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Is Transshipment Trade via Shanghai Permitted Under 2026 Policies?

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STATUS: 20261016 · VERIFIED
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I am an operations manager at a foreign trade company. Recently, we have a batch of Indonesian-produced palm oil that we plan to transship to Iran via Shanghai, involving third-country transshipment and certificates of origin. I heard that in 2026, customs will enforce particularly strict verification of certificates of origin for goods with "no substantial processing".

Our finance team is also concerned about VAT deferral and foreign exchange settlement issues. I want to know whether transshipment trade via Shanghai is currently allowed, and what key nodes we need to pay attention to during operations?

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Expert Answer

Daniel
DanielYears of service：8Customer Rating：5.0

Legal AdvisorStart a Chat

Shanghai fully supports transshipment trade in 2026，but a closed-loop system must be achieved through "full-link compliance + precise policy matching". Taking the transshipment of palm oil from Indonesia to Iran via Shanghai as an example，the following core links require key attention:

I. Pre-document Verification: Authenticity Check of Certificate of Origin is the Core. Shanghai Customs will implement the "Transshipment Trade White List System" in 2026. Third countries (such as Indonesia) need to provide a triplicate document package including "Certificate of Origin + Transshipment Port Logistics Track + Import Permit of the Final Destination Country". The "substantial processing" clause must be satisfied: no unpacking，mixed loading，or processing activities are allowed at the transshipment port. For example，if goods are temporarily stored in Yangshan Port Bonded Warehouse，the "Transshipment Certificate for Bonded Warehouse Goods" must be submitted. The customs system will automatically verify whether logistics data matches declaration information to avoid suspicion of "empty transshipment".

II. Core Node Coordination: Dynamic Balance Between Title to Goods and Declaration. Upon arrival at the port，"two-document matching" must be completed: the bill of lading (marked with "transshipment" + blank endorsement) and the "Transshipment Trade Contract Filing Form"，to ensure title to the goods remains with our party throughout the transshipment period. When declaring customs，adopt the "declare first，inspect later" mode，and proactively submit the "Goods Transit Risk Isolation Agreement" to customs，clarifying that goods will not enter domestic market circulation during transshipment，otherwise，"taxation as domestic sales" will be triggered.

III. Contingency Plans: Loss Mitigation Techniques for Port Detention and Customs Seizure. If an Iranian importer suddenly cancels the order，immediately activate the "emergency resale in bonded zone" process，utilizing Shanghai Free Trade Zone's 24-hour fast clearance channel for "emergency transshipment"，and complete new buyer qualification verification within 72 hours (proof of foreign exchange from the Central Bank of Iran is required). If customs questions the certificate of origin，submit production records and transportation documents from Indonesian factories via the "Cross-border Blockchain Traceability System" to achieve "second-level verification".

IV. Compliance Implementation: Long-term Closed-loop From Operations to Risk Control. It is recommended to apply for the "Shanghai Cross-border Trade RMB Settlement Pilot" qualification simultaneously，and complete foreign exchange payments via the CIPS system to avoid the risk of "account suspension" caused by SWIFT message delays. On the tax front，leverage the "special VAT treatment for transshipment trade" policy to apply for VAT deferral during the import stage，and declare tax refunds uniformly after goods leave the country. A single transaction can save approximately 12% of capital occupation costs.

Alexander
AlexanderYears of service：10Customer Rating：5.0

Senior Trade AdvisorStart a Chat

Chief Customs Declaration Expert: For transshipment trade, focus on verifying "HS code consistency of third-country certificates of origin". For example, the HS code for Indonesian palm oil is 15079000. If declared as 15111000 (refined palm oil) during transshipment, it will trigger a price assessment dispute. It is recommended to submit the "Transshipment Trade Price Declaration" 72 hours in advance, accompanied by temperature monitoring records of the overseas warehouse, to prove no processing has been performed on the goods.

Robert
RobertYears of service：6Customer Rating：5.0

Warehouse Management AdvisorStart a Chat

Senior Logistics Expert: In 2026, Shanghai Port will launch the "multimodal transport transshipment charter service". The "one-way direct voyage" from Yangshan Port to Bandar Abbas Port in Iran can reduce container detention fees to USD 0.8 per container per day. The bill of lading must use "order title + blank endorsement" to ensure title to goods can be transferred via telex release documents, avoiding "straight bill of lading disputes" caused by incorrect bill of lading titles.

John
JohnYears of service：6Customer Rating：5.0

Export Tax Rebate AdvisorStart a Chat

Senior Tax Consultant: Shanghai Free Trade Zone provides a combined policy of "VAT deferral + consumption tax exemption" for transshipment trade enterprises. Enterprises can temporarily exempt from paying VAT during import by presenting the "Transshipment Trade Filing Receipt", and apply for tax refunds by presenting the "Customs Declaration Form for Export Tax Refund" after goods leave the country. Note: Starting from 2026, "offshore resale transactions" must be accounted for separately to avoid confusion with domestic sales businesses.

William
WilliamYears of service：10Customer Rating：5.0

International Logistics AdvisorStart a Chat

Trade Compliance Expert: Foreign exchange settlement must match "CIPS message verification". When receiving foreign exchange, the remark "Transshipment Trade - Indonesia - Iran" must be added to avoid "account suspension and freezing" caused by incorrect SWIFT codes. If third-party payment is involved, verify in advance whether the counterparty is on the "white list" of Shanghai Foreign Exchange Administration; otherwise, a 5-working-day verification period will be triggered.

David
DavidYears of service：3Customer Rating：5.0

Business Development AdvisorStart a Chat

Foreign Trade Legal Expert: The contract must clearly specify the "transshipment liability division" clause, such as agreeing on "which party shall bear port detention losses caused by changes in customs policies". It is recommended to use a "demand guarantee" instead of traditional letters of credit, so that bank compensation can be obtained quickly in case of certificate of origin disputes, avoiding long-term detention of goods due to legal disputes.

Olivia
OliviaYears of service：5Customer Rating：5.0

Senior Customs AdvisorStart a Chat

On-site Inspection Expert: Before inspection, self-check whether there are "traces of substantial processing" on the goods, such as whether palm oil packaging labels contain the words "refined and processed in Shanghai". If customs requires unpacking inspection, make an appointment for "non-intrusive inspection" with the inspection department in advance to avoid cargo damage disputes caused by unpacking.

Sarah
SarahYears of service：3Customer Rating：5.0

Foreign Exchange AdvisorStart a Chat

Special Packaging Engineer: Iran has strict packaging requirements for imported goods. If additives are included, "UN3264 dangerous goods packaging" must be used, accompanied by an MSDS document. It is recommended to complete packaging reinforcement in Yangshan Port Bonded Zone to avoid packaging damage caused by long-distance transportation; otherwise, a fine of USD 5,000 per batch will be imposed.

Note: We respect all users' opinions and contributions. However, comments and answers reflect the views of their respective authors only.
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