. If ship change or storage is required at the transit port, "bonded storage" filing shall be handled locally, and no import declaration is required at this time, but the storage agreement shall be submitted to the customs.

If the goods stay at the transit port for longer than the specified time (for example, 7 days in Singapore), you need to apply for delayed filing, otherwise they may be forced to be cleared. It is recommended to select a freight forwarder with transit qualification and plan the logistics route in advance to avoid customs declaration risks caused by storage or ship change.

William
WilliamYears of service:10Customer Rating:5.0

International Logistics AdvisorStart a Chat

The tax treatment of re-export trade is related to the number of customs declarations. If it is only transit, there is no need to pay value-added tax or tariff in the transit country; if there is a second declaration (import and re-export), you need to pay attention to the VAT deferral policy of the transit country.

For example, Singapore allows zero VAT rate application for re-export goods, but proof of final destination is required. If the second declaration is missed, the tax authority of the transit country may deem the goods as imported, and you need to pay the overdue value-added tax and late fee. It is recommended to consult the tax authority of the transit country in advance to clarify tax obligations and avoid extra costs.

David
DavidYears of service:3Customer Rating:5.0

Business Development AdvisorStart a Chat

The compliance of foreign exchange receipt and payment for re-export trade shall match the number of customs declarations. If only one declaration is made (export to the transit port), the foreign exchange settlement shall indicate "re-export trade" and provide the transit agreement. If two declarations are made (import and re-export), foreign exchange receipt and payment procedures shall be handled respectively to ensure that the capital flow is consistent with the logistics.

The SWIFT message shall be marked with the transit route to avoid being identified as an abnormal transaction by the foreign exchange administration. If the second declaration is missed, you shall supplement the transit certificate to the bank and explain the purpose of funds to avoid account freezing.

Emily
EmilyYears of service:3Customer Rating:5.0

Client Success AdvisorStart a Chat

The contract clauses of re-export trade shall specify the responsibility for customs declaration. If the contract stipulates that the freight forwarder is responsible for customs declaration at the transit port, the specific obligations of "transit filing" or "second customs declaration" shall be specified in the agreement.

If losses are caused by the freight forwarder's missed declaration, the responsibility can be investigated in accordance with the contract. The force majeure clause shall cover the risk of customs delay at the transit port to avoid contract breach caused by customs declaration problems. It is recommended to add a "customs declaration compliance guarantee" clause in the contract to clarify the responsibility boundary of both parties.

Olivia
OliviaYears of service:5Customer Rating:5.0

Senior Customs AdvisorStart a Chat

During customs inspection at the transit port, if the goods have not gone through transit filing, they may be regarded as imported goods. During inspection, you need to provide the transit agreement, bill of lading for final destination and unprocessed certificate.

If there is a transit port mark on the goods packaging (such as local logistics label), you need to explain that it is a temporary label and the goods have not entered the local market. You shall cooperate with the customs to provide all documents during on-site inspection to avoid customs seizure caused by incomplete information.

Alexander
AlexanderYears of service:10Customer Rating:5.0

Senior Trade AdvisorStart a Chat

The packaging of re-export goods shall meet the requirements of the transit port and the final destination. If the transit port is located in a tropical region, moisture-proof packaging shall be adopted to avoid mildew of goods.

If the goods are dangerous goods, UN packaging verification shall be handled at the transit port to ensure compliance with local regulations. The packaging shall be marked with transit mark to avoid being misjudged as imported goods. If the packaging does not meet the requirements, it may lead to customs inspection at the transit port and delay the logistics time.

Charlotte
CharlotteYears of service:4Customer Rating:5.0

Currency Exchange AdvisorStart a Chat

The export tax rebate for re-export trade shall meet the "departure" condition. If the goods are only transited and do not leave the country, you cannot apply for export tax rebate. If two declarations are made (export to the transit port and then export to the final destination), you need to apply for tax rebate with the export declaration form of the final destination.

If the second declaration is missed, you need to supplement the customs declaration certificate of the final destination, otherwise you cannot enjoy the tax rebate policy. It is recommended to check all customs declaration documents before tax rebate declaration to ensure that they meet the tax rebate requirements.

John
JohnYears of service:6Customer Rating:5.0

Export Tax Rebate AdvisorStart a Chat

The supply chain design of re-export trade shall balance cost and compliance. When selecting a transit port, local customs declaration policies and logistics costs shall be considered. For example, Singapore has simple transit customs declaration procedures but high storage costs; Malaysia has lower transit costs but strict customs declaration requirements.

It is recommended to adopt the "bonded transit" mode to reduce the number of customs declarations and lower compliance risks. At the same time, optimize the inventory layout to avoid excessive stay of goods at the transit port, which may lead to extra costs.

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